OSHA Hazard Communication 29 CFR 1910 1200 Subpart

OSHA Hazard Communication 29 CFR 1910. 1200 Subpart Z Updated 5 May 2014

Subpart Z Toxic & Hazardous Substances (1910. 1000 – 1450) Written program 1200(e)(1) 1200(h)(1) 2218 Information and training 1548 SDS’s for each chemical 1200(g)(1) 580 SDS’s readily accessible 1200(g)(8) 507 Labeling (old standard) 1200(f)(5)(i) 405 OSHA Most Cited 2012

Phase in Period for GHS into Hazard Communication Standard Effective Completion Date Requirements 1 December 2013 Train employees on the new label elements and SDS format 1 June 2015 Comply with all modified provisions of this final rule, except 1 December 2015 Distribution may ship products labeled by manufactures under the old system until 1 December 2015 1 June 2016 Update alternative workplace labeling and hazard communication program as necessary and provide additional employee training for newly identified physical or health hazards Transition Period Comply with either 29 CFR 1910. 1200 (final standard) or the current standard or both Who Employers Chemical manufactures, importers, distributors and employers Employers All chemical manufacturers, importers, distributors and employers

What is the Purpose of 1910. 1200 (a) Hazards Communication: (1) Purpose: Is to ensure that the hazards of all chemicals produced or imported are classified and that information concerning the classification hazards is transmitted to the employers and employees

What is the Purpose of 1910. 1200 Hazards Communication: • The requirements of this section are intended to be consistent with the provisions of the United Nations Globally Harmonized System (GHS) of Classification and Labelling of Chemicals

29 CFR 1910. 1200 (d) (1) • Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section. • For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified.

29 CFR 1910. 1200 (d) (1) • Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.

Classification: • All hazards to be CLASSIFIED not Evaluated: • "Classification" a. Identify the relevant data regarding the hazards of a chemical; b. Review those data to ascertain the hazards associated with the chemical c. Determine whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section. In addition, d. Classification for health and physical hazards includes the determination of the degree of hazard, • "Hazard class" means the nature of the physical or health hazards, e. g. , flammable solid, carcinogen, oral acute toxicity.

Old 1910. 1200 Haz Comm Standard: • Required an employer to: 1. Have a written hazard communication program 2. Have each hazardous chemical in the workplace labeled 3. Have a Material Safety Data Sheet (MSDS) for each hazardous chemical in the workplace 4. Train his/her employees about the hazards associated with and precautionary measures required for each hazardous chemical in the workplace. Training is required initially and anytime a new hazardous chemical is introduces into the workplace.

How has Haz Comm Changed? • Hazards Classification rather than “hazard determination • Labels are more defined and will now require: • Product identifier • Pictogram • Signal word • Hazard statement(s) • Precautionary statement(s) • Name, address, and phone number • Safety Data Sheet (not Material Safety Data Sheet): • Uses a 16 section format

New Haz Comm Standard has 4 Basic Sections: • 29 CFR 1910. 1200 Subpart Z: 1. Written Program 2. Labeling and other Warnings 3. Safety Data Sheets (SDS) 4. Employee Info and Training

1. Written Hazard Comm Program

Written Program 29 CFR 1910. 1200 (e) (1) • Employers shall develop, implement and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g) and (h) of this section: • Labels and other forms of warning • Safety Data Sheets (SDS) • Employee information and training

Written Program 29 CFR 1910. 1200 (e) (1) Hazardous Chemical List: (i) A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet

Written Program 29 CFR 1910. 1200 (e) (1) Methods: (ii) The methods the employer will use to inform employees of the hazards of non-routine tasks (example , the cleaning of reactor vessels) and the hazards associated with the chemical contained in unlabeled pipes in their work areas.

Written Program 29 CFR 1910. 1200 (e) (2) Multi-employer workplaces: Employers who produce, use or store hazardous chemicals at a workplace in such a way that the employees of other employer may be exposed shall additionally ensure that the hazards communication program developed and implemented under this paragraph:

Written Program 29 CFR 1910. 1200 (e) (1) (2) Multi-employer workplaces: (i) The methods the employer will use to provide SDS (ii) The methods the employer will use to inform the other employers of any precautionary measures that need to be taken to protect employees during workplace’s normal operating conditions and in foreseeable emergencies (iii) The methods the employer will use to inform the other employers of the labeling system used in the workplace

Written Program 29 CFR 1910. 1200 (e) (4) • The employer shall make the written hazard communication program available upon request to employees

What are GHS Categories Hazards? • • The categories of hazards are: Physical Health Environmental (non- mandatory)

GHS Physical Hazards: • • Explosive • Pyrophoric Solids Flammable Gases • Self Heating Substance Flammable aerosols • Substances which in contact Oxidizing Gases w/ water emit flammable gases Gases under Pressure • Oxidizing Liquids Flammable Liquids • Oxidizing Solids Self Reactive Substances • Organic Peroxides Pyrophoric Liquids • Corrosive to Metals

GHS Health Hazards: • • • Acute Toxicity Skin Corrosion/Irritation Serious Eye Damage /Eye Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicology Target Organ Systemic Toxicity Single Exposure Aspiration Toxicity Target Organ Systemic Toxicity – Repeated Exposure

2. Labels and other Warnings

GHS Labeling Format: • There is no label format or layout specified • There are required label elements

GHS Labeling Elements: • • • Product Identifier Supplier Identifier Hazard pictogram Signal Word Hazard statement Precautionary information

Labeling Signal Words: “Danger” or “Warning” • Used to emphasis hazards and indicate relative level of severity of the hazard assigned to a GHS hazard class and category • Only one signal word on a label

• Include appropriate statements for each GHS hazard on labels for products that possess more than one hazard • Examples of required hazards statements: - Keep away from fire, sparks and heated surfaces - Do not use in areas without adequate ventilation

Pictograms: Pictograms have been standardized to convey health, physical and environmental hazard information, assigned to a GHS hazard class and category HEALTH HAZARD GAS CYLINDER FLAME OVER CIRCLE FLAME CORROSION ENVIRONMEN T EXCLAMATION MARK EXPLODING BOMB SKULL & CROSSBONE S

Pictogram: Health Hazard • • • Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity 28

Pictogram: Flame • • • Flammables Pyrophoric Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides 29

Pictogram: Exclamation Mark • • • Irritant (skin and eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non-Mandatory) 30

Pictogram: Gas Cylinder • Gases Under Pressure 31

Pictogram: Corrosion • Skin Corrosion/Burns • Eye Damage • Corrosive to Metals 32

Pictogram: Exploding Bomb • Explosives • Self-Reactives • Organic Peroxides 33

Pictogram: Flame over Circle • Oxidizers 34

Pictogram: Environmental • Aquatic Toxicity • (Non-Mandatory) 35

Pictogram: Skull and Crossbones • Acute Toxicity (fatal or toxic) 36

GHS Labeling Example:

Labeling 1910. 1200 (f) (8) • The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers and which are intended for immediate use of the employee who performs the transfer. • Define immediate use?

3. Safety Data Sheets (SDS)

• Prepared by the chemical manufacturer or importer and describes: § § § § Physical hazards, such as fire and explosion Health hazards, such as signs of exposure Routes of exposure Precautions for safe handling and use Emergency and first-aid procedures Control measures Must be readily accessible to employees in their work area

Old Material Safety Data Sheet (MSDS)

16 Sections – Standardized format: 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 and storage 8. Exposure control/personal protection

Format: 16 Sections (cont. ): 9. Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12. Ecological information 13. Disposal information 14. Transport information 15. Regulatory information 16. Other information

4. Employee Info and Training

Haz Comm Training 1910. 1200 (h) (1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area: a. at the time of initial assignment b. whenever a new chemical hazard the employees have not been previously been trained is introduced into the work area.

Haz Comm Information 1910. 1200 (g) (2) Employees shall be informed of: a. Any operations in their work area where hazardous chemicals are present b. The location and availability of the written communication program c. List of all hazardous chemicals

Haz Comm Training 1910. 1200 (3) (i) Methods and observations that may be used to detect the presence or release of a hazardous chemical (ii) The physical health aspects (iii) The measures employees can take to protect themselves from these hazardous – PPE (iv) The details of the hazard communication program developed by the employer – labeling and SDS

Summary Hazard Communication 1910. 1200