What Are The Major Changes To The Hazard Communication Standard?

Modification of the Hazard Communication Standard (HCS) to conform with the United Nations' (UN) Globally Harmonized System of Nomenclature and Labeling of Chemicals (GHS)

Questions and Answers

Q. What is the Globally Harmonized Organization?

A. The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemic hazards, and a standardized approach to characterization elements and prophylactic data sheets. The GHS was negotiated in a multi-yr process by hazard communication experts from many different countries, international organizations, and stakeholder groups. Information technology is based on major existing systems around the world, including OSHA'south Hazard Communication Standard and the chemical nomenclature and labeling systems of other U.s. agencies.

The result of this negotiation procedure is the Un' document entitled "Globally Harmonized System of Classification and Labeling of Chemicals," commonly referred to equally The Regal Volume. This document provides harmonized classification criteria for health, physical, and ecology hazards of chemicals. It also includes standardized label elements that are assigned to these hazard classes and categories, and provide the appropriate betoken words, pictograms, and adventure and precautionary statements to convey the hazards to users. A standardized gild of data for condom data sheets is too provided. These recommendations can exist used by regulatory government such as OSHA to establish mandatory requirements for run a risk communication, but practice non constitute a model regulation.

Q. Why did OSHA decide to alter the Run a risk Advice Standard to prefer the GHS?

A. OSHA has modified the Chance Communication Standard (HCS) to adopt the GHS to improve safety and health of workers through more effective communications on chemical hazards. Since information technology was commencement promulgated in 1983, the HCS has provided employers and employees extensive information virtually the chemicals in their workplaces. The original standard is performance-oriented, allowing chemic manufacturers and importers to convey information on labels and material condom data sheets in whatever format they choose. While the available information has been helpful in improving employee safety and wellness, a more standardized approach to classifying the hazards and carrying the information volition be more effective, and provide further improvements in American workplaces. The GHS provides such a standardized approach, including detailed criteria for determining what hazardous effects a chemical poses, as well every bit standardized characterization elements assigned by hazard form and category. This will heighten both employer and worker comprehension of the hazards, which will aid to ensure advisable handling and safe apply of workplace chemicals. In addition, the safety data sheet requirements constitute an order of data that is standardized. The harmonized format of the safety data sheets will enable employers, workers, health professionals, and emergency responders to admission the information more efficiently and effectively, thus increasing their utility.

Adoption of the GHS in the US and around the world will also help to ameliorate information received from other countries—since the US is both a major importer and exporter of chemicals, American workers often come across labels and condom information sheets from other countries. The various and sometimes alien national and international requirements can create confusion amid those who seek to use chance information effectively. For example, labels and safety data sheets may include symbols and hazard statements that are unfamiliar to readers or not well understood. Containers may be labeled with such a large volume of information that of import statements are not easily recognized. Given the differences in hazard classification criteria, labels may as well exist incorrect when used in other countries. If countries around the globe prefer the GHS, these issues will be minimized, and chemicals crossing borders will have consistent information, thus improving advice globally.

Q. What is the stage-in period in the revised Chance Communication Standard?

A. The tabular array below summarizes the stage-in dates required under the revised Run a risk Communication Standard (HCS):

Constructive Completion Date	Requirements	Who
Dec 1, 2013	Railroad train employees on the new characterization elements and rubber data canvass (SDS) format.	Employers
June i, 2015*, Dec 1, 2015	Compliance with all modified provisions of this final rule, except: The Distributor shall not transport containers labeled by the chemic manufacturer or importer unless it is a GHS characterization	Chemic manufacturers, importers, distributors and employers
June one, 2016	Update alternative workplace labeling and hazard communication program as necessary, and provide boosted employee grooming for newly identified physical or wellness hazards.	Employers
Transition Menstruation to the constructive completion dates noted in a higher place	May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both	Chemical manufacturers, importers, distributors, and employers

*This date coincides with the Eu implementation date for classification of mixtures

During the phase-in catamenia, employers would be required to be in compliance with either the existing HCS or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be nowadays in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.

Q. Why must training be conducted prior to the compliance effective date?

A. OSHA is requiring that employees are trained on the new label elements (i.due east., pictograms, adventure statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final dominion volition begin in 2015. OSHA believes that American workplaces will before long brainstorm to receive labels and SDSs that are consistent with the GHS, since many American and strange chemic manufacturers accept already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees brainstorm to run into the new labels and SDSs in their workplaces, they volition be familiar with them, sympathise how to use them, and access the information effectively. For more data,http://www.osha.gov/dsg/hazcom/effectivedates.html.

Q. What are the major changes to the Hazard Communication Standard?

A. The 3 major areas of change are in chance classification, labels, and safe data sheets.

• Hazard nomenclature: The definitions of gamble accept been changed to provide specific criteria for nomenclature of health and physical hazards, likewise equally classification of mixtures. These specific criteria will assistance to ensure that evaluations of hazardous furnishings are consistent beyond manufacturers, and that labels and condom data sheets are more authentic equally a result.
• Labels: Chemical manufacturers and importers will be required to provide a characterization that includes a harmonized signal give-and-take, pictogram, and risk statement for each hazard class and category. Precautionary statements must also exist provided.
• Safety Data Sheets: Will now have a specified sixteen-section format.

The GHS does non include harmonized training provisions, merely recognizes that preparation is essential to an effective hazard communication approach. The revised Hazard Communication Standard (HCS) requires that workers be re- trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safe data sheets.

For a side-by-side comparison of the current HCS and the concluding revised HCS please meet OSHA's hazard communication safety and health topics webpage at:http://www.osha.gov/dsg/hazcom/index.html

Q. What Hazard Advice Standard provisions are unchanged in the revised HCS?

A. The revised Run a risk Communication Standard (HCS) is a modification to the existing standard. The parts of the standard that did non relate to the GHS (such as the basic framework, scope, and exemptions) remained largely unchanged. There have been some modifications to terminology in order to align the revised HCS with language used in the GHS. For example, the term "hazard determination" has been changed to "take a chance nomenclature" and "material safety data sail" was changed to "safe data sheet." OSHA stakeholders commented on this arroyo and found it to be appropriate.

Q. How volition chemic take a chance evaluation alter nether the revised Take chances Communication Standard?

A. Nether both the current Hazard Communication Standard (HCS) and the revised HCS, an evaluation of chemic hazards must be performed considering the available scientific evidence concerning such hazards. Under the current HCS, the hazard decision provisions have definitions of take a chance and the evaluator determines whether or non the information on a chemical meet those definitions. It is a performance-oriented arroyo that provides parameters for the evaluation, but not specific, detailed criteria. The hazard nomenclature arroyo in the revised HCS is quite dissimilar. The revised HCS has specific criteria for each health and physical hazard, along with detailed instructions for chance evaluation and determinations as to whether mixtures or substances are covered. It also establishes both hazard classes and adventure categories—for near of the effects; the classes are divided into categories that reflect the relative severity of the effect. The current HCS does not include categories for most of the health hazards covered, and then this new approach provides additional data that can be related to the appropriate response to accost the adventure. OSHA has included the general provisions for hazard classification in paragraph (d) of the revised rule, and added all-encompassing appendixes (Appendixes A and B) that accost the criteria for each wellness or concrete event.

Q. How will labels alter under the revised Adventure Communication Standard?

A. Nether the current Hazard Communication Standard (HCS), the characterization preparer must provide the identity of the chemic, and the advisable run a risk warnings. This may be washed in a diverseness of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard nomenclature is completed, the standard specifies what information is to exist provided for each hazard class and category. Labels will crave the post-obit elements:

Health Hazard

• Carcinogen
• Mutagenicity
• Reproductive Toxicity
• Respiratory Sensitizer
• Target Organ Toxicity
• Aspiration Toxicity

Flame

• Flammables
• Pyrophorics
• Self-Heating
• Emits Combustible Gas
• Self-Reactives
• Organic Peroxides

Exclamation Mark

• Irritant (peel and eye)
• Pare Sensitizer
• Acute Toxicity (harmful)
• Narcotic Furnishings
• Respiratory Tract Irritant
• Hazardous to Ozone Layer (Not Mandatory)

Gas Cylinder

• Gases under Pressure

Corrosion

• Pare Corrosion/ burns
• Heart Damage
• Corrosive to Metals

Exploding Flop

• Explosives
• Self-Reactives
• Organic Peroxides

Flame over Circle

• Oxidizers

Environs (Non Mandatory)

• Aquatic Toxicity

Skull and Crossbones

• Acute Toxicity (fatal or toxic)

Pictogram: a symbol plus other graphic elements, such as a border, groundwork pattern, or color that is intended to convey specific data about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red foursquare frame assail a signal (i.eastward. a blood-red diamond). There are 9 pictograms nether the GHS. However, only 8 pictograms are required nether the HCS.

Signal words: a single give-and-take used to indicate the relative level of severity of chance and warning the reader to a potential run a risk on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "alarm" is used for less severe hazards.

Chance Statement: a statement assigned to a hazard course and category that describes the nature of the adventure(s) of a chemic, including, where appropriate, the degree of risk.

Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemic, or improper storage or handling of a hazardous chemical.

Q. Tin I use a black edge on pictograms for domestic shipment?

A. Nether the revised Hazard Communication Standard (HCS), pictograms must have red borders. OSHA believes that the utilize of the red frame will increase recognition and comprehensibility. Therefore, the red frame is required regardless of whether the shipment is domestic or international.

Q. Will OSHA allow bare cherry borders?

A. The revised Run a risk Communication Standard (HCS) requires that all ruby borders printed on the label accept a symbol printed inside it. If OSHA were to let blank red borders, workers may be confused near what they mean and concerned that some information is missing. OSHA has adamant that prohibiting the use of blank red borders on labels is necessary to provide the maximum recognition and bear on of alarm labels and to ensure that users do non get desensitized to the warnings placed on labels.

Q. When must label information be updated?

A. In the revised Take chances Advice Standard (HCS), OSHA is lifting the stay on enforcement regarding the provision to update labels when new information on hazards becomes available. Chemical manufacturers, importers, distributors, or employers who become newly enlightened of any significant information regarding the hazards of a chemical shall revise the labels for the chemical inside vi months of becoming aware of the new information, and shall ensure that labels on containers of chancy chemicals shipped after that time contain the new information. If the chemical is non currently produced or imported, the chemical manufacturer, importer, benefactor, or employer shall add the information to the label before the chemical is shipped or introduced into the workplace again.

Q. How will workplace labeling provisions be changing under the revised Hazard Communication Standard?

A. The current standard provides employers with flexibility regarding the type of system to be used in their workplaces and OSHA has retained that flexibility in the revised Take chances Communication Standard (HCS). Employers may cull to label workplace containers either with the same label that would be on shipped containers for the chemic under the revised rule, or with label alternatives that run across the requirements for the standard. Culling labeling systems such as the National Fire Protection Clan (NFPA) 704 Gamble Rating and the Hazardous Cloth Identification System (HMIS) are permitted for workplace containers. Even so, the data supplied on these labels must be consistent with the revised HCS, eastward.g., no conflicting hazard warnings or pictograms.

Q. How is the Safety Information Sheet (SDS) changing under the revised Hazard Communication Standard?

A. The information required on the safety data sheet (SDS) will remain essentially the aforementioned as that in the current standard (HazCom 1994). HazCom 1994 indicates what information has to exist included on an SDS, but does not specify a format for presentation or order of data. The revised Hazard Communication Standard (HazCom 2012) requires that the data on the SDS be presented using specific headings in a specified sequence.

Paragraph (k) of the final dominion provides the headings of information to exist included on the SDS and the order in which they are to be provided. In addition, Appendix D provides the information to exist included under each heading. The SDS format is the same as the ANSI standard format which is widely used in the U.S. and is already familiar to many employees.

Wellness Take a chance

• Carcinogen
• Mutagenicity
• Reproductive Toxicity
• Respiratory Sensitizer
• Target Organ Toxicity
• Aspiration Toxicity

The format of the 16-section SDS should include the following sections:

• Department 1. Identification
• Department ii. Hazard(s) identification
• Department iii. Composition/information on ingredients
• Section 4. First-Aid measures
• Section v. Burn down-fighting measures
• Department 6. Accidental release measures
• Section 7. Handling and storage
• Section viii. Exposure controls/personal protection
• Department 9. Physical and chemical properties
• Department 10. Stability and reactivity
• Section 11. Toxicological information
• Section 12. Ecological information
• Department 13. Disposal considerations
• Section 14. Send information
• Department 15. Regulatory data
• Department sixteen. Other information, including date of training or last revision

The SDS must also contain Sections 12-15, to be consistent with the United nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Although the headings for Sections 12-15 are mandatory, OSHA will non enforce the content of these four sections because these sections are inside other agencies' jurisdictions.

Q. Will TLVs be required on the Rubber Data Sheet (SDS)?

A. OSHA is retaining the requirement to include the American Conference of Regime Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) on the safety data sheet (SDS) in the revised Standard. OSHA finds that requiring TLVs on the SDS volition provide employers and employees with useful data to help them assess the hazards presented by their workplaces. In improver to TLVs, OSHA permissible exposure limits (PELs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sail are too required.

Q. May the International Agency for Research on Cancer (IARC) and the National Toxicology Programme (NTP) lists be used to make carcinogen classifications?

A. In the revised Take chances Advice Standard (HCS), OSHA has provided classifiers with the choice of relying on the nomenclature listings of IARC and NTP to make nomenclature decisions regarding carcinogenicity, rather than applying the criteria themselves. OSHA believes that this will brand classification easier for classifiers, as well every bit lead to greater consistency. In addition, OSHA has provided in not-mandatory Appendix F of the revised dominion, guidance on hazard nomenclature for carcinogenicity. Part A of Appendix F includes groundwork guidance provided by GHS based on the Preamble of the IARC "Monographs on the Evaluation of Carcinogenic Risks to Humans" (2006). Part B provides IARC classification information. Function C provides groundwork guidance from the National NTP "Report on Carcinogens" (RoC), and Part D is a table that compares GHS carcinogen adventure categories to carcinogen classifications under IARC and NTP, allowing classifiers to be able to use information from IARC and NTP RoC carcinogen classifications to complete their classifications nether the GHS, and thus the HCS.

Q. Volition the International Bureau for Research on Cancer (IARC) and the National Toxicology Programme (NTP) classifications exist required on the Safety Data Sail (SDS)?

A. OSHA has retained the requirement to include IARC and NTP classifications on condom information sheets (SDSs). Therefore, if a chemic is listed as a carcinogen past either IARC or NTP, it must exist noted on the SDS. Additionally, if OSHA finds a chemical to be a carcinogen, it must be noted on the SDS likewise.

Q. How has OSHA addressed hazards covered nether the current Hazard Advice Standard that accept non been addressed by the GHS?

A. In the Notice of Proposed Rulemaking (NPRM), OSHA proposed to include hazards currently covered under the Take a chance Communication Standard (HCS) that have however to be addressed by the GHS (OSHA provided several examples: unproblematic asphyxiants, and flammable grit) in a carve up category called "Unclassified Hazards". In response to comments from the regulated community, OSHA has renamed the category to "Hazards Not Otherwise Classified (HNOC)" to minimize confusion. In the final HCS, HNOC hazards will not be required to be disclosed on the label but volition be required to be disclosed in section 2 of the Rubber Data Canvas (SDS). This reflects how GHS recommends these hazards should exist disclosed. Chemical manufacturers and importers are expected to assess these hazards when they are conducting their hazard evaluation of concrete and health hazards. A new or separate evaluation is not required. As well in the final standard, in response to comments, OSHA has removed pyrophoric gases, unproblematic asphyxiants, and combustible dust from the HNOC hazard category and has addressed these chemicals individually (run into question below for more information on each hazard).

Q. How has OSHA addressed pyrophoric gases, simple asphyxiants, and combustible grit?

A. In the revised Run a risk Communication Standard (HCS), OSHA has added pyrophoric gases, uncomplicated asphyxiants and flammable dust to the definition of "hazardous chemical". OSHA has also added definitions to the revised HCS for pyrophoric gases and simple asphyxiants, and provided guidance on how to define combustible dust for the purposes of complying with the HCS.

• Pyrophoric gases:

  OSHA has retained the definition for pyrophoric gases from the electric current HCS.Pyrophoric gases must be addressed both on container labels and SDSs. OSHA hasprovided label elements for pyrophoric gases which include the indicate word"danger" and the gamble statement "catches fire spontaneously ifexposed to air".

• Simple asphyxiants:

  OSHA has revised the definition of simple asphyxiants that was proposed in theNotice of Proposed Rulemaking (NPRM) as a event of comments from the regulatedcommunity. In the last HCS, elementary asphyxiants must be labeled whereappropriate, and be addressed on SDSs. OSHA has provided characterization elements forsimple asphyxiants which include the indicate give-and-take "alert" and thehazard statement "may readapt oxygen and cause rapid suffocation".

• Flammable dust:

  OSHA has non provided a definition for combustible dust to the final HCS given ongoing activities in the specific rulemaking, also as in the United Nations Sub-Commission of Experts on the GHS (Un/SCEGHS). Even so, guidance is beingness provided through existing documents, including the Combustible Dust National Emphasis Plan Directive CPL 03-00-008, which includes an operative definition, likewise as provides information about current responsibilities in this area. In addition, there are a number of voluntary industry consensus standards (particularly those of the NFPA) that accost flammable grit.

  In the concluding HCS, combustible grit hazards must be addressed on labels andSDSs. Label elements are provided for combustible dust in the concluding HCS andinclude the signal word "warning" and the hazard statement "Mayform combustible dust concentrations in the air".

  For chemicals in a solid form that exercise not nowadays a combustible dust gamble,but may course combustible dusts while being processed in normal downstream uses,paragraph (f)(4) of the HCS allows the chemical manufacturer some flexibilityin labeling requirements. The manufacturer or importer to may transmit thelabel to the customer at the time of the initial shipment, but the label doesnot demand to be included with subsequent shipments unless it changes. Thisprovides the needed information to the downstream users on the potentialhazards in the workplace, while acknowledging that the solid metal or othermaterials practise not present the aforementioned hazards that are produced when thesematerials are candy under normal conditions of use.

Q: How many businesses and workers would exist affected by the revised Hazard Communication Standard?

A: OSHA estimates that over v meg workplaces in the U.s. would be afflicted by the revised Hazard Advice Standard (HCS). These are all those workplaces where employees—a total of approximately 43 million of them—could be exposed to hazardous chemicals. Included amongst these v meg workplaces are an estimated 90,000 establishments that create chancy chemicals; these chemical producers utilise almost 3 one thousand thousand workers.

Q: What are the estimated overall costs for manufacture to comply with the revised Adventure Communication Standard?

A: The revised Hazard Communications Standard's (HCS) total cost, an estimated $201 meg a yr on an annualized footing for the entire Us, is the sum of four major cost elements. (1) OSHA estimates that the cost of classifying chemical hazards in accordance with the GHS criteria and revising safety data sheets and labels to meet new format and content requirements would be $22.5 one thousand thousand a year on an annualized basis. (two) OSHA estimates that training for employees to become familiar with new warning symbols and the revised safe data canvass format under GHS would cost $95.4 million a year on an annualized footing. (3) OSHA estimated annualized costs of $59 meg a yr for direction to become familiar with the new GHS system and to engage in other direction-related activities equally may be necessary for industry's adoption of GHS. (4) OSHA estimated annualized costs of $24.1 million for press packaging and labels for hazardous chemicals in color.

Q: What are the estimated benefits attributable to the revised Hazard Communication Standard?

A: OSHA expects that the modifications to the Hazard Advice Standard (HCS) will outcome in increased safety and wellness for the afflicted employees and reduce the numbers of accidents, fatalities, injuries, and illnesses associated with exposures to hazardous chemicals. The GHS revisions to the HCS standard for labeling and condom data sheets would enable employees exposed to workplace chemicals to more speedily obtain and to more easily understand information about the hazards associated with those chemicals. In improver, the revisions to HCS are expected to meliorate the utilise of appropriate exposure controls and work practices that can reduce the safety and wellness risks associated with exposure to hazardous chemicals.

OSHA estimates that the revised HCS will result in the prevention of 43 fatalities and 585 injuries and illnesses (318 non-lost-workday injuries and illnesses, 203 lost-workday injuries and illnesses, and 64 chronic illnesses) annually. The monetized value of this reduction in occupational risks is an estimated $250 million a yr on an annualized basis.

OSHA estimates that the revised HCS volition event in savings of $475.2 million from productivity improvements for health and condom managers and logistics personnel, $32.2 1000000 during periodic updating of SDSs and labels, and $285.3 one thousand thousand from simplified hazard communication training.

OSHA anticipates that, in addition to safe and wellness benefits, the revised HCS volition effect in four types of productivity benefits: (ane) for chemic manufacturers, because they will demand to produce fewer SDSs in future years; (2) for employers, in providing grooming to new employees equally required by the existing OSHA HCS through the improved consistency of the labels and SDSs. (3) for firms engaging in, or considering engaging in, international trade.

Q. I understand that the Un revises the GHS every two years. How will OSHA manage and communicate changes to the Hazard Advice Standard?

A. It is expected that the GHS will exist a living document and is expected to remain up-to-date and relevant; therefore further changes may be adopted on a two year cycle. Soon near of the contempo updates have been clarification of text. Yet, OSHA anticipates that future updates of the Hazard Communication Standard (HCS) may exist necessary and tin can be done through various rulemaking options, including:

• Technical updates for minor terminology changes,
• Direct Final Rules for text clarification, and
• Detect and Comment rulemaking for more than substantive or controversial updates such equally additional criteria or changes in health or condom hazard classes or categories.

Source: https://www.delphon.com/blog/conforming-to-ghs/

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