The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS)
|Effective Completion Date||Requirement(s)||Who|
|December 1, 2013||Train employees on the new label elements and safety data sheet (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|
Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
Safety Data Sheets:
The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
Information and training:
To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.
Class the hazard or hazards assigned to a product, or inherent properties, which are identified as physical, health, and environmental.
Category the degree of danger represented by the hazard of a particular product, these range from category 1, great danger to category 5, low danger.
Product Identifier chemical name or trade name or proper shipping name.
Safety Data Sheet (SDS) analogous to MSDS in the U.S. These are sheets or a booklet that describe the hazards of the product, and give details about safe handling and responding to emergencies.
Pictogram the symbol or sign used to identify the class (hazard(s)) assigned to a product on the warning label. There are 9 pictograms.
Signal Word is the word Danger or Warning that will appear as part of the warning label. Indicates the degree of hazard the product possesses.
Hazard Statements are standardized statements that will appear as part of the hazard communication system identifying just what hazards the user should be aware of.
Precautionary Statements are standardized statements (and/or pictogram) which describe recommended measures that should be taken to minimize adverse effects resulting from exposures to a hazardous product, or improper storage or handling of a hazardous product.
Three basic classes of hazards:
Physical - e.g. flammability or reactivity
Health - immediate and long-term toxicity
Environmental - toxicity to aquatic organisms, potential to bio accumulate or persist in the environment, and things hazardous to the ozone layer.
Acute Toxicity (immediate hazard)
Chronic Toxicity (long-term hazard)
Categories 1 through 5 - similar to transportation packing group
Categories may be further sub-divided, e.g. Category 1A, 1B, 1C, etc. Explosive hazards are designated by “divisions”. The less dangerous categories may not be regulated in all modes in all countries.
Example: Assigning categories using the GHS system
|Exposure Route||Category 1||Category 2||Category 3||Category 4||Category 5|
|Oral (mg/kg bodyweight)||5||50||300||2000||5000|
|Dermal (mg/kg bodyweight)||50||200||1000||2000||5000|
|Dusts and Mists (mg/l)||0.05||0.5||1.0||5||5000|
Note: A very small amount, 0-5 mg/kg of bodyweight (oral), of an acutely toxic substance yields an LD50 (the lethal dose kills 50 % of the tested population). This results in assigning a Category 1 - most hazardous designation. (Example: Cyanide - http://en.wikipedia.org/wiki/Cyanide)
Classification (class and category) drives labeling. Information should be conveyed in more than one way, both symbols and text.
GHS Standardized Elements:
Only two words are used, “Danger” or “Warning”, to emphasize the hazard and differentiate between the degrees of hazard. Danger is used for higher hazard materials, and Warning for lower level hazards. The use of one word excludes the use of the other.
GHS assigns a single harmonized statement for each level of hazard within each hazard class. See Annex 3 - Section 1, of the Globally Harmonized System of Classification and Labeling of Chemicals (2011) Fourth Revised Edition . Example below:
Example: Flammable liquids
Note: Another useful reference is Annex 1 "Allocation of Label Elements". This resource includes the label pictogram, signal word, hazard statement, and the UN Model Regulation pictogram and information.
Hazard Statements: phrase assigned to a hazard class and category which describes the nature of the hazard. Each statement will uniquely express the hazardous product, including, where appropriate, the degree of hazard.
What does a Hazard Code look like?
Where can I find further information on the different types of Hazard statements?
Do I need to apply both hazard statement and code when creating a Label?
What are the requirements for hazard statements when preparing a SDS?
This element is not yet mandatory in the U.S. as of Jan 2013. Mandatory or recommended inclusion of precautionary statements on the label will be left up to the individual country. Annex 3 - Section 2 discusses the codification and use of precautionary statements.
Note: Only those label elements identified with a red arrow are currently required under the GHS labeling system. The chemical or product/trade name serves as the product identifier and one should identify the hazardous ingredients where appropriate.
Precautionary Statements: phrases (and/or pictograms) that describe recommended measures that should be taken in order to minimize or prevent adverse effects that could result from improper storage and handling of or exposure to a hazardous product.
What does a Precautionary Code look like?
Where can I find further information on the different types of Precautionary statements?
Do I need to apply a precautionary statement and code when creating a label?
What are the requirements for precautionary statements when preparing a SDS?
"P313: Get medical advice/attention"
"P330: Rinse mouth"
The SDS will provide comprehensive information about a chemical substance or mixture, including:
GHS referenced standards, include but not limited to, to assist in SDS preparation:
OSHA will not regulate:
Differences in cut-offs - OSHA new category "Unclassified Hazard" to cover hazards originally included in the OSHA standard but not included in the GHS.
U.S. Department of Transportation:
US DOT harmonization with GHS has already been completed.
Note: The definitions and criteria of the hazards of a substance can be found in the Globally Harmonized System Revision 4 2011 edition. Physical hazards are found in Part 2, health hazards are found in part 3, and environmental hazards are found in part 4.
OSHA recommends that employers offer the following prevention strategies (listed in order of OSHA priority):
Engineering controls eliminate or reduce exposure to a chemical or physical hazard through the use or substitution of engineered machinery or equipment. Examples include self-capping syringe needles, ventilation systems such as a fume hood, sound-dampening materials to reduce noise levels, safety interlocks, and radiation shielding.
Administrative controls (or work practice controls) are changes in work procedures such as written safety policies, rules, supervision, medical surveillance and training with the goal of reducing the duration, frequency, and severity of exposure to hazardous chemicals or situations.
Personal Protective Equipment (PPE) such as safety glasses with side shields, splash goggles, face shields, chemical resistant gloves, hard hats, rubber aprons, safety shoes, respirators, & hearing protectors must be worn when required, and maintained in good condition. The employer is responsible for providing proper PPE to the employee (this does not apply to students in classes or labs).
In order of most common to least common: Inhalation, Absorption, Ingestion, Injection
COMPRESSED GAS - Any gas, mixture of gases or liquids in a container having a pressure or vapor pressure exceeding ANSI Standards.
The following precautions must be used when handling:
Safety Data Sheet (SDS)
Other Specific Information
All safety data sheets for Alfred University can be found on the internet at MSDS. Please use the following link for instructions and access to the site.http://people.alfred.edu/~envhealthsafety/msds/msds.htm
If your work area or laboratory does not have access to a computer, a hard copy of all SDS’s in a 3-ring binder must be maintained in addition to the electronic copy. Supervisors are responsible for assigning an MSDS Online site administrator, and notifying EH&S when a new site administrator has been assigned. EH&S will train MSDS Online site administrators utilizing both online and individual training.
It is the employee's responsibility to read, understand and follow the information provided by an SDS for any hazardous material they may use or come in contact with.
Ensure your work area/lab has the following safety devices/systems:
An Emergency Response information folder has been published by Alfred University providing detailed information relating to emergencies and non-emergencies. A copy of this folder may be obtained by contacting the office of Public Safety at ext. 2108.
The Alfred University Accident/Incident/Near-Miss Investigation Report can be found at the following link:https://my.alfred.edu/ehs
The report must be submitted to EH&S within 24 hours
The EH&S Office is located in Myers Hall Rm. 117
The EH&S website is located at https://my.alfred.edu/ehs
Emergency (from campus phone) 9-911
Mike Honeycutt (EH&S Coordinator)
Dean Perry (EH&S Co-Coordinator)