GHS Changes to HazCom

The GHS Rule: The 4 Most Important Changes You Need to Know About

Date First Published on SafetySmart Compliance: November 2nd, 2012
Topics: GHS Transition | HazCom |

GHS LabelsIn case you don’t have the time to work through all 858 pages of the Final GHS Rule that OSHA published today, here’s a quick briefing of the key changes and how they affect you.

1. MSDSs BECOME SDSs

What’s Changing: Material Safety Data Sheets will be called Safety Data Sheets—SDSs rather than MSDSs.

Impact on You: Dropping the “M” from MSDS won’t have any substantive impact but will require administrative changes like relabeling your MSDS binders and changing “MSDS” to “SDS” in training materials, policies and programs.

2. THE INFORMATION THAT MUST BE LISTED IN THE SDS

What’s Changing:  The new SDS must list different information from the old MSDS. And while the MSDS didn’t mandate a format, the GHS rule says that each SDS must list  information under 16 specific headings. Key new info that must be on the SDS includes:

  • “Signal words,” e.g., DANGER for severe hazards or WARNING for less severe ones, to let users know the stuff is hazardous;
  • Symbols or pictograms, e.g., skull-and-crossbones or flames, to alert users to dangerous properties;
  • More detailed first-aid information, including measures for each route of entry; and
  • More detailed fire-fighting measures, including which extinguishing agents to use and not use.

Impact on You: You need to ensure that every hazardous substance in your workplace has an SDS that meets the new GHS standards by Dec. 1, 2013. The more hazardous substances you use, the more burdensome this task will be.

According to OSHA’s estimates—which for obvious reasons tend to be on the low side—medium establishment (100 to 499 employees) should expect to spend 5 hours per SDS; other medium establishments might incur $208 per SDS in additional software modification costs; small establishments (up to 99 employees) are looking at 7 hours per SDS.

3. FORMAT & INFORMATION IN WORKPLACE LABELS

What’s Changing:  Workplace labels aren’t going away. But GHS labels will be different from the Hazcom labels you’re used to. Labels still must include information about the chemical’s identity, its hazards, etc. But whereas Hazcom didn’t specify a format, the GHS label will have to incorporate 4 standard design elements:

  • Signal words like “DANGER” or “WARNING”;
  • Square shaped pictograms displaying one of 8 black hazard symbols,  e.g., a flame over circle for oxidizers, on a white background with a red frame;
  • Specific hazard statements based on the kind of chemical and hazards it poses; and
  • Precautionary statements.

Impact on You: Effective Dec. 1, 2013, you must ensure that all hazardous substances have a workplace label that meets the new GHS requirements. If your current labels are black-and-white, you’ll have to switch over to color printing so that the color elements of pictograms, i.e., the red frames around hazard symbols, show.  Estimated costs: $.01 to $.014 per label, depending on how big the establishment is.

4. THE NEED TO RE-TRAIN EMPLOYEES

What’s Changing: GHS doesn’t change the “training and information” requirements of Hazcom. As before, employees will still have the “right to know” about the hazardous chemicals they work with.  But what GHS does change is the information employees will have to be trained in.

Impact on You: You will have to train or re-train all employees so that they know how to read and use the new SDS and GHS labels so that they’re ready to make the transition to the new system on Dec. 1, 2013. According to OSHA estimates, training required will be for:

  • Most industries: 1 hour per employee;
  • Occupations with little chemical exposure: 30 minutes per employee;
  • Occupations already using pictograms: 10 minutes per employee.

 

Conclusion: GHS Could Have Been Much Worse

If, like the majority of employers, you acquire the hazardous substances you use from a manufacturer or importer, you spent time, energy and money getting ready for GHS in time for the Dec. 1, 2013 deadline. But it could have been worse. The companies that GHS will hit hardest are the ones that manufacture or import hazardous substances. These companies will have to reclassify their products according to new hazard criteria and then have to develop an entirely new MSDS and label for each product.

 

INFORMATION THAT MUST BE LISTED IN THE SDS

Heading

Key Info Required

Identification

  • Product identifier on label
  • Other means of identification
  • Recommended uses & restrictions
  • Name, address, phone of manufacturer, importer or other responsible party
  • Emergency phone no.

Hazard(s) identification

  • Chemical classification
  • “Signal words,” i.e., DANGER or WARNING, depending on severity, symbols, e.g., skulls and crossbones and/or precautionary statements describing the hazards
  • Statement of unknown acute toxicity for mixtures containing 1% or more unknown acute toxicity ingredients

Composition/information on ingredients

Different requirements for:

  • Substances
  • Mixtures
  • Chems claimed to be a trade secret

First aid measures

  • Different measures for different routes of entry
  • Key symptoms—acute & delayed
  • Indication if immediate medical treatment is needed

Fire fighting measures

  • Suitable/unsuitable extinguishing agents
  • Combustion & other chemical hazards
  • PPE needed

Accidental release measures

  • PPE & emergency procedures to use
  • Methods/materials to contain & clean up

Handling & storage

  • Precautions for handling
  • Conditions for safe storage

Exposure controls/personal protection

  • OSHA PEL
  • ACGIH TLV
  • Appropriate engineering controls
  • PPE

Physical & chemical properties

  • Appearance
  • Odor
  • Odor threshold
  • pH
  • Melting/freezing point
  • Initial boiling point & boiling range
  • Flash point
  • Evaporation rate
  • Flammability
  • Upper/lower flammability or explosive limits
  • Vapor pressure & density
  • Relative density
  • Solubility
  • Partition coefficient: n-octanol/water
  • Auto-ignition temperature
  • Decomposition temperature
  • Viscosity

Stability & reactivity

  • Reactivity
  • Chemical stability
  • Possibility of hazardous reactions
  • Conditions to avoid
  • Incompatible materials
  • Hazardous decomposition products

Toxicological information

  • Likely routes of exposure
  • Symptoms
  • Delayed & immediate effects from exposure
  • Numerical toxicity estimates

Ecological information (non-mandatory)

  • Ecotoxicity
  • Degradability
  • Bioaccumulative potential
  • Mobility in soil
  • Other adverse effects

Disposal considerations (non-mandatory)

Safe methods of disposal

Transport information (non-mandatory)

  • UN no. & shipping name
  • Transport hazard class
  • Packing group
  • Enviro hazards
  • Special precautions

Regulatory information (non-mandatory)

EHS regulations that pertain to product

Other information

  • Date SDS was prepared
  • Date SDS was last changed
  • Other
 
 
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