New Chemical Hazard Communication Standard Globally Harmonized System

New Chemical Hazard Communication Standard Globally Harmonized System of Classification and Labeling of Chemicals, WAC 296 -901 -140

Overview of GHS and changes to the standard

What is the GHS? § Harmonized criteria for classifying substances and mixtures according to their health, environmental and physical hazards. § Harmonized hazard communication system including requirements for labeling and safety data sheets (SDS). § Target audience - workers, employers, consumers, transport workers, emergency responders.

http: //bit. ly/LRVdsf

Agencies Involved with the GHS Federal Washington State DOT WSDOT OSHA L&I / DOSH EPA DOE & WSDA CPSC

Dark green: Countries/regions that have already implemented GHS. Light green: Countries/regions where GHS is voluntary. Yellow: Countries/regions that are in the process of implementing GHS. Blue: Countries/regions where GHS is not implemented or not available.

OSHA’s “Haz. Com 2012” Standard § Published March 26, 2012 § Conforms to the GHS, Rev. 3 § Changes to: – Hazard classification – Label content – Safety Data Sheet content (mandatory 16 section SDS, % required)

Stay tuned. . . § The GHS is updated on a two year cycle. § Recent updates have mostly been text clarifications. § Future updates of the Chemical Haz Com standard may be necessary.

WISHA’s new GHS-based Hazard Communication Standard Effective April 15, 2013

Substantially identical to OSHA’s standard Phase-in schedule: – During the transition period, there is the option to comply with the applicable requirements in the existing rules, or the requirements in the new rule, or both. – June 1, 2014: ERs train EEs on Safety Data Sheet (SDS) format and new label elements. – June 1, 2015: Manufacturers & importers comply with new SDS and label requirements. – Dec. 1, 2015: Distributors not to ship unless container has GHS label.

Substantially identical to OSHA’s standard Phase-in schedule, cont. : – June 1, 2016: ERs update labels, EE hazard training, and written Haz Com programs. – Upon completion of the transition period, the existing standard (296 -800 -170) will be repealed.

Exemptions § All the current exemptions from the rule, and exemptions from labeling, still apply. § One new exemption from the rule: – “Nuisance particulates where the chemical manufacturer or importer can establish that they do not pose any physical or health hazard covered under this section. ”

Major Changes § Labels & SDS – No longer performance-based. – Each hazard class and category has specified hazard statement(s), signal word, pictogram(s), and precautionary statement(s) in mandatory Appendix C. Those elements must appear on the label and SDS.

Major Changes § Hazard determination – Now titled “hazard classification” – Detailed data-based criteria • Health hazard criteria in mandatory Appendix A and non-mandatory Appendix F • Physical hazard criteria in mandatory Appendix B – Specified; no longer performance-based

Classification of chemical hazards § Hazard class: the nature of the physical or health hazards, e. g. , flammable solid, carcinogen, oral acute toxicity. § Hazard category: division by degree or type of hazard within each hazard class.

Hazard Class Hazard Category (health hazard criteria, Appendix A) Acute toxicity 1 2 3 4 Skin corrosion/irritation 1 A 1 B 1 C 2 Serious eye damage/irritation 1 2 A 2 B Respiratory or skin sensitizers 1 A 1 B Germ cell mutagenicity 1 A 1 B 2 Carcinogenicity 1 A 1 B 2 Reproductive toxicity 1 A 1 B 2 lactation Specific target organ toxicity - single exposure Specific target organ toxicity - repeated exposure Aspiration 1 2 3 1 2 1

Hazard Class Hazard Category (physical hazard criteria, Appendix B) Explosive Flammable gases Flammable aerosols Oxidizing gases Gases under pressure Unstable 1 1 1 Compressed Div 1. 1 2 2 Liquefied Flammable liquids Flammable solids Self-reactive Pyrophoric liquids Pyrophoric solids Self-heating Emits flammable gas when in contact with water Oxidizing liquids Oxidizing solids Organic peroxides Corrosive to metals 1 1 A 1 1 2 2 B 2 2 3 1 1 A 1 2 2 B 3 3 C Div 1. 2 Refrigerated liquefied 3 C Div 1. 3 Dissolved 4 D E F G D

Label Requirements

1. Find the hazard class From Appendix B:

2. Find the hazard category From Appendix B:

3. Find the required label elements From Appendix C:

Label pictograms

Exploding Bomb Symbol § Unstable Explosives § Explosives (Divisions 1. 1 -1. 4) § Self-reactives (Type A and Type B with Flame) § Organic Peroxides (Type A and Type B with Flame)

Flame Symbol § § § § § Flammable Gases Flammable Aerosols Flammable Liquids (Categories 1 -3) Flammable Solids Self-Reactives (Type B with bomb, Types C-F) Pyrophoric liquids and solids Self-heating substances Substances which in contact with water emit flammable gases Organic Peroxides (Type B with bomb, Types C-F)

Flame over Circle Symbol § Oxidizing Gases § Oxidizing Liquids § Oxidizing Solids

Gas Cylinder Symbol § Compressed Gas § Liquefied Gas § Refrigerated Liquefied Gas § Dissolved Gas

Corrosion Symbol § Corrosive to Metals (steel or aluminum >6. 25 mm/year at 55 C) § Skin corrosion/ irritation – Category 1 (A, B and C) § Serious eye damage/ irritation – Category 1

Skull and Crossbones Symbol § Acute Toxicity – Categories 1 -3 (oral, inhalation or dermal routes)

Exclamation Mark Symbol § Acute Toxicity – Category 4 (oral, inhalation or dermal routes) § Skin Irritation/ Corrosion – Category 2 § Serious Eye damage/ irritation – Category 2 A § Skin Sensitizer § Specific target organ toxicity (single exposure) – Category 3 (respiratory tract irritation, narcotic effects) § Hazardous to the Ozone Layer

Health Hazard Symbol § Respiratory Sensitizer § Germ Cell Mutagenicity § Carcinogenicity § Toxic to Reproduction § Specific target organ toxicity (single exposure) – Categories 1 -2 § Specific target organ toxicity (repeated exposure) – Categories 1 -2 § Aspiration Hazard

Environment Symbol* § Acute hazards to the aquatic environment – Category 1 (Categories 2 and 3 use no symbol or signal word) § Chronic hazards to the aquatic environment – Categories 1 and 2 (Categories 3 and 4 use no symbol or signal word) *Part of GHS, but not required by WISHA or OSHA standards.

Hazard statements § Hazard statement is specified for each level of hazard (category) within each hazard class (See Appendix C) – Example: Flammable liquids § § Category 1: Extremely flammable liquid and vapour Category 2: Highly flammable liquid and vapour Category 3: Flammable liquid and vapour Category 4: Combustible liquid 32

Hazard statements § The text of all applicable hazard statements shall appear on the label. § Hazard statements may be combined where appropriate to reduce the information on the label and improve readability, as long as all of the hazards are conveyed as required. 33

Multiple hazards § The pictogram and signal word used must reflect the most severe hazard category; and all relevant hazard statements must be used. – If skull and crossbones, no exclamation point for acute toxicity – If corrosive, no exclamation point for eye/skin irritation – If health hazard for respiratory sensitization, no exclamation point for skin sensitization or eye/skin irritation

Precautionary statements "Precautionary statement" means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. 35

Precautionary statements § There are 4 types of precautionary statements – – Prevention Response Storage Disposal 36

Precautionary statements § May be combined or consolidated to save label space and improve readability. § Where a chemical has multiple hazards and the precautionary statements are similar, the most stringent shall be included on the label. § An order of precedence may be imposed. § If the chemical manufacturer, importer, or responsible party can demonstrate that a precautionary statement is inappropriate to a specific substance, it may be 37 omitted from the label.

Supplementary hazard information § Only allowed if it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information. § Placement shall not impede identification of information required by the Standard. 38

Label arrangement § Label elements must be located together on the label, tag or mark. § Must not conflict with DOT regulations. § Pictograms must have red border. § Red frame must be wide enough to be clearly visible. § Blank red diamonds are not permitted. § Where a DOT label appears on a shipped container, the same OSHA pictogram shall not appear. § Labels must be in English (other languages also permitted).

1. Product identifier 2. Signal word 3. Pictogram(s) 4. Hazard statement(s) 5. Precautionary statement(s) 6. Contact info for responsible party

Potential for confusion § In NFPA 704 and HMIS, “ 4” = severe hazard § In GHS, “ 4” = low hazard HMIS/NFPA GHS Index 1 2 3 4 Category Hazard 1 highest 2 high 3 medium 4 low Hazard slight moderate serious severe

§ From the preamble to OSHA’s new standard: “Neither the proposal nor final rule prohibits the use of NFPA or HMIS rating systems. ” – Federal Register, 77(58), Monday, March 26, 2012, p. 17758

Potential for confusion § May confuse employers who need to look up hazard categories. § Most employees won’t notice unless it’s covered in their training, because hazard categories don’t appear on labels or SDSs (only used to determine required label info)

Potential for confusion

M ATERIAL S AFETY D S ATA HEETS

Safety Data Sheets § 16 -section format now required, similar to the current ANSI format. § Order of the sections is specified. § Specific required information for each section is in mandatory Appendix D. § Environmental provisions are included to be GHScompliant; DOSH will not enforce (sections 12 -15).

Safety Data Sheets § Must be in English (additional languages OK) § If there’s no relevant information for a section, it must be marked to indicate no data § Preparer must assure information accurately reflects the scientific evidence used in making the hazard classification § Preparer must update within 3 months of significant new information. If not currently produced, then before shipped again or introduced into the workplace.

SDS distribution § Provide with initial shipment, and with first shipment after update. § Either before or with the shipment, on request. § Retail and wholesale distributors shall post a sign or inform employers that SDSs are available.

New SDS elements § Standardized pictograms, hazard statements, signal words, and precautionary statements § Exact percentages of ingredients are required in most cases; some may still give ranges: – When there is a trade secret claim. – When a product varies batch-to-batch. – For a group of substantially similar mixtures with similar chemical composition.

SDS required sections 1. Identification 2. Hazard(s) identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling & storage 8. Exposure control/personal protection 9. Physical & chemical properties 10. Stability & reactivity 11. Toxicological information 12. Ecological information 13. Disposal considerations 14. Transport information 15. Regulatory information 16. Other information

Section 1 - Identification § Product identifier used on the label or other means of identification; § Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party; § Emergency phone number

Section 2 - Hazard(s) identification § Classification of the chemical § Signal word, hazard statement(s), symbol(s) and precautionary statement(s). § Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol, e. g. , flame, skull and crossbones, etc.

Section 3 - Composition / Ingredients For substances: § Chemical name § Common name and synonyms § CAS number and other unique identifiers § Impurities and stabilizing additives which are classified and contribute to the classification of the substance.

Section 3 - Composition / Ingredients For mixtures: Info required for substances, plus: § Chemical name and concentration (exact or range) of all ingredients which are classified as health hazards and – are present above their hazard class cutoff/concentration limits; or – present a health risk below the hazard class cutoff/concentration limits.

Section 4 - First-aid measures § Description of necessary measures, subdivided according to the different routes of exposure, i. e. , inhalation, skin and eye contact, and ingestion. § Most important symptoms/effects, acute and delayed. § Indication of immediate medical attention and special treatment needed, if necessary. 55

Section 5 - Fire-fighting measures § Suitable (and unsuitable) extinguishing media. § Specific hazards arising from the chemical (e. g. , nature of any hazardous combustion products). § Special protective equipment and precautions for fire-fighters. 56

Section 6 - Accidental release measures § Personal precautions, protective equipment, and emergency procedures. § Methods and materials for containment and cleaning up.

Section 7 - Handling and storage § Precautions for safe handling. § Conditions for safe storage, including any incompatibilities.

Section 8 - Exposure Controls/Personal Protection § Permissible exposure limit (PEL), Threshold Limit Value (TLV), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available. § Appropriate engineering controls. § Individual protection measures, such as personal protective equipment.

Section 9 - Physical and Chemical Properties § Appearance (physical state, color, etc. ) § Odor threshold § p. H § Melting point/freezing point § Initial boiling point and boiling range § Flash point § Evaporation rate § Flammability (solid, gas) § Upper/lower flammability or explosive limits § Vapor pressure § Vapor density § Relative density § Solubility(ies) § Partition coefficient: n-octanol/water § Auto-ignition temperature § Decomposition temp. § Viscosity

Section 10 Stability and Reactivity § Chemical stability § Possibility of hazardous reactions § Conditions to avoid (e. g. , static discharge, shock, or vibration) § Incompatible materials § Hazardous decomposition products

Section 11 - Toxicological Information Description of health effects and the available data used to identify those effects, including: § Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact) § Symptoms related to the physical, chemical and toxicological characteristics § Delayed and immediate effects and also chronic effects from short- and long-term exposure

Section 12 - Ecological Information Non-mandatory § Ecotoxicity (aquatic and terrestrial, where available) § Persistence and degradability § Bioaccumulative potential § Mobility in soil § Other adverse effects (such as hazardous to the ozone layer).

Section 13 - Disposal Considerations Non-Mandatory § Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging.

Section 14 Transport Information Non-Mandatory § § § UN number UN proper shipping name Transport hazard class(es) Packing group, if applicable Environmental hazards (e. g. , Marine pollutant) Special precautions which a user needs to be aware of in connection with transport or conveyance either within or outside their premises.

Section 15 Regulatory Information Non-Mandatory § Safety, health and environmental regulations specific for the product in question.

Section 16 - Other Information § The date of preparation of the SDS or the last change § References

Compliance assistance

Effective dates for employers § During the transition period, option to comply with the requirements in the existing rules, or the requirements in the new rule, or both. § June 1, 2014: Train EEs on Safety Data Sheet (SDS) format and new label elements. § June 1, 2016: Update labels, train EEs on new hazards, and update written Chemical Haz Com programs.

Help available from DOSH

Help available from DOSH

Help available from DOSH

Help available from DOSH

Additional help from DOSH § Consultation Services – Customized training assistance for employers on request. – Workshops being developed. § Education & Outreach – Online training modules being developed by Ernesto Carcamo.

GHS-related changes to other standards

GHS requires changes in 25 other standards 1. Wording of hazard signs and labels. 2. Definitions of flammable and combustible materials in multiple standards. Affects virtually all standards addressing chemical hazards (including PSM, laboratories, spray finishing, dipping, coating, welding, hazardous waste, emergency response, etc. )

GHS requires changes in 25 other standards § § § Welding, Cutting, & Brazing Flammable & Combustible Liquids Spray finishing Shipbuilding, -Repairing & Breaking Hexavalent Chromium Cotton Dust Coke Ovens Asbestos, Tremolite, Anthophyllite, & Actinolite Carcinogens Vinyl Chloride Acrylonitrile 1, 2 -Dibromo-3 -chloropropane § § § § Cadmium Butadiene Methylene chloride Lead Methylenedianiline (MDA) Hazardous Chemicals In Laboratories Process Safety Management Dipping & Coating Operations Hazardous Waste Operations Arsenic Benzene Ethylene Oxide Formaldehyde

Other resources

www. osha. gov/dsg/hazcom

www. schc. org

DOSH Specialist on GHS: Pam Edwards, Industrial Hygienist, MES DOSH Technical Services, Tumwater Pamela. Edwards@lni. wa. gov (360) 902 -6457