Controls and Labeling

The Hazard Communication Standard

The GHS Process

If you are exposed to hazardous chemicals at work, OSHA's Hazard Communication Standard (29 CFR 1910.1200) will help you identity the hazards of those materials and how to use them safely. Your employer must also teach you about the protective measures when working with hazardous chemicals. When you have this important information, you'll be able to take steps to protect yourself from the negative effects caused by accidental exposure.

OSHA's Hazard Communication Standard (HCS) requires employers and manufacturers to develop and distribute chemical information as described below:

• Chemical manufacturers and importers must classify 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.
• Employers with classified hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train workers to safely handle those chemicals.

As mentioned above, the standard requires your employer to provide information to employees about the hazardous chemicals to which they are exposed, by means of:

1. a hazard communication program,
2. labels and other forms of warning,
3. safety data sheets, and
4. information and training.

Employers who do not produce or import chemicals need only focus on those parts of this rule that deal with establishing a workplace program and communicating information to their workers.

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Global Harmonization

The UNECE "Purple Book"

The new HCS 2012 is now aligned with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) that provides many benefits, including:

• Providing a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets;
• Improving the quality and consistency of hazard information in the workplace;
• Helping reduce trade barriers;
• Productivity improvements for American businesses that regularly handle, store, and use classified hazardous chemicals;
• Providing cost savings for American businesses that periodically update safety data sheets and labels for classified chemicals.

Historical note: The old HCS 1994 gave workers the right to know, but the new HCS 2012 gives workers the right to understand: this is a very important change in OSHA's approach.

Hazardous Substances and Chemicals

Chemical manufacturers and importers must evaluate chemicals.

OSHA has defined the term "substances" as chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition.

For the purposes of the HCS, a hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

Physical hazards - a chemical that is classified as posing one of the following hazardous effects:

• explosive
• flammable (gases, aerosols, liquids, or solids)
• oxidizer (liquid, solid or gas)
• self-reactive; pyrophoric (liquid or solid)
• self-heating
• organic peroxide
• corrosive to metal
• gas under pressure or
• in contact with water emits flammable gas

See Appendix B to 1910.1200 -- Physical Hazard Criteria.

Health hazard - a chemical which is classified as posing one of the following hazardous effects:

• acute toxicity (any route of exposure)
• skin corrosion or irritation
• serious eye damage or eye irritation
• respiratory or skin sensitization
• germ cell mutagenicity
• carcinogenicity
• reproductive toxicity
• specific target organ toxicity (single or repeated exposure) or
• aspiration hazard

The criteria for determining whether a chemical is classified as a health hazard are detailed in 1910.1200, Appendix A - Health Hazard Criteria.

Hazardous mists produce vapors when spray painting.

Forms of Hazardous Chemicals

You might think that the chemicals which apply to the rule are those in liquid, gas or particulate form. But, the standard's definition of "chemical" is much broader than that commonly used. According to the HCS, chemicals that apply may exist in one of many forms:

Dusts - are finely divided particles. Example - wood dust.

Fumes - are even smaller particles usually formed when solid metal is heated and vaporized, and then condenses as tiny particles.

Fibers - are similar to dusts but are of an elongated shape. Examples - asbestos and fiberglass.

Mists - are liquid droplets that have been sprayed into the atmosphere.

Vapors - are gases formed when liquid evaporates.

Gases - are substances that are normally airborne at room temperature. A vapor is the gaseous phase of a substance which is a normally a liquid or solid at room temperature.

Solids - such as metal, treated wood, plastic.

Liquids - the most common form in the workplace.

Chemical Effects

The effects chemicals have on the various organs of the human body depend on several important factors:

1. The form of the chemical: Is the chemical a solid, liquid, or gas?
2. The route of entry, or how the chemical contacts the body: is it ingested, inhaled, absorbed or injected?
3. The dose, or amount, the body receives: How much chemical makes its way into the body?
4. The toxicity: How poisonous is the chemical?

Routes of Entry

Another important task when assessing the workplace for chemical hazards is to determine the route(s) of entry the chemicals may take. If we know the route(s) of entry, we can then determine appropriate engineering, administrative, and PPE controls to eliminate or reduce the exposure. The four common routes of entry are:

1. Ingestion: Do we eat or drink it?
2. Inhalation: Do we breathe it in? This is the most common route of entry.
3. Absorption: Does it pass through the skin, eyes or other membranes?
4. Injection: Does it enter through a puncture or cut?

Chemical Hazard Control Strategies

Hazardous substances can be used safely in workplaces if adequate control strategies are used to prevent exposure to those chemicals. To eliminate or reduce exposure to hazardous chemicals, an effective protocol called the "Hierarchy of Controls" has been developed. When you determine during a workplace assessment that exposure to harmful levels of hazardous chemicals is present, try to eliminate or reduce that exposure using the following strategies in the following order:

The first three strategies focus on doing something with the hazard.

1. Elimination: The best solution is to totally eliminate hazardous substances in the workplace.
2. Substitution: Substitution is the next-best solution. Replace a toxic substance with a less-toxic substance. If you can't get rid of the toxic substances, you may be able to replace them with substances that are at least less toxic.
3. Engineering Controls: Redesign or modify processes that use toxic chemicals to eliminate or reduce exposure to the chemical hazard itself.

The last two strategies focus on doing something with behaviors to reduce exposure to the hazard.

4. Administrative Controls: Change work procedures to reduce the duration, frequency, and severity of exposure to the chemical hazard. The chemical hazard is not eliminated or reduced using this strategy. The primary focus is to incorporate safer work practices through written safety policies, rules, supervision and training. And that's a problem because you may have to regularly supervise employees as they perform a task. These controls work only so long as employees "behave" properly.
5. Personal Protective Equipment (PPE): The use of PPE is probably the most common strategy, and mandatory when working with hazardous chemicals. PPE forms a barrier between worker and hazard. Once again, the chemical hazard is neither eliminated nor reduced, and a high reliance is placed on appropriate use of PPE for this strategy to be successful.

Remember, the first question you want to ask is, "How can I eliminate, reduce, or engineer out the hazard?" Hopefully you'll be able to eliminate the hazard or reduce it to the point where safe behaviors or PPE won't be necessary.

Types of Containers and Labels

Shipped/Primary Containers

Container labeling can be a very effective method to communicate the physical and health hazards of chemicals used in the workplace. The information on a container label will vary depending on what type of container it is and how it is used. We will discuss labeling requirements under the HCS 2012 labeling requirements in this section.

We'll take a look at the labeling requirements for each of the four types of containers listed below:

• Shipped/Primary containers
• Workplace/Secondary containers
• Stationary containers
• Portable containers

Check out this short audio clip by Dan Clark of the theSafetyBrief.com that discusses important questions about the new labeling requirements.

To learn more about the four types of container labels and associated requirements, download the OSHA Brief, Hazard Communication Standard: Labels and Pictograms.

Shipped - Primary Container Label Requirements

Sample GHS Label

Under the new HCS 2012, labels on containers shipped from manufacturers or distributors must be labeled, tagged or marked with the following six items:

1. Product Identifier - This should include the chemical identity of the substance.
2. Signal word - Signal words used in GHS are "Danger" and "Warning." Danger is for the more severe hazard categories.
3. Hazard Statements - This is a phrase assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, and the degree of the hazard.
4. Pictograms - These include symbols plus other elements, such as a border, background pattern or color that conveys specific information.
5. Precautionary statements - These are phrases (and/or pictograms) that describe the recommended measures to minimize or prevent adverse effects resulting from exposure to a hazardous product.
6. Supplier identification - This contains the name, address, and telephone number of the manufacturer or supplier of the substance or mixture.

Workplace or Secondary Container Labeling

Most employers use the primary containers they purchase to store and use chemicals. However, they may also use their own containers such as coffee cans, drums, plastic jugs, spray bottles, etc. to store and use smaller quantities of chemicals they purchase. These are called workplace or secondary containers.

Make sure your secondary containers are properly labeled, not only to protect employees, but to avoid OSHA citations. One of the most frequent citations related to HCS 2012 is "improperly labeled secondary containers." OSHA sees this all of the time, and whatever OSHA sees the most, they cite the most. Remember that.

The employer must ensure that each workplace or secondary container of hazardous chemicals in the workplace is labeled, tagged or marked with either:

• The information required on shipped container labels; or,
• Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and specific information regarding the physical and health hazards of the hazardous chemical.

Portable Container Labeling

It is important to know portable containers must be under the positive control of the employee using it. If the employee walks away from the container and loses control of the chemical, it must be labeled as a workplace/secondary container.

Portable containers are used to transfer hazardous chemicals from labeled containers, and are intended only for the immediate use of the employee who performs the transfer. The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.

Drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.

Labeling Solid Materials

Railroad ties - good example of solid materials needing an SDS

For solid metal (such as a steel beam or a metal casting), solid wood, or plastic items that are not exempted as articles due to their downstream use, or shipments of whole grain, the required label may be transmitted to the customer at the time of the initial shipment, and need not be included with subsequent shipments to the same employer unless the information on the label changes.

For example, treated lumber is covered since the lumber is not completely cured at the time of shipment and the hazardous chemical will, to a varying degree, offgas during shipment and be available for exposure to employees. Railroad ties treated with creosote should have an accompanying safety data sheet (SDS) when shipped.

HCS 2012 Pictogram Requirements

The HCS 2012 requires GHS 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(s). The pictogram on the label is determined by the chemical hazard classification.

HCS Pictograms and Hazards

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Video

This Lab Safety Institute video gives a brief overview of the new GHS regulations and how these changes will impact HAZCOM in the USA and WHMIS in Canada.