HAZ COM-How to Prepare for the 2013 Deadline and Other Critical FAQs Presented by: Brad Harbaugh MSDSONLINE Tuesday, April 23, 2013 1:30 p.m. to 3:00 p.m. Eastern 12:30 p.m. to 2:00 p.m. Central 11:30 a.m. to 1:00 p.m. Mountain 10:30 a.m. to 12:00 p.m. Pacific www.blr.com or www.hrhero.com For CD and other purchasing information, contact customer service at: 800-274-6774 or E-mail: [email protected] © 2013 BLR ® and HR Hero® —Business & Legal Resources and HR Hero. All rights reserved. These materials may not be reproduced in part or in whole by any process without written permission. This webinar qualifies for Continuance of Certification (COC) credit. CSPs will earn 0.075 COC points for attending this webinar. 4/17/2013 HAZ COM-How to Prepare for the 2013 Deadline and Other Critical FAQs Presented by: Brad Harbaugh MSDSonline April 23, 2013 Brad Harbaugh Editor of the EH&S Blog, MSDSonline 2 1 4/17/2013 Goals for this Presentation Intro GHS and OSHA’s Adoption Deadlines and Responsibilities 2013 Training GHS Compliance Best Practices FAQs 3 What is HCS? Hazard Communication Standard An OSHA Regulation – protect workers from hazardous chemicals Adopted in 1983 Covers 43+ Million U.S. Workers 5 Million Workplaces Over 880,000 Chemicals 4 2 4/17/2013 Who has Responsibilities Employers Who “Use” Chemicals Are responsible for the following as part of a compliant HazCom program: 1. 2. 3. 4. Written Hazard Communication Plan / Program Written Chemical Inventory Ensuring proper use of Labels and Warnings Maintaining MSDSs and providing Right-to-Know access to employees 5. Providing Employee Training 5 The Problem Regulations vary widely internationally Within a country, regulations vary widely among agencies with jurisdiction over hazardous chemicals Multiple labels & MSDSs often required for same product being shipped to different locations Workers see different labels and MSDSs for similar products from different manufacturers 6 3 4/17/2013 Enter GHS GHS = Globally Harmonized System of Classification and Labelling of Chemicals 1st edition approved in 2002 and published by UN in 2003 Result of international mandate (Chapter 19 of Agenda 21) from 1992 Rio Earth Summit (i.e.,UNCED) Common & coherent global approach To Classifying and Defining & Communicating Hazards Provides Consistency/ Harmonization to Labels and Safety Data Sheets 7 GHS At-A-Glance GHS is Not… A Regulation, Standard or Mandate GHS is… Collection of best practices Adaptable by Country (and Agency) Referred to as the “Building Block Approach” Select parts of system that apply to existing regulations Implementation consistent with requirements in place, or can use to create new requirements 8 4 4/17/2013 OSHA Alignment with GHS Revise HCS to Align with GHS Maintain HCS framework Enhance protection Based on GHS Rev 3 (2009) Major Changes Chemical Classification Safety Data Sheets (SDSs) Labels 9 GHS Alignment Timeline 1 • Dec. 1, 2013 ─ EMPLOYERS • Train on new label elements and SDS format 2 • June 1, 2015 ─ MANUFACTURERS, DISTRIBUTORS & IMPORTERS • Reclassify chemicals, and update all SDSs and labels to GHS format 3 • Dec. 1, 2015 ─ DISTRIBUTORS • Begin sending only GHS formatted SDSs and GHS labeled products Deadline also applies to EMPLOYERS who choose to perform their own chemical classifications instead of relying on those provided by Mfr/Distr/Imptr • June 1, 2016 ─ EMPLOYERS 4 ANYTIME during Transition • Update alternative workplace labeling and HazCom Program as needed, and provide addtl. employee training for newly identified physical or health hazards • EMPLOYERS, MANUFACTURERS, and DISTRIBUTORS • Comply with either HazCom 1994, or HazCom 2012, or both 10 5 4/17/2013 Deadline: December 1, 2013 Train Employees on: New label elements New safety data sheet format Why the Rush? 11 Why Train on GHS? Try to think like your employees as you look at these next slides. 12 6 4/17/2013 Why Train on GHS? Do you know what these pictograms mean? 13 Why Train on GHS? 14 7 4/17/2013 Why Train on GHS? Oxidizers 15 Why Train on GHS? 16 8 4/17/2013 Why Train on GHS? Environmental Toxicity 17 Why Train on GHS? 18 9 4/17/2013 Why Train on GHS? Carcinogenicity Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity 19 Why Train on GHS? Are you familiar with the updated GHS SDS format? 20 10 4/17/2013 Why Train on GHS? How Many Sections in a GHS Formatted SDS? 21 SDS 1. - 9. - 2. - 10. - 3. - 11. - 4. - 12. - 5. - 13. - 6. - 14. - 7. - 15. - 8. - 16. - 22 11 4/17/2013 Why Train on GHS? What Sections Are Outside OSHA’s Jurisdiction? 23 SDS 1. - 9. - 2. - 10. - 3. - 11. - 4. - 12. Ecological Information 5. - 13. Disposal Considerations 6. - 14. Transport Information 7. - 15. Regulatory Information 8. - 16. - 24 12 4/17/2013 Why Train on GHS? In what section of an SDS do you find Hazard(s) Identification info? 25 SDS 1. - 9. - 2. Hazard(s) Identification 10. - 3. - 11. - 4. - 12. - 5. - 13. - 6. - 14. - 7. - 15. - 8. - 16. - 26 13 4/17/2013 Why Train on GHS? How would your employees do answering those same questions? 27 Examples of What to Cover for December 1, 2013 Training Deadline 1/11/2013 28 28 14 4/17/2013 Shipped Labels Six Main Elements 1) Product/Chemical Identifier 2) Signal Word 3) Hazard Pictogram(s)* 4) Hazard Statement(s)* 5) Precautionary Statements** 6) Supplier Identifier ** Standardized under HCS * Standardized under GHS 29 Shipped Labels 1) Product Identifier 9 Name used to identify chemical (e.g., chemical name, code or batch number) 9 Same identifier should also appear in Section 1 of the SDS 2) Signal Word 9 Two Signal words: Danger or Warning 9 Only one will appear, not both – the one representing the most severe hazard 30 15 4/17/2013 Shipped Labels 3) Hazard Pictogram 9 Harmonized black hazard symbol surrounded by a red diamond border on a white background 9 8 of 9 adopted – Review each Environment was not adopted 9 Must contain all elements No red diamond borders should appear without their respective hazard symbols and vice versa Environment Environmental Toxicity (Not mandatory) 31 Label Pictograms North America Current North America (U.S. DOT/ Canada WHMIS) Systems 32 16 4/17/2013 Label Pictograms – DOT and GHS Transport Pictograms GHS Pictograms 33 Label Pictograms Exploding Bomb Explosives Self Reactive Organic Peroxide Gas Cylinder Flame Flame Over Circle Flammable Self Reactive Pyrophoric Self-Heating Emits Flammable Gas Organic Peroxides Skull and Crossbones Gases Under Pressure Health Hazard Acute Toxicity (Fatal or toxic) Exclamation Mark Carcinogenicity Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity Skin & Eye Irritant Dermal Sensitizer Acute Toxicity (harmful) Transient Target Organ Effects Harmful to Ozone Layer (Not mandatory) Oxidizers Corrosion Skin Corrosion Corrosive to Metals Serious Damage to Eye Environment (Not mandatory) Environmental Toxicity 34 17 4/17/2013 Shipped Labels 4) Hazard Statements 9 Define: They describe the nature and degree of hazard associated with a particular chemical 9 Harmonized: So chemicals with same hazards, have same base hazard statements 9 May be combined to reduce redundancies and improve readability Example of a hazard statement: “Causes damage to lungs through prolonged or repeated exposure when inhaled into lungs.” 35 Shipped Labels 5) Precautionary Statements 9 Define what they are i.e., They describe what precautionary measures to take when handling or storing a chemical to prevent or minimize adverse effects resulting from exposure 9 4 types 9 Prevention, Response, Storage, and Disposal 9 Statements may be combined to save space and improve readability Most stringent statement placed on label 36 18 4/17/2013 Precautionary Statements Forward slash designates that classifier can choose one of the statements From this: Do not breath dust/fume/gas/mist/vapors/spray. Get medical advice/attention if you feel unwell. To this: Do not breath vapors or spray. Get medical attention if you feel unwell Some statements may be combined 1) “Keep away from heat, spark and open flames.” 2) “Store in a well-ventilated place.” 3) “Keep cool.” “Keep away from heat, sparks and open flames and store in a cool, well-ventilated place.” 37 Shipped Labels Precedence of Hazard Information: C.2.1.1 of the rule says, If the signal word "Danger" is included, the signal word "Warning" shall not appear; C.2.1.2 of the rule says, “If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity” SIGNAL WORD Danger OR Warning, NOT both PICTOGRAMS Skull and Crossbones Acute Toxicity (Fatal or toxic) Exclamation Mark Acute Toxicity (Harmful) Transient Target Organ Effects Skin & Eye Irritant Dermal Sensitizer Harmful to Ozone Layer (Not mandatory) 38 38 19 4/17/2013 Shipped Labels 6) Supplier Information 9 Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party 9 Use to contact responsible party with questions related to the chemical and safety 9 Corresponds with contact information in Section 1 – Identification of the SDS 39 Supplemental Label Information Label producer may provide additional information that it deems helpful” Hazards Not Otherwise Classified (HNOC) PPE pictograms (e.g. HMIS picture of person in goggles) Expiration date, fill date, direction of use 40 20 4/17/2013 Employer Label Responsibilities Employer is not responsible for updating labels on shipped containers, even if the shipped containers are labeled under HazCom 1994 However, if employer becomes aware of newly identified hazards that are not disclosed on the label, the employer must ensure that workers are aware of the hazards 41 Safety Data Sheets Redefined as Safety Data Sheets (SDS) GHS includes 16-part format Essentially the ANSI Standard = Several Sections are not Mandatory Sections 12-15 Ecological information Disposal considerations Transport information Regulatory information Outside of OSHA’s jurisdiction New Appendix D Details what is to be included in each section 42 21 4/17/2013 Safety Data Sheets SDS Training - Examples of what to cover Review the 16 sections 9Heading names 9Specified order 9Type of info found in each section Example: Section 6, Accidental Release Measures Lists emergency procedures; protective equipment; proper methods of containment and cleanup 43 43 Safety Data Sheets 1. Identification 2. Hazard(s) Identification 9. Physical & Chemical Properties 3. Composition/Ingredient Information 10. Stability & Reactivity 4. First-Aid Measures 12. Ecological Information 5. Fire-Fighting Measures 13. Disposal Considerations 6. Accidental Release Measures 14. Transport Information 7. Handling and Storage 16. Other Information 11. Toxicological Information 15. Regulatory Information 8. Exposure Control/ Personal Protection 44 22 4/17/2013 SDS – Sections 1-2 45 Safety Data Sheets 9 Describe how information from the SDS relates to the corresponding Shipped Label Shipped Label 46 46 23 4/17/2013 Safety Data Sheets NOTE: On the SDS, a Pictogram may be represented like: OR OR Skull & Crossbones. 47 47 SDS – Sections 3-5 48 24 4/17/2013 SDS – Sections 6-11 49 SDS – Sections 12-16 50 25 4/17/2013 Safety Data Sheets 9 Describe how information on Labels and SDSs relates to your HazCom program and workplace Product Identifier same in all 3 places Written Plan Chemical Inventory List Shipped Label 51 51 Employer Training Requirements New OSHA Fact Sheet explains the December 1, 2013 Training Requirements Image Source: OSHA website https://www.osha.gov/Publications /OSHA3642.pdf 52 26 4/17/2013 Label Requirements 2 Types of Labels with 2 Different Requirements 1) Shipped Container Labels 2) Workplace Container Labels 53 53 Workplace Labels Requirements for Shipped Label Compliance for Shipped Label is now more prescriptive Requirements for Workplace Label Compliance for Workplace Label is still performance-based 54 54 27 4/17/2013 Workplace Labeling Compliance Training Other Info in Workplace Workplace Label Workplace Label System Provide employees with immediate access to all hazard information about a chemical 55 55 Workplace Labels Effectiveness of Alternative Workplace Label + Training + Other readily available hazard info in the workplace Effectiveness of Shipped Label + Training + Other readily available hazard info in the workplace 56 56 28 4/17/2013 Workplace Labeling Employers Have Four Main Options: 1. Replicate information that is on the manufacturer label 2. Use product identifier and words, pictures, symbols or combination thereof, which + other information immediately available to employee provides specific information regarding hazards 3. Continue to use HazCom 1994 compliant workplace labeling system – so long as employees have information on all health and physical hazards 4. Continue to use NFPA or HMIS systems so long as: • Information is consistent with requirements of HazCom • Employees have immediate access to specific hazard information and fully aware of hazards of chemicals used 57 Workplace Labeling Compliance An OSHA inspector may test for employee comprehension By asking employee look at a container and convey their understanding of the chemical hazards based upon information available as part of the workplace labeling system Employee’s response will dictate whether an employer’s workplace label system is deemed effective 58 58 29 4/17/2013 Workplace Labeling Labels on Incoming Containers Must not be removed or defaced unless immediately replaced Workplace Labels Must be prominently displayed In English Other languages permitted (additionally) Portable containers No label required for portable containers only intended for immediate use by employee who performs the transfer 59 Deadline: June 1, 2015 Manufacturers & Distributors Reclassify chemicals using GHS criteria Produce labels and SDSs in GHS formats Ship updated documents to downstream users with first shipment or next shipment after changes are made Deadline: December 1, 2015 Distributors until this date may ship containers labeled by manufacturer under HazCom 1994 60 30 4/17/2013 Two Most Prevalent Changes OSHA added the definition of Classification to the revised standard: “"Classification" means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section.” 61 Two Most Prevalent Changes 2nd Key Component of the New Definition: “In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards.” 62 31 4/17/2013 UN’s GHS Hazard Classifications Physical Health & Environmental Acute Toxicity Aspiration Toxicity Skin Corrosion/Irritation Serious Eye Damage/Eye Irritation Respiratory or Skin Sensitization Germ Cell Mutagenicity Carcinogenicity Reproductive Toxicity Target Organ Systemic Toxicity – Single and Repeated Dose Hazardous to the Aquatic Environment/Aquatic Toxicity Hazardous to the Ozone Layer Explosives Flammable – Gases, Aerosols Liquids, Solids Oxidizers– liquids, solids, gases Self-Reactive Substances Self-Heating Substances Pyrophoric – liquids, solids Organic Peroxides Corrosive to Metals Gases Under Pressure Water-Activated Flammable Gases 63 HazCom 1994 vs HazCom 2012 HCS/HazCom 1994 Gases Under Pressure Carcinogenicity GHS Alignment/ HazCom 2012 Compressed Gases Refrigerated Gases Liquefied Gases Dissolved Gases Carcinogenicity Category 1 1A = Known 1B = Probable Category 2 Suspected Note the numbering scheme: Lower the #, the more severe the hazard 64 32 4/17/2013 Under New OSHA Definition… OSHA incorporated new elements into its revised definition of Hazardous Chemical To include 3 classes of chemicals defined in its HCS that weren’t in GHS, Rev. 3 “Hazardous Chemical” means any chemical which is classified as a 1) 2) 3) 4) 5) Physical hazard; or Health hazard; or Simple asphyxiant; or Combustible dust; or Pyrophoric gas; or 6) Hazard Not Otherwise Classified (HNOC) 65 3 OSHA Specified Hazards - HazCom 2012 66 33 4/17/2013 HCS / HazCom 2012 Appendices More info on Classification in Appendices: Appendix A: Health Hazard Criteria Appendix B: Physical Hazard Criteria Appendix C: Allocation of Label Elements Appendix D: Safety Data Sheets Appendix E: Definition of "Trade Secret” Appendix F: Guidance for Hazard Classification Regarding Carcinogenicity 67 Classification 68 34 4/17/2013 Classification 69 Classification 70 35 4/17/2013 Classification Differences Hazard Class EU CLP 4th UN GHS US OSHA HCS Physical Hazards FLAMMABLE GASES 1/2 AEROSOLS 1/2/A (unstable gas)/ B (unstable gas) Flammable Aerosols 1/2 FLAMMABLE LIQUIDS 1/2/3 (unflammable aerosols) 1/2/3 1/2/3/4 (US Adopted Cat. 4) Health Hazards ACUTE TOXICITY 1‐4 EYE DAMAGE/IRRITATION TOXIC TO REPRODUCTION 1‐5 1/2A 1/2A/2B 1A/1B/2/ Effects on or via Lactation (Note that the cut‐off value is 0.1% in US, not 0.3% and 3% in EU) Environmental Hazards ACUTE TOXICITY TO THE AQUATIC ENVIRONMENT CHRONIC HAZARD TO THE AQUATIC ENVIRONMENT 1 Not Required 1/2/3 1/2/3/4 Not Required 1/2/3/4 1 Not Required 1 HAZARDOUS TO THE OZONE LAYER Other Hazards OTHER UNIQUE HAZARDS EU Supplementary Hazards: EUH029 Contact with water liberates toxic gas & EUH014 Reacts violently with water, etc. OSHA‐Defined Hazards: Pyrophoric Gas, Simple Asphyxiant, Combustible Dust 71 In-House or Outsource? Should We Author In House? Already Setup Not Currently Setup Is your current software updated to meet GHS criteria? What do we need to do to be set up to author internally? YES NO To‐Do OUCH • Overhead and staffing reqs • Training needs • IT commitments • Can it be updated in time? Cost? • Overhead and staffing reqs • Training needs • IT commitments • Procure software (local or cloud?) • IT commitments for installation • Overhead costs • Training Can be a bigger project than expected! 72 36 4/17/2013 In-House or Outsource? Should We Outsource? What are the considerations when selecting an authoring service provider? a) Capacity b) Desired service level c) Pricing a) b) c) d) Per document + hourly rate Straight hourly rate All inclusive per document rate Project timeline considerations 73 Deadline: June 1, 2016 Employers Must 9 Complete any necessary HazCom program updates, including updates to the written plan and the chemical inventory list Written Plan Chemical Inventory List 9 Update workplace labels as necessary 9 Complete training on any newly identified hazards resulting from manufacturer chemical reclassifications 9 Be using the updated versions of SDSs and labels Labels Training 74 37 4/17/2013 HCS Employer Responsibilities Written HazCom Plan Safety Data Sheets Chemical Inventory Labels & Warning Signs Employee Training 75 General HazCom Training Expectations Employees Trained: On chemicals present in their work areas On location of written HazCom program, list of chemicals, and MSDSs Before working with a hazardous chemical & whenever a new hazard is introduced into their work area On detecting presence/release of a hazardous chemical in the work area On specific chemicals or categories of hazards (e.g., flammability, carcinogenicity) Training must be Effective - Employees must carry the knowledge into their daily jobs 76 38 4/17/2013 Identify Training Needs Task Analysis Who trained on what? Learning outcomes • • • • Recognition Discrimination Understanding Skills Population Considerations Age and length of service Educational level Resource Considerations Budget Location & shift work Language differences 77 Identify Training Needs Task Analysis / What: How many different chemical classes/substances are there in the work areas? Which chemical hazards are involved? How many different job classifications? How many employees in each classification? How often are new processes involving chemical hazards introduced? How often do you expect to receive new MSDSs? Do you have any potentially hazardous chemicals in non-labeled pipes? What General Elements are needed? What site-specific training is needed? What learning outcomes are needed? Information to be made available? Knowledge? Skills? 78 39 4/17/2013 Identify Training Needs Population Considerations / Who: What is the size of the group to be trained on any one topic? How many different groups do you have? What are the average ages of employees within the defined groups? What length of service? What is the rate of turnover (new hires, transfers)? What educational levels? Are there reading or learning difficulties? Are there language differences? How much work experience within groups? Is there any documentation of prior training? 79 Identify Training Needs Resource Considerations / How? What is your budget? Do you have a room large enough to handle your groups? Do you have other options? What assistance will be available? What kinds of audiovisual aids are available? What existing programs might be used? What problems might you have in arranging the training (i.e., scheduling)? How will you handle the training of shift workers? 80 40 4/17/2013 Setting Training Objectives 1. Observable: Employees must be able to demonstrate learning 2. Measurable: Objectives should define acceptable performance 3. Performance Conditions Stated: Conditions under which the individual will demonstrate competence 81 Setting Training Objectives Good Examples: • Given an MSDS, employee will correctly locate at least three pieces of designated information • Employee will list correctly the three steps to take in reporting a leak or spill Bad Example • Worker will understand the hazards of chemicals with which he or she works 82 41 4/17/2013 Documenting Training There is no requirement to document training, but it makes sense to maintain records Recording class attendance is not enough; document what you set out to teach and how well you achieved it. OSHA recommends: 1. 2. 3. 4. Date of presentation Learning objectives Training program outline Names of participants, with an identifier such as Social Security number 5. Names of instructors 6. Data, such as test results, to demonstrate that objectives were met Paper copies of training records are hard to maintain, consider inexpensive and user-friendly software. 83 Documenting Training Retraining OSHA has no specific retraining requirement Retrain when employees are no longer retaining their hazard communication knowledge and skills You don’t have to repeat the entire hazard communication training program if you can document that some or most knowledge and skill concepts have been retained 84 42 4/17/2013 14 Steps Towards Employer Compliance 85 Employer Compliance Tasks 1. Designate GHS Transition Leader 2. Get Educated on GHS 3. Inventory Chemicals (Physical Inventory) 4. Check Inventory Against Safety Data Sheet Library 5. Acquire Missing MSDSs 6. Safely Dispose of Chemicals No Longer in Use/Needed 7. Archive MSDSs No Longer Used 8. Train Employees on GHS Label Elements and SDS Format 9. Prepare for SDS Churn a) Look for new hazards on incoming safety data sheets 10. Get Secondary Container Labeling Strategy 11. Train Employees On Any New Hazards 12. Update Written HazCom Program 13. Meet SARA / EPCRA Reporting Obligations 14. Stay Current on GHS 86 43 4/17/2013 GHS Alignment Timeline http://www.msdsonline.com/ blog/ghs-compliancechecklist/ 87 Penalties for Noncompliance Are Very Real From 2009 – 2012 OSHA cited over 24,000 instances of HCS violations in workplaces across the United States #2 on OSHA’s top 10 list of most frequently cited compliance standards for 2012 Source: www.OSHA.gov 88 44 4/17/2013 Costs Add Up Quickly Fines Potential Risk & Liability Downtime & Internal Disruption Lost Revenues Negative Press & Impact to Corporate Image 89 Electronic Management OSHA’s provisions for electronic MSDS management and deployment, haven’t changed Electronic systems are still permitted under HazCom 2012, so long as there is: 9 No barrier preventing employee access to the SDSs, 9 A compliant back-up system is in place for retrieving SDSs during foreseeable emergencies like power-outages, 9 Hard copies of SDSs can be provided upon request Employers want to be sure they understand how their electronic system will go about handling the MSDS to SDS document churn Still OK 90 90 45 4/17/2013 Links to GHS Info http://www.MSDSonline.com http://www,MSDSonline.com/blog/ghs-answer-center/ http://www.MSDSonline.com/blog/ghs-101-links-to-useful-ghsinformation/ 91 Questions 1.888.362.2007 www.MSDSonline.com [email protected] [email protected] 92 46 4/17/2013 Disclaimers *This webinar is designed to provide accurate and authoritative information about the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional services. *This webinar provides general information only and does not constitute legal advice. No attorney-client relationship has been created. If legal advice or other expert assistance is required, the services of a competent professional should be sought. We recommend that you consult with qualified local counsel familiar with your specific situation before taking any action. 47 Speaker Biography BRAD HARBAUGH BRAD HARBAUGH IS EDITOR OF THE ENVIRONMENTAL HEALTH AND SAFETY BLOG FOR MSDSONLINE — A LEADING PROVIDER OF COSTEFFECTIVE, CLOUD-BASED COMPLIANCE SOLUTIONS THAT HELP BUSINESSES MANAGE A VARIETY OF GLOBAL ENVIRONMENTAL, HEALTH & SAFETY (EH&S) REGULATORY COMPLIANCE REQUIREMENTS. IN ADDITION TO RESEARCHING AND REPORTING ON CURRENT EH&S ISSUES, BRAD IS THE CREATOR OF MSDSONLINE’S POPULAR GHS ANSWER CENTER AND GHS WEBINAR SERIES.
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