OSHA and GHS HAZCOM Training by Marie Athey

© 2013 360training.com© 2013 360training.com
Marie Athey, OHST
GHS and Hazardous
Communication Compliance
Are You Ready to Meet the 12/1/2013 Deadline?

© 2013 360training.com
Marie Athey, OHST
• Director of EHS Product Line Management at 360training.com
• Degreed with over 15 years of EHS experience having
worked for various US companies in Construction and
General Industry.
• Training certifications:
– ANSI ASTM CAP
– OHST designated by BCSP
– OSHA 500 and 501 Instructor 10/30 hour classes
– Competent Person Trainer- Trenching / Excavation
– Competent Person Trainer – Fall Protection
– Competent Person Trainer- Scaffold
– HAZWOPER Instructor 1910.120
– First Aid/CPR /AED Instructor- Medic First Aid
– Approved Professional Source- State of Texas – Texas Department
of Insurance #1952

Objectives
• Understand the Scope of Globally Harmonized System
(GHS) -15 Minutes
– What is it?
– Who is affected?
• Significant Changes - 30 Minutes
– Phases of implementation
– Training topics
– Labels and SDS
– Free resources available
• Are You in Compliance? -15 Minutes
– Written Hazard Communication Program
– Training solutions

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GHS
Ready to Comply?
HAZARDOUS COMMUNICATION STANDARD
RIGHT TO KNOW
29CFR 1910.1200

Some Interesting Facts about Hazard
Communication Standard and Globally
Harmonized System
• Over 50 Million American workers are exposed to
hazardous chemicals in their workplaces.
• Over 5 Million Businesses will be impacted by the new
GHS requirements for labeling and SDS.
• HCS covers some 650,000 hazardous chemical products
found in over five million establishments.
• In 2012, OSHA issued 4,696 citations for Hazard
Communication (29 CFR 1910.1200) violations (mainly
due to lack of training, labeling fail, access to MSDSs
and lacking correct MSDSs).

Globally Harmonized System- What is it?
• OSHA revised its
Hazard
Communication
Standard (HCS)
March 2012
• Aligns with the United
Nations’ Globally
Harmonized System
of Classification and
Labeling of Chemicals
(GHS)

Globally Harmonized System (GHS)
• Nations recognized chemical hazards must be classified
and labeled under a universally understood
communications system to avoid risks to human health
and the environment.
• Nations throughout the world agreed to harmonize
chemical hazard communications under a system
developed by the United Nations (UN) and the
International Labor Organization (ILO).
• Globally Harmonized System of Classification and
Labeling of Chemicals (GHS), adopted by consensus in
2003 by the United Nations Economic and Social
Council.

Phases of Implementation
By December 1, 2013, Employees must
be trained on new labeling and SDSTo help companies
comply with the
revised standard,
OSHA is phasing in
the specific
requirements over
several years
(December 1, 2013
to June 1, 2016).

Two Significant Changes
Training Requirement:
New labeling elements
Training Requirement:
Standardized format for Safety
Data Sheets (SDSs)
Improve worker understanding of the hazards

Label Elements
Training Requirement

OSHA Minimum Required Training Topics
Training tip from Dr. Michaels:Label Elements
1. Product Identifier
2. Signal Word
3. Pictogram
4. Hazard Statement
5. Precautionary
Statements
6. Name, address,
phone of
manufacturer,
distributor, importer
OSHA requires employers: (with all training)
Present information in a manner and language that
their employees can understand.
If employers customarily need to communicate work
instructions or other workplace information to
employees in a language other than English, they
will also need to provide safety and health training
to employees in the same manner.
Similarly, if the employee’s vocabulary is limited, the
training must account for that limitation.
By the same token, if employees are not literate,
telling them to read training materials will not
satisfy the employer’s training obligation.

Required Training- Labels
Label Elements
2. Signal Word
3. Pictogram
4. Hazard Statement
5. Precautionary Statements
6. Name, address, phone of
manufacturer, distributor,
importer
Do you recognize the six
elements?

Label Elements
• Chemical Name
• Code number or batch number
• Manufacturer, importer or distributor can decide the
appropriate product identifier
• Product identifier must be both on the label and in
Section 1 of the SDS (Identification)

Label Elements
2. Signal Word
– Used to indicate the relative level of severity of
hazard and alert the reader to a potential hazard on
the label.
– Two Words: “Danger” and “Warning.”
– “Danger” is used for more severe hazards.
– “Warning” is used for less severe hazards.
– There will only be one signal word on the label no
matter how many hazards a chemical may have.
– If one of the hazards warrants a “Danger” signal
word and another warrants the signal word
“Warning,” then only “Danger” should appear on
the label.

Label Elements
Examples:
3. Pictogram:
(hazard
pictograms) with
red border
*A square red frame set at a point without a hazard symbol is not a
pictogram and is not permitted on the label.

Pictograms

Label Element:
4. Hazard Statement
• Describe the nature of the hazard(s) of a chemical.
For example: “Causes damage to kidneys through
prolonged or repeated exposure when absorbed
through the skin.”
• All of the applicable hazard statements must appear on the label.
• Hazard statements may be combined where appropriate to reduce
redundancies and improve readability.
• Hazard statements are specific to the hazard classification
categories.
• Chemical users should always see the same statement for the same
hazards, no matter what the chemical is or who produces it.

Label Elements
5. Precautionary Statement
– 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.
Example: Labels give workers information on correct storage of the
chemical or exposure effects.
Example: Information on the label might be used to quickly locate
information on first aid when needed by employees or
emergency personnel.
6. Name, address, phone of manufacturer, distributor,
importer

How the elements work together on a label
• Where a chemical has multiple hazards, different
pictograms are used to identify the various hazards.
• Employees should expect to see the appropriate
pictogram for the corresponding hazard class.
• When there are similar precautionary statements, the
one providing the most protective information will be
included on the label.

Safety Data Sheets (SDS)
Training Requirement

Safety Data Sheet (SDS)
• As of June 1, 2015,
the HCS will require
new SDSs to be in a
uniform format, and
include the section
numbers, the
headings, and
associated
information.

SDS Training Requirements
Training on the format of the SDS must include information on:
1. Standardized 16-section format, including the type of
information found in the various sections
Example- the employee should be instructed that with the new format,
Section 8 (Exposure Controls/Personal Protection) will always
contain information about exposure limits, engineering controls and
ways to protect yourself, including personal protective equipment.
2. How the information on the label is related to the SDS
Example- explain that the precautionary statements would be the same
on the label and on the SDS.

New Safety Data Sheet (SDS) Format
• Section 1, Identification
• Section 2, Hazard(s)
Identification
• Section 3,
Composition/Information on
Ingredients
• Section 4, First Aid Measures
• Section 5, Fire Fighting
Measures
• Section 6, Accidental Release
Measures
• Section 7, Handling and
Storage
• Section 8, Exposure Controls/
Personal Protection
• Section 9, Physical and
Chemical Properties
• Section 10. Stability and
Reactivity
• Section 11, Toxicological
Information
• Section 12, Ecological
Information
• Section 13, Disposal
Considerations
• Section 14. Transport
Information
• Section 15, Regulatory
Information
• Section 16, Other Information

• Section 1,
Identification
– includes product
identifier, manufacturer
or distributor name,
address, phone
number; emergency
phone number,
recommended use,
restrictions on use.

• Section 2, Hazard(s)
Identification
– includes all hazards
regarding the
chemical; required
label elements.

• Section 3,
Composition/
Information on
Ingredients
– includes information
on chemical
ingredients; trade
secret claims.

• Section 4, First aid
Measures
– includes important
symptoms/effects,
acute, delayed;
required treatment.

• Section 5, Fire Fighting Measures
– lists suitable extinguishing techniques, equipment; chemical
hazards from fire.

• Section 6, Accidental
Release Measures
– lists emergency
procedures, protective
equipment, proper
methods of
containment and
cleanup.

• Section 7, Handling
and Storage
– lists precautions for
safe handling and
storage, including
incompatibilities.

• Section 8, Exposure
Controls/ Personal
Protection
– lists OSHA’s
Permissible Exposure
Limits (PELs);
Threshold Limit Values
(TLVs); appropriate
engineering controls;
personal protective
equipment (PPE).

• Section 9, Physical
and Chemical
Properties
– lists the chemical’s
characteristics.

• Section 10, Stability
and Reactivity
– lists chemical stability
and possibility of
hazardous reactions.

• Section 11,
Toxicological
Information
– includes routes of
exposure; related
symptoms, acute and
chronic effects;
numerical measures of
toxicity.

• Section 12, Ecological information*
• Section 13, Disposal considerations*
• Section 14, Transport information*
• Section 15, Regulatory information*
Note: Since other Agencies regulate this information,
OSHA will not be enforcing Sections 12 through 15
(29 CFR 1910.1200(g)(2)).

• Sections 12 and 13
• Examples
SDS Vs. MSDS

• Section 14
• Example:
SDS Vs. MSDS

• Section 15
• Example:
SDS Vs. MSDS

• Section 16, Other
Information
– includes the date of
preparation or last
revision.

Free Supplemental Resources
• OSHA Fact Sheet – Training Requirements for the
Revised Hazard Communication Standard
– https://www.osha.gov/Publications/OSHA3642.pdf
• Quick Card SDS
– https://www.osha.gov/Publications/OSHA3493QuickCardSafetyD
ataSheet.pdf
• Quick Card Labels
– https://www.osha.gov/Publications/HazComm_QuickCard_Label
s.html

Hazardous Communication
Compliance

Checklist to Comply with HCS
 Obtain a copy of the rule. (29CFR1910.1200) osha.gov
 Read and understand the requirements.
 Assign responsibility for tasks.
 Prepare an inventory of chemicals.
 Ensure containers are labeled.
 Obtain SDS for each chemical.
 Prepare Hazardous Communication written program.
 Make SDSs available to workers.
 Conduct training for workers upon hire, annually, change.
 Establish procedures to maintain current program.
 Establish procedures to evaluate effectiveness.

We Have a Course for That
• GHS and OSHA Hazardous Communication demo

Need additional Guidance?
osha.gov
marie.athey@360training.com
Questions or Comments

OSHA and GHS HAZCOM Training by Marie Athey

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