HAZ COM-How to Prepare
for the 2013 Deadline and
Other Critical FAQs
Presented by:
Brad Harbaugh
MSDSONLINE
Tuesday, April 23, 2013
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12:30 p.m. to 2:00 p.m. Central
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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
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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
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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
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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
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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
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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.
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Why Train on GHS?
Do you know what these
pictograms mean?
13
Why Train on GHS?
14
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Why Train on GHS?
Oxidizers
15
Why Train on GHS?
16
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Why Train on GHS?
Environmental
Toxicity
17
Why Train on GHS?
18
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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SDS – Sections 6-11
49
SDS – Sections 12-16
50
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Classification
69
Classification
70
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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
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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
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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
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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?
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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?
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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
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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
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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
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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
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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
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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]
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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.
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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.