Globally Harmonized System GHS Change from Material Safety

Globally Harmonized System (GHS) Change from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS) Pesticide Education Program

Objectives • • History of GHS Major Changes Under GHS What Do You Need to Do Step by Step Compliance Pesticide Education Program

History of GHS • An international mandate to harmonize labels was adopted at the United Nations Conference on the Environment and Development (UNCED) in 1992 in Brazil: – A globally-harmonized hazard classification and compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible, by the year 2000. Pesticide Education Program

In March 2012, Occupational Safety and Health Administration (OSHA) published a final rule to align its Hazardous Communication Standards (HCS) regulations with the Globally Harmonized System (GHS) of Classification and labeling of chemicals Pesticide Education Program

The primary goal of GHS is improved protection of human health and the environment by providing chemical users and handlers with enhanced and consistent information on chemical hazards. Pesticide Education Program

The GHS is based on major existing systems for industrial chemicals, pesticides, consumer chemicals, and chemicals in transport, but implementation of the GHS would require some changes in all existing systems in order to achieve harmonization. Pesticide Education Program

However, it is important for growers who use Federally regulated pesticides to note that the Environment Protection Agency (EPA) has NOT yet moved to amend its pesticide labeling regulations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to align with the GHS. Pesticide Education Program

Why the switch from MSDS to SDS? Under the Haz. Com 2012, the MSDS will be replaced with a Safety Data Sheet (SDS). Pesticide Education Program

Why the switch from MSDS to SDS? • Before the Haz. Com 2012, there were several acceptable MSDS formats. OSHA’s adoption of Global Harmonization Standards (GHS) requires the use of a single format. • All SDS will have 16 sections that appear in a specific order. Pesticide Education Program

Major Changes Under GHS Pesticide Education Program

Changes • MSDS to SDS Format • Labeling Requirements/Pictograms • Hazard Classification Pesticide Education Program

Changes • MSDS to SDS Format – MSDS will now be referred to as Safety Data Sheets (SDS). – There is now a specified 16 -section format that must be followed. Pesticide Education Program

Section 1 Identification of Substance and Supplier • Includes – Product identifier (Product Name). – Manufacturer’s or distributor’s name, address and phone number. – Emergency phone number. – Recommended use. – Restrictions on use. Pesticide Education Program

Section 2 Hazard Identification • Includes: – All hazards regarding the chemical. – Required label elements: • Pictograms. • Signal Word. • Hazard Statements. Pesticide Education Program

Section 2 Hazard Identification Signal Words (OSHA): – Warning. – Danger. Pesticide Education Program

Section 3 Composition/Information on Ingredients • Includes: – Composition/information on ingredients: • Common Name. • CAS number. • Concentration. – Information on chemical ingredients. – Trade secret claims. Pesticide Education Program

Section 4 First Aid Measures • Includes: – Important symptoms. – Acute symptoms. – Delayed symptoms. – Required treatment based on route of exposure. Pesticide Education Program

Section 5 Firefighting Measures • Includes: – Suitable extinguishing techniques. – Equipment needed. – Chemical hazards from fire. Pesticide Education Program

Section 6 Accidental Release Measures • Includes: – Emergency procedures. – Protective equipment. – Proper methods of containment and cleanup. Pesticide Education Program

Section 7 Handling and Storage • Includes: – Precautions for safe handling. – Precautions for safe storage. – Incompatibilities. Pesticide Education Program

Section 8 Precautions to Control Exposure/ Personal Protection • Includes: – OSHA’s Permissible Exposure Limits (PELs). – Threshold Limit Values (TLVs). – Appropriate engineering controls. – Personal Protective Equipment (PPE) requirements. Pesticide Education Program

Section 9 Physical and Chemical Properties • Includes: – Chemical’s characteristics. Pesticide Education Program

Section 10 Stability and Reactivity • Includes: – Stability of chemical. – Chemical characteristics. Pesticide Education Program

Section 11 Toxicological Information • Includes: – Routes of exposure. – Related symptoms. – Acute effects. – Chronic effects. – Numerical measures of toxicity. • LD 50 values and LC 50 values. Pesticide Education Program

OSHA does not regulate sections 12 to 16 since other Agencies (like the EPA) regulate information in these sections. Pesticide Education Program

Section 12 Ecological Information • Includes: – Eco-toxicity. – Mobility. • Does it move in air, soil, or water. – Degradability. • Is it biodegradable. – Bioaccumulation. Pesticide Education Program

Section 13 Waste Disposal Consideration • Includes: – Advise to contact local wasted disposal authority for direction on disposal. – Information that directs washing liquids should not be allowed to enter drains. – Directions for container disposal. – Recommendations for disposal if recycling is not an option. Pesticide Education Program

Section 14 Transportation Information • Includes: – Proper shipping name. – Hazard class. – Secondary risk. – Identification information. – Packing group. – Label required. – Marine pollutant identification. Pesticide Education Program

Section 15 Regulatory Information For pesticides this is the area where any FIFRA information would be included, for example: “Pesticide Registration: This chemical is a pesticide product registered by the Environmental Protection Agency and is subject to certain labeling requirements under federal pesticide law. These requirements differ from the classification criteria and hazard information required for safety data sheets, and for workplace labels of non-pesticide chemicals. Following is the hazard information as required on the pesticide label: ” Pesticide Education Program

Section 16 Other Information • Includes: – Department issuing SDS. – Email address. – Training necessary. – Reissue date/reason for reissue. – General intended use of the product. Pesticide Education Program

Pictograms Pesticide Education Program

Pictograms • Health Hazard – – – Carcinogen Respiratory sensitizer Reproductive toxicity Target Organ toxicity Mutagenicity Aspiration toxicity. Pesticide Education Program

Pictogram • Flame – – – Flammables Self-Reactives Pyrophorics Self-Heating Emits flammable gas Organic peroxides Pesticide Education Program

Pictograms • Exclamation Mark – – – Skin and eye irritant Skin sensitizer Acute toxicity Narcotic effects Respiratory tract irritant Pesticide Education Program

Pictograms • Gas Cylinder – Gas Under Pressure • Flames Over Circle – Oxidizer Pesticide Education Program

Pictograms • Corrosion – Corrosives – Damaging – Destroys materials • Skull and Crossbones – Acute Toxicity (Severe) Pesticide Education Program

Pictograms • Exploding Bomb – Explosives – Self-Reactive – Organic peroxides Pesticide Education Program

Pictograms • Environment – Aquatic Toxicity Pesticide Education Program

Hazard Classification • The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures • These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result Pesticide Education Program

Will the change require that both and MSDS and an SDS be kept for the same product? • For compliance with the new OSHA Haz. Com 2012 regulatory requirements, maintaining both an MSDS and a SDS for the same chemical is not necessary. • As the SDS becomes available for individual products, they will replace the existing MSDS. • Although there is no requirement to keep the older MSDS once it is replaced with an SDS, a good management practice would be to keep an electronic copy on file, especially if existing stocks of the chemical were purchased under the older MSDS. Pesticide Education Program

Will the change require that both and MSDS and an SDS be kept for the same product? • When the chemical in question is a pesticide and the content of the MSDS and the SDS differs, a copy of both documents must be maintained to ensure compliance with OSHA Haz. Com 2012 and FIFRA which regulates pesticide products. Pesticide Education Program

The differences between EPA’s current requirements and the GHS are related to classification criteria, hazard statements, pictograms, and signal words. Pesticide Education Program

For example, FIFRA pesticide product labels may contain the following signal words: of “Danger-Poison with the skull and crossbones graphic, ” “Warning, ” or “Caution” depending on the toxicity level of the product, and “Danger” for a product that may be a potential skin or eye irritant. Pesticide Education Program

The GHS uses only two signal words, “Danger” and “Warning. ” Pesticide Education Program

How this may cause a problem for example is the label of a chemical that has an oral LD 50 of 550 mg/kg bears the signal word “Caution” under current FIFRA labeling practices but would require the signal word “Warning” under the GHS Safety Data Sheet format. Pesticide Education Program

For pesticide products, FIFRA labels approved by EPA pre-empt OSHA’s label requirements, but not the requirements for SDS and worker training (except for certified applicators and agricultural workers for whom EPA has training requirements). Pesticide Education Program

EPA realizes that this may require users of the SDS that are prepared for pesticide products to become familiar with two different systems, at least until the agencies’ requirements are harmonized. Pesticide Education Program

As a result, EPA issued guidance in the April 20, 2012 Federal Register to manufactures so that when changes are made to the SDS to meet the OSHA requirements, the new SDS format will also be in compliance with the pesticide regulations under FIFRA. Pesticide Education Program

Will the change require that both and MSDS and an SDS be kept for the same product? • When the chemical in question is a pesticide and the content of the MSDS and the SDS differs, a copy of both documents must be maintained to ensure compliance with OSHA Haz. Com 2012 and FIFRA which regulates pesticide products. Pesticide Education Program

Haz. Com 2012 Compliance Dates and Deadlines: There is a 3 year phase in period through 2016 Pesticide Education Program

Haz. Com 2012 Compliance Dates and Deadlines: • December 1, 2013 – – Employers must train employees on how to read GHS formatted labels and SDS’s. – Changes to labels are probably more substantial, however, employees need to understand where to find information on the SDS. Pesticide Education Program

Haz. Com 2012 Compliance Dates and Deadlines: • 2013 – 2015 On an Ongoing Basis – – Employers should replace existing MSDSs with new SDSs as they become available. – For pesticide products, employers must be sure to determine if there any differences between the MSDS and SDS. If differences exist, a copy of the MSDS must also be maintained to be in compliance with both Haz. Com 2012 and FIFRA. Pesticide Education Program

Haz. Com 2012 Compliance Dates and Deadlines: • June 1, 2015 – Chemical manufacturers and distributors should have completed their reclassification of chemicals and be shipping GHS formatted SDS and labels with their shipments. Pesticide Education Program

Haz. Com 2012 Compliance Dates and Deadlines: • December 1, 2015 – Distributors have an additional 6 months beyond the June 1, 2015 date to pass along manufacturer labels and SDSs in the older formats. However, beyond December 1, 2015, all MSDSs and labels in the U. S. should be in compliance with Haz. Com 2012 provisions. Pesticide Education Program

Haz. Com 2012 Compliance Dates and Deadlines: • June 1, 2016 – – Employers should be fully compliant with Haz. Com 2012. That includes making any necessary updates to their Haz. Com program, training employees on any newly identified chemical hazards (identification of new hazards is likely during the reclassification process chemical manufacturers undertake), and updating SDS libraries and secondary labels. Pesticide Education Program

This presentation was created in partnership with the Pesticide Education Program, Penn State Cooperative Extension; and the Pennsylvania Department of Agriculture. For more information on this and other resources, please visit extension. psu. edu/pested Where trade names appear, no discrimination is intended, and no endorsement by Penn State Cooperative Extension is implied. Penn State is committed to affirmative action, equal opportunity, and the diversity of its workforce. © The Pennsylvania State University 2012 November 2012 Pesticide Education Program