How GHS Affects Welding Operations

  editor |   Laws & Regulations

QUESTION:

We do a lot of welding and brazing at our site. I read in one of those web chatrooms where GHS is going to have a big impact on welding operations. Is that just urban legend or is it true? Can you explain?

ANSWER:

Yes. Even though you shouldn’t believe everything you read on the internet, this is one of those occasions where the info is actually accurate.

About The Expert

Glenn Demby is an OSHA attorney and editor-in-chief of SafetySmart Compliance

EXPLANATION:

First, I want to say that I love your question because it brings up a significant point about GHS that has gone largely overlooked: GHS changes not Hazcom but other chemical safety programs and requirements based on Hazcom rules, e.g., standards like Hazwoper (click on the link for the Safety Smart Compliance Hazwoper Compliance Center) and

Process Safety Management that incorporate definitions from Hazcom such as “flashpoint,” “health hazard” and “flammable liquid” that GHS is changing.

Welding, Cutting and Brazing, General Requirements (Sec. 1910.252) is actually one of the non-Hazcom standards that GHS affects directly. The contaminants used in welding operations are hazardous chemicals subject to Hazcom. To coordinate the welding standard with the new GHS rules, OSHA added a new provision to the standard (Section 1910.252(c)(1)(iv)), which requires employers to do 2 things:

1. Include Welding Materials in their Hazard Communication Program

First, new Section 1910.252(c)(1)(iv) requires employers to include the potentially hazardous materials used in fluxes, coatings, coverings and filler metals—all of which may be used or released into the atmosphere during welding and coating operations—in their written Hazard Communication Program (HCP). (Click on the hyperlink to find out more about how GHS affects the HCP.) In other words, you’ll have to ensure each employee who uses or is exposed to these substances:

  • Has access to an MSDS or SDS for each substance;
  • Has access to a label on the containers of these substances; and
  • Is trained how to use the new SDS and GHS labels.

2. Ensure Containers of Welding/Cutting Contaminants Have Proper GHS Labels

Containers of dangerous chemicals used in welding and cutting operations must have a workplace label meeting Hazcom/GHS requirements. For some substances, labels must also display additional information. There are 2 sets of rules, depending on time period:

Now Until June 1, 2015

Containers of potentially hazardous materials used in fluxes, coatings, coverings and filler metals must have a workplace label that complies with GHS label rules. In addition:

All filler metals and fusible granular materials must list at least one of the following: notices on tags, boxes or other containers:

Option 1: Do not use in areas without adequate ventilation. See ANSI Z49.1-1967 Safety in Welding, Cutting and Allied Professions published by the American Welding Society; or

Option 2: CAUTION:

Welding may produce fumes and gases hazardous to health. Avoid breathing these fumes and gases. Use adequate ventilation. See ANSI Z49.1-1967 Safety in Welding and Cutting published by the American Welding Society

Brazing (welding) filler metals containing “significant amounts” of cadmium must have a label:

Option 1: A label indicating the hazards associated with cadmium including cancer, lung and kidney effects and acute toxicity effects.

Option 2: The following notice:

CONTAINS CADMIUM—POISONOUS FUMES MAY BE FORMED ON HEATING.

Do not breathe fumes. Use only with adequate ventilation such as fume collectors, exhaust ventilators or air-supplied respirators. See ANSI Z49.1-1967. If chest pain, cough or fever develops after use call physician immediately.

Brazing and gas welding fluxes containing fluorine compounds must have either:

Option 1: A label indicating the hazards associated with fluorine compounds including eye and respiratory tract effects.

Option 2:A cautionary wording to indicate that the chemical contains fluorine compounds. Recommended warning:

CAUTION

CONTAINS FLUORIDES

This flux when heated gives off fumes that may irritate the eyes, nose and throat.

  1. Avoid fumes—use only in well ventilated spaces
  2. Avoid contact of flux with eyes or skin
  3. Do not take internally

After June 1, 2015

 

All of the above hazardous chemicals used in welding will need to have a GHS label and only a GHS label on the container. In other words, Option 2 disappears and Option 1 becomes mandatory.

Got a Question About GHS or Other OSHA Topic?

Let me know what’s on your mind and I’ll do my level best to give you some answers and practical guidance. glennd@bongarde.com.

 
 
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