Introducing the Globally Harmonized System (GHS)

OSHA's Hazcom Revisited

In a world economy, many countries both import and export to the United States a wide variety of goods, including chemicals. The global chemical business is more than $1.7 trillion each year, according to the Occupational Safety and Health Administration (OSHA). Chemicals affect all of our lives, both personally and professionally. Employees are entitled to know what chemicals are in the workplace and any potential hazards they may have. As employers, we are required to keep this information easily accessible and updated. OSHA's Hazard Communication Standard (HCS) addresses this requirement.

OSHA is changing the hazardous communication classification and communication provisions of hazard communications. As employers, you must be up-to-date on your responsibilities involving the Globally Harmonized System (GHS). According to OSHA, the GHS is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. The GHS was negotiated in a multiyear process by hazard communication experts from many different countries, international organizations and stakeholder groups. It is based on major existing systems around the world, including OSHA's HCS and the chemical classification and labeling systems of other U.S. agencies. These recommendations can be used by regulatory authorities such as OSHA to establish mandatory requirements for hazard communication, but they do not constitute a model regulation.

"Exposure to hazardous chemicals is one of the most serious threats facing American workers today," said former U.S. Secretary of Labor Hilda Solis. "Revising OSHA's Hazard Communication Standard will improve the quality and consistency of hazard information, making it safer for workers to do their jobs and easier for employers to stay competitive."

The HCS is now aligned with the GHS of Classification and Labeling of Chemicals. This update to the HCS will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. Once implemented, the revised standard will improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals.

Many of you have probably never paid attention to the data sheets in the bright yellow material safety data sheet manual that you are required to have. Take a glance at them. Some are one paragraph and some are five pages long. If you accidentally get some chemical in your eye, you do not want to have to read through a data sheet that has no kind of required order and that might be several pages long before you know if you're supposed to flush the chemical or not. That is the primary reason that this GHS system is being implemented.

To ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. OSHA's HCS requires the development and dissemination of such information:

> Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers. |

> All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.

In the new version, each chemical data sheet will have 16 unified sections-meaning all manufacturers will use the exact same format/pictograms/ codes to make it simple to read and understand quickly. Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices and emergency control measures (e.g., fire fighting). This should be helpful to those who need to get the information quickly.

As of June 1, 2015, the HCS will require pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard. The pictogram on the label is determined by the chemical hazard classification. You have to train your employees on these pictograms by December 1, 2013.

Major Changes bo bhe Hazard Communicabion Sbandard

> Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.

> Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided.

> Safety data sheets: Will now have a specified 16-section format.

> Information and training: Employers are required to train workers by December 1, 2013, on the new labels' elements and safety data sheets' format to facilitate recognition and understanding.

> December 1, 2015: Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it has a GHS label. Prior to this time, manufacturers will start to use the GHS system. This is why you have to train your employees before they start to see the new versions of the data sheets.

Telcom Insurance Group has put together a train-the-trainer PowerPoint presentation that you can use to meet this training deadline of December 1, 2013. If you'd like a copy, please contact us. 0

As employers, you musb be up-bo-dabe on your responsibilibies involving bhe GHS.

HCS Pictograms and Hazards

FLAME OVER CIRCLE

? Oxidizers

FLAME

? Flammables

? Pyrophoric s

? Self-Heating

? Emits Flammable Gas

? Self-Reactives

? Organic Peroxides

HEALTH HAZARD

? Carcinogen

? Mutagenicity

? Reproductive Toxicity

? Respiratory Sensitizer

? Target Organ Toxicity

? Aspiration Toxicity

EXCLAMATION MARK

? Irritant (skin and eye)

? Skin Sensitizer

? Acute Toxicity

? Narcotic Effects

? Respiratory Tract Irritant

? Hazardous to Ozone Layer (Non-Mandatory)

EXPLODING BOMB

? Explosives

? Self-Reactives

? Organic Peroxides

CORROSION

? Skin Corrosion/Burns

? Eye Damage

? Corrosive to Metals

ENVIRONMENT

(NONMANDATORY)

? Aquatic Toxicity

SKULL & CROSSBONES

? Acute Toxicity (fatal or toxic)

GAS CYLINDER

? Gases Under Pressure

Marilyn A. Blake is chief operating officer of Telcom Insurance Group. She can he reached at MA B @telcominsgrp. com.