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The un-harmonized GHS: SDS Sections 11-16
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US Hazard Communication Essentials
Dec 08, 2014-Dec 11, 2014
Pittsburgh, PA
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OSHA has published its long awaited final rulemaking to bring the existing Hazard Communication Standard (HCS) (29 CFR 1910.1200) in line with Revision 3 of the United Nation’s Globally Harmonized System of Classification and Labelling (GHS) which also is known simply as the Purple Book.

The final Rulemaking will be issued on March 26, 2012, and up to then can be found at: http://www.osha.gov/dsg/hazcom/ghs-final-rule.html

HAZARD CLASSES

As indicated in its proposed rulemaking, OSHA has adopted all physical and health hazard endpoints found in the revision 3 of the Purple Book with the following exceptions:

  • Acute Toxicity (category 5 for oral, dermal and inhalation exposures)
  • Skin Corrosion/Irritation (category 3)
  • Aspiration Hazard (category 2)
  • Hazardous to the Environment (all endpoints)

These exclusions are consistent with the prior scope of coverage found in 29 CFR 1910.1200 originally effective November 25, 1985.

Additional endpoints that are now included are:

  • Combustible dusts
  • Pyrophoric gases
  • Simple asphyxiants

Hazards not specifically addressed by the United Nation’s Globally Harmonized System of Classification and Labelling (GHS) are now termed ‘hazards not otherwise classified’ by OSHA.

Health hazard criteria can be found in Appendix A while physical hazard criteria can be found in Appendix B.

The following tables identify the included building blocks:

Health Hazards

Acute toxicity (Category 1, 2, 3 and 4)

Skin corrosion/irritation (Category 1A, 1B, 1C and 2)

Serious eye damage/irritation (Category 1, 2A and 2B)

Respiratory sensitization (Category 1A and 1B)

Skin sensitization (Category 1A and 1B)

Germ cell mutagenicity (Category 1A, 1B and 2)

Carcinogenicity (Category 1A, 1B and 2)

Reproductive toxicity (Category 1A, 1B and 2)

Effects on or via lactation

Specific target organ toxicity – single exposure (Category 1, 2 and 3)

Specific target organ toxicity – repeated exposure (Category 1, and 2)

Aspiration hazard (Category 1)

 

Physical Hazards

Explosives Division (Unstable explosive, Division 1.1, 1.2, 1.3, 1.4, 1.5, 1.6)

Flammable gases (Category 1 and 2)

Flammable aerosols (Category 1 and 2)

Oxidizing gases (Category 1)

Gases under pressure (Compressed gas, Liquefied gas, Dissolved gas, Refrigerated liquefied gas)

Flammable liquid (Category 1, 2, 3 and 4)

Flammable solids (Category 1 and 2)

Self-reactive chemicals (Type A, B, C, D, E, and F)

Pyrophoric liquids (Category 1)

Pyrophoric solids (Category 1)

Self-heating substances and mixtures (Category 1 and 2)

Chemical which in contact with water release flammable gases (Category 1, 2 and 3)

Oxidizing liquids (Category 1, 2 and 3)

Oxidizing solids (Category 1, 2 and 3)

Organic peroxides (Type A, B, C, D, E, and F)

Corrosive to metal (Category 1)

 MIXTURE CLASSIFICATION

Mixture classification is no longer simply based on two simple thresholds (0.1% and 1%). Mixture classification for health hazards is handled by one of several ways:

  1. Bridging Principles (can apply to acute toxicity endpoints – see Figure A.1.1 – and certain other health endpoints)
  2. Formula (one of two calculations may apply to acute toxicity endpoints – see Figure A.1.1) 
  3. Summation (a calculation method  that applies to skin corrosion/irritation and serious eye damage/irritation endpoints)
  4. Non-additive methods (applies to skin corrosion/irritation and Serious eye damage/irritation endpoints)
  5. Cut-off values/concentration limits method (Sensitization - respiratory and skin, germ cell mutagenicity, carcinogenicity, reproductive toxicants, specific target organ toxicity - single exposure, specific target organ toxicity - repeated exposure)

 Safety Data Sheet

OSHA has included an obvious but necessary change to ensure world-wide consistency when referring to hazard communication documents. The phrase ‘Material Safety Data Sheet’ and the acronym ‘MSDS’ is being replaced by the phrase ‘Safety Data Sheet’ and the acronym ‘SDS’ respectively.

Appendix D – Safety Data Sheets outlines the required format for the SDS and is considered mandatory.

As was expected, OSHA is allowing the use of a 16 section format for SDSs but will not enforce information requirements for Sections 12 through 15 as coverage in these sections exceeds the scope of OSHA’s mandate.

LABELING

Appendix C – Allocation of Label Elements is considered mandatory and identifies per endpoint, the required symbol/pictogram, signal word, hazard statements and precautionary statements (prevention, response, storage and disposal). Additional required label elements are the product identifier and the name, address and telephone number of the manufacturer, importer or other responsible party.

Symbols/pictograms will be in the shape of a square set at a point and shall include a black hazard symbol on a white background with a red frame sufficiently wide to be clearly visible.

The existing stay on enforcement of label changes within 90 days is being lifted.  The new timeframe for label update is six months after becoming aware of new information.  By the end of the six month period, chemical manufacturers, importers, distributors or employers must ensure that labels on containers shipped contain new, significant information regarding the hazards of a chemical.

 TRANSITION PERIOD

Provisions of the Final Rule will become effective 60 days after publication in the Federal Register.

Effective Completion Date

Requirement(s)

Who

December 1, 2013

Train employees on the new label elements and SDS format.

Employers

June 1, 2015

December 1, 2015

Compliance with all modified provisions of this final rule, except: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.

Chemical manufacturers, importers, distributors and employers

June 1, 2016

Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Employers

Transition period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard) or the current standard or both

Chemical manufacturers, importers, distributors and employers

 AFFECTED CITATIONS

Other standards such as the Flammable and Combustible Liquids Standard (29 CFR 1910.106), the Process Safety Management Standard (29 CFR 1910.119) and selected substance specific health standards (29 CFR 1910.1001-1052) have been revised to conform to the new criteria as well as revised for associated hazard communication elements. Here’s a complete listing of affected citations:

PART 1910 – OCCUPATIONAL SAFETY AND HEALTH STANDARDS

Subpart A

 

29 CFR 1910.6

Incorporation by reference

Subpart H

 

29 CFR 1910.106

Flammable liquids

29 CFR 1910.107

Spray finishing using flammable and combustible materials

29 CFR 1910.119

Process safety management of highly hazardous chemicals

29 CFR 1910.120

Hazardous waste operations and emergency response

29 CFR 1910.123

Dipping and coating operations: coverage and definitions

29 CFR 1910.124

General requirements for dipping and coating operations

29 CFR 1910.125

Additional requirements for dipping and coating operations that use flammable or combustible liquids

Subpart Q

 

29 CFR 1910.252

General requirements

Subpart Z

 

29 CFR 1910.1001

Asbestos

29 CFR 1910.1003

13 carcinogens

29 CFR 1910.1017

Vinyl toluene

29 CFR 1910.1018

Inorganic arsenic

29 CFR 1910.1025

Lead

29 CFR 1910.1026

Chromium (VI)

29 CFR 1910.1027

Cadmium

29 CFR 1910.1028

Benzene

29 CFR 1910.1029

Coke oven emissions

29 CFR 1910.1043

Cotton dust

29 CFR 1910.1044

1,2-dibromo-3-chloropropane

29 CFR 1910.1045

Acrylonitrile

29 CFR 1910.1047

Ethylene oxide

29 CFR 1910.1048

Formaldehyde

29 CFR 1910.1050

Methylenedianiline

29 CFR 1910.1051

1,3-butadiene

29 CFR 1910.1052

Methylene chloride

29 CFR 1910.1200

Hazard communication

29 CFR 1910.1450

Occupational exposure to hazardous chemicals in the laboratories

PART 1915 – OCCUPATIONAL SAFETY AND HEALTH STANDARDS FOR SHIPYARD EMPLOYMENT

Subpart Z

 

29 CFR 1915.1001

Asbestos

29 CFR 1915.1026

Chromium (VI)

PART 1926 –SAFETY AND HEALTH REGULATIONS FOR CONSTRUCTION

Subpart D

 

29 CFR 1926.60

Methylenedianiline

29 CFR 1926.62

Lead

29 CFR 1926.64

Process safety management of highly hazardous chemicals

29 CFR 1926.65

Hazardous waste operations and emergency response

Subpart F

 

29 CFR 1926.152

Flammable liquids

29 CFR 1926.155

Definitions applicable to this subpart

Subpart Z

 

29 CFR 1926.1101

Asbestos

29 CFR 1926.1126

Chromium

29 CFR 1926.1127

Cadmium

FURTHER INFORMATION

The text of the final rulemaking will be published in the Federal Register on Monday March 26, 2012. As is consistent with any published changes to existing rules, only the revised or new text will appear in this document.  OSHA has also made available Quick Cards, Fact Sheets and FAQs to aid understanding and ensure compliance with the new Hazard Communication Standard 2012.

Redline strikeout of the HCS Final Regulatory text 2012 can be found at: http://www.osha.gov/dsg/hazcom/redline.html. The Side-by-Side Comparison of OSHA’s Existing Hazard Communication Standard (HCS 1994) vs. the Revised Hazard Communication Standard (HCS 2012) which can be found at: http://www.osha.gov/dsg/hazcom/side-by-side.html

Training Courses

The un-harmonized GHS: SDS Sections 11-16
Nov 10, 2014
Online
Read More

REACH Essentials
Nov 10, 2014
Pittsburgh, PA
Read More

REACH Practical Implementation
Nov 11, 2014-Nov 12, 2014
Pittsburgh, PA
Read More

REACH for Article Manufacturers, Importers, and Distributors
Nov 13, 2014
Pittsburgh, PA
Read More

US Hazard Communication Essentials
Dec 08, 2014-Dec 11, 2014
Pittsburgh, PA
Read More

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