GHS-and-the-2012-Hazcom-Rule

GHS and The 2012 Hazcom Standard: What You Need To Think About Now : 

GHS and The 2012 Hazcom Standard: What You Need To Think About Now June 27, 2012 Labelmaster Paul Burgess, Regulatory Specialist

Objectives for this Presentation : 

Objectives for this Presentation History of Hazard Communications Introduction to the GHS The Hazcom/GHS Link up Timeline and Impact – What You Need to Think About NOW

A Little History: 

A Little History Early 70s – OSHA (Occupational Safety and Health Administration) Established in USA 1983 – Hazard Communication Rule (29 CFR 1910.1200) Initial Promulgation 1992 – Rio De Janeiro UN Conference Sets Goal of a “ Globally Harmonized System ” of Hazard Communication in Transportation and Workplace by the Year 2000

What is GHS? : 

What is GHS? GHS (Globally Harmonized System) Joint Global Framework of Guidelines Classifying and Communicating Chemical Hazards UN Created GHS, Updates as Conditions and Knowledge Change Current Iteration: 4 th Revision. OSHA Hazcom Based on 3 rd Revision

PowerPoint Presentation: 

“GHS” Itself is NOT : A Law A Regulation A Legal Standard An Industry Best Practice GHS is an Agreed Framework which Countries, Groups and other Interested or Affected Bodies can use to Create Harmonized Versions of the Above What is GHS (What it Isn’t)?

Let’s Talk Hazcom : 

Let’s Talk Hazcom “Hazcom” Accepted Term for the HCS , or “ Hazard Communication Standard ” Legal Text Found Under US 29 CFR 1910.1200 Provides for the Required Communication of Workplace Chemical Hazards to Employees Working in the United States Extant Since 1983

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Affects More Than 40 Million Employees Impacts 5 Million Workplaces Provides Hazard Communication Guidelines Related to Nearly 900,000 Chemicals “One Employee, One Chemical” Baseline Governed by OSHA (US Executive Branch) Let’s Talk Hazcom

Who is Affected: 

Who is Affected Chemical Manufacturers & Distributors Chemical Producers Must Classify Products and Provide Appropriate Hazard Warning Labeling and Safety Data Sheets (SDS) for Each Substance Must be Provided to Downstream Shippers and/or Users Distributors/Importers Must Distribute the Same Information to Customers

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Employers Provide Written Hazard Communication Plan Provide Accurate, Up-to-Date Inventory of the Chemicals on Their Premises & In Use by Their Employees Who is Affected

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Employers Appropriate Labeling Systems to Provide Communication and Hazard Warning Provide Accurate Library/Database with SDS for Their Chemical Inventory Provide Access Under “Right to Know” Law Train Employees to Use and Understand the System Who is Affected

The Impact of GHS: 

The Impact of GHS Divergence Leads to Confusion Globally, Countries Used Divergent Hazard Communication Methods Divergent Systems have Negative Impact on Global Trade

PowerPoint Presentation: 

Designed to Address Previous International Issues by Harmonizing Global Hazard Communications Improved Cross-border/International Communication Breaks Through Some Trade Barriers The Impact of GHS

Benefits of GHS: 

Benefits of GHS Full Implementation will Make Hazcom Understandable from “Tokyo to Timbuktu” Ease Burden of Hazard Communication for Global Trade/Remove “Technical Barrier” Some Countries Use Allow Workers to Change Jobs & Maintain Familiarity with the System

2009 – OSHA Tests the Water : 

2009 – OSHA Tests the Water Proposed Rule Released in 2009 Extensive Revisions Determine Best Policy Introduction of GHS to US Hazcom Avoid Undue Economic Impact to Present and Future Business Operations (i.e. the Regulatory Burden Issue)

March, 2012 – OSHA Acts : 

March, 2012 – OSHA Acts The New Hazcomm Standard Promulgated as a Final Rule Effective Date: May 25 th , 2012 The Standard is Now in Place in the US

What Does it Do? : 

What Does it Do? Keeps Most Basic Elements of old Hazcom Standard in Place Changes the “How” Increases Worker Protection by Enhanced Requirements for Hazard Communication & Classification Uses the GHS Rev. 3 as Baseline

The Gorilla in the Room: 

The Gorilla in the Room Biggest Change to HCS is Chemical Classification, Now Under Stringent Guidelines in the GHS Document Eliminates “Wiggle Room”

The Gorilla’s Buddy: SDS : 

The Gorilla’s Buddy: SDS New Standard Converts Current Material Safety Data Sheets (MSDS) to Safety Data Sheets (SDS) Sections Harmonized with International Requirements Significantly More Information about Product, Use & Handling

SDS: The Good News: 

SDS: The Good News SDS Largely Based on MSDS Format SDS More Comprehensive, Largely “Apples to Apples” Many Companies Already Started Conversion Affects Chemical Manufacturers Mostly

The Last Gorilla: Labeling : 

The Last Gorilla: Labeling GHS Labeling Largely Reflects Usage by USDOT/ICAO/IMO Transport World Internationally Recognized Pictograms Designed to Limit Need for Language Conversion from Country to Country

Implementation Dates : 

Implementation Dates Dec. 1, 2013 Employers must train employees on the new label elements and safety data sheet (SDS) format Chemical manufacturers, importers, distributors and employers must comply with all modified provisions June 1, 2015 Dec. 1, 2015 Distributors begin shipping containers labeled by the chemical manufacturer or importer with a HCS label June 1, 2016 Employers must update alternative workplace labeling and hazard communication programs as necessary and provide additional employee training for newly identified physical or health hazards

GHS Hazard Classifications: 

GHS Hazard Classifications Physical Hazards Explosives Flammable Gases, Aerosols, Liquids, Solids Oxidizers Self-Reactives Self-heaters Pyrophorics Organic Peroxides Corrosives Pressurized Gases Dangerous When Wet Health/Environmental Acute Toxicity Aspiration Skin Corrosion and Irritation Respiratory and/or Skin Sensitization Mutagenicity Carcinogenicity Reproductive Damage Organ Toxicity, Single and Multiple Doses Danger to Aquatic Environment

Severity of Danger : 

Severity of Danger Major Change, Evaluates DEGREE of Danger Strict Guidance for Setting Levels GHS Reverses “Lower is Better” Expectation in the US

Label Elements: 

Label Elements Strictly Constructed Pictographic and Textual Information for Use on Hazard Warning Labels Symbols Familiar to Users of Transport-based Labeling Systems Deliberate Goal of the GHS Alignment

Label Elements: 

Label Elements

What You Need To Think About Now: 

What You Need To Think About Now Train Your Employees December 1, 2013 Establishes that ALL Employees be Trained Most Employers Conduct “ Right to Know ” Training Yearly Now is Optimal Time to “Convert” This is a Large Change— Don’t Wait Until the Last Minute

How Can Labelmaster Help?: 

How Can Labelmaster Help? Full Line of GHS Compliant: Training Program & Materials SDS Binders Software & Printer

How Can Labelmaster Help?: 

How Can Labelmaster Help? Pictograms & Mini Pictograms Custom Labels Drum Labels Additional Assistance Regulatory Staff to Assist Planning Continual Monitoring & Updating of the Rules

Resources : 

Resources Labelmaster.com GHS Liaison: Paul Burgess, PBURGESS@labelmaster.com Extensive information and assistance available on Department of Labor/OSHA websites Information on the UN GHS Program Itself Can Be Found on the UN Website Many Local Governments also Offer Assistance

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If We Do Not Get To Your Question Today, Please Email PBURGESS@labelmaster.com Q & A