Category: GHS

GHS Is Closer Than You Think

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As you most likely recall, on December 1 of 2013, companies in the U.S. were required to provide employees with training on how to read and understand the Globally Harmonized Standards (GHS) labels and Safety Data Sheets (SDS). Since then you may or may not have begun to see these labels and SDS arriving with the chemical shipments you receive. If you haven’t seen them yet, you will soon.

Beginning on June 1 of this year, all chemical manufacturers will be required to use the GHS labelling and provide the new format SDS. This also applies to chemical importers. Chemical distributors will be required to use the GHS labelling and documentation beginning December 1 of this year.

In June of 2016, OSHA is scheduled to update requirements for alternative workplace labelling, which could result in additional requirements.

Now would be a good time to refresh your GHS training. As workers begin seeing the labels and SDS, it’s critical that you ensure they know what they’re looking at. During this transition time your employees’ ability to understand and interpret the SDS and label information is essential to chemical safety.

Training needs to be far more extensive than simply handing them a copy of the SDS or a chart of GHS symbols in hopes of them figuring it out. The SDS is an extremely technical document that may not be easy to comprehend.

Workers need to know that GHS pictograms can have different meanings depending on the combinations in which they are used. Employees need to know what signal words, hazard statements, and precautionary statements mean to them.

To keep up with the United Nations (UN) GHS changes, OSHA is expected to consider adopting additional UN-GHS changes every two years. More UN-GHS standards will likely be incorporated into the Hazard Communication System during the phase-in period, and beyond.

Now that Canada has begun to incorporate GHS into its WHMIS program, these same GHS requirements being implemented in the U.S. will come into effect in Canada over the next three years.
Before actively starting a new or refresher training program, you should take a close look at the material you’re using to make sure it provides the necessary information in a way workers can understand.

If you’re not certain it does, our GHS HAZCOM training kit is designed to meet those needs. Good training and sound procedures can protect the environment and reduce accidents among workers responding to chemical hazards.

OSHA Definition of a HNOC Clarified For The HCS

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On March 4, 2014 OSHA released an open letter to the American Petroleum Institute clarifying how they interpret the Hazard Communication Standard (HCS) regarding Hazards Not Otherwise Classified (HNOC).


From the official definition, a HNOC is a negative physical or health effect that doesn’t fit the HCS categories.

A negative effect has to occur from workplace exposure to a chemical causing material health impairment or functioning. Employees must be free from negative effects even if regularly exposed to the chemical.

The criteria for classifying a negative health effect is the weight of evidence as described in Appendix A. All available information will be considered together using expert judgment. Also important is the quality of the data, with a precedence on good quality human data, routes of exposure, and positive and negative results.


If there is a physical or health hazard that fits the HCS category, but is less than the stated cut-off value or concentration it is not a HNOC.

Also categories of GHS Hazards not adopted by OSHA – like acute toxicity – are also not an HNOC.

Furthermore, OSHA considers “physical effect” in the definition to be impairment of health or function caused by a chemical’s hazards in normal conditions or foreseeable emergencies. This means scalds by an exposure to chemicals at high temperature or slipping on a spilled liquid chemical does not make those hazards a HNOC.

For example, OSHA does not consider water a HNOC because an employee may be scalded by boiling water, get hypothermia from being in cold water, slip in a puddle, or be knocked down by water sprayed at high pressure.

A HNOC is also not a pyrophoric gas, simple asphyxiate or combustible dust because they have intentionally been added to the “hazard chemical” definition.

HNOC Labelling Requirements

There are no Safety Data Sheet (SDS) label requirements for a HNOC, and such information does not have to be physically separate, but must not cause confusion with the required information.

On the label, the only two signal words that may be used are “danger” and “warning” and the correct signal word for a HNOC must be used.

Because a HNOC is determined through the hazard classification process, that information can be included under the required sections.

2014 Interpretations

In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules. Here is what has been released in 2014:

  • Construction’s Electrical Power Regulations Final Rule
  • Cranes and Derricks Near Power Lines
  • Recordkeeping for Multiple Business Establishments
  • How to Decide It’s a Workplace Injury
  • Safety Data Sheet (SDS) Reporting of Petroleum Streams
  • Combustible Dust Labeling Requirements in Hazard Communication Standard (HCS)
  • OSHA Definition of A HNOC Clarified for the HCS
  • General Duty Clause Covers All Impalement Hazards
  • Employer Responsible for Determining Qualified Rigger Status

OSHA Interprets Safety Data Sheet (SDS) Reporting of Petroleum Streams

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On March 4, 2014, OSHA released a new interpretation further refining guidance of applying the 2012 Hazard Communication Standard (HCS). This time the topic was how to apply the classification and Safety Data Sheet (SDS) requirements to petroleum streams.

The problem is the contents of petroleum streams – which includes anything coming from crude oil that is either a well-defined chemical compound (butane or propane) or a substance with unknown or variable parts, complex reaction products or defined biological material – can’t be described by fixed percentages or molecular formulas because what is in them either changes or are unknown.

Therefore applying the SDS disclosure requirements to petroleum streams the same way they are done to known substances is infeasible and the following guidelines need to be followed.

  1. Provide the concentrations of groups of toxicologically similar chemicals. If it is better to treat a set of constituents as a group, and all of the toxicologically useful information can be conveyed that way, the SDS only has to have the name and concentration of the group. For example, provide the total concentration of a class of constituents like polycyclic aromatic hydrocarbons (PAH) instead of the concentration of individual PAH’s.
  2. Other chemicals known to be in the stream with classified health hazards must be listed individually in section 3 with their concentrations above the exposure limit.
  3. Where there is reliable and good information that an element of the petroleum stream poses no health risk in downstream use, it doesn’t need to be on the SDS.
  4. Concentration ranges, based on the information available (analysis result, product specifications, nature of the process) will be used when the exact concentration of a chemical or group isn’t known.  The high end of the range must not change the hazard classification.

2014 Interpretations

In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules. Here is what has been released in 2014:

  • Construction’s Electrical Power Regulations Final Rule
  • Cranes and Derricks Near Power Lines
  • Recordkeeping for Multiple Business Establishments
  • How to Decide It’s a Workplace Injury
  • Safety Data Sheet (SDS) Reporting of Petroleum Streams
  • Combustible Dust Labeling Requirements in Hazard Communication Standard (HCS)
  • OSHA Definition of A HNOC Clarified for the HCS
  • General Duty Clause Covers All Impalement Hazards
  • Employer Responsible for Determining Qualified Rigger Status

2013 Interpretations of OSHA Regulations

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Even while creating new regulations and amending current ones to fit the workplace’s changing safety standards, OSHA is hard at work providing guidance material to help employers follow their rules, and answering questions and providing guidance on existing rules.

These are known as interpretations, and 2013 saw several interesting interpretations, mostly on the new elements of the Hazard Communication Standard (HCS) such as: combustible dust, labeling small containers, safety data sheets (SDS), and hazards not otherwise classified (HNOC).

But questions in other fields were answered, like: fall protection, temporary workers, excavation shield walls, employee representatives, and pressure relief devices.

This article will provide a summary of OSHA more consequential interpretations for the previous year.

December 27, 2013
1910.1200 Hazard Communication Standard (HCS) inspection guidance for Combustible Dust
Guidance for OSHA inspectors when inspecting manufacturers and importers to determine whether they are in compliance with the requirements for combustible dust – 1910.1200(d) – until OSHA addresses the issues in its rules.
Because the Globally Harmonized Systems for Classification and Labelling of Chemicals (GHS) does not address combustible dust hazards, OSHA is currently relying on its previous guidance on combustible dust including the Combustible Dust National Emphasis Program (NEP) with an operative definition and existing voluntary standards like from the National Fire Protection Association (NFPA).
The NEP defines combustible dust as a solid combustible material, made of distinct pieces, that “presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations, regardless of particle size or shape.”
Inspectors will determine how classifiers have handled the available evidence about a product’s explosibility. Where there is evidence that a product was involved in a deflagration or dust explosion, it should be classified as a combustible dust. Where tests have been done, the dust should be classified by the results. In the absence of these, rely on information about similar materials or particle size to determine the combustible dust hazard.

September 3, 2013
1926.501 Construction Fall Protection requirements with a 32 in. high barrier wall
Question. What kind of fall protection is needed for workers walking along bridge decks when the finished edges have a 32 in. high barrier wall?
Answer. A 32 in. high concrete barrier doesn’t comply with minimum top edge requirement of a guardrail system to be 42 in. (plus or minus 3 in.) Possible systems include a fabricated wood rail, and a c-clamp guardrail system. A warning line system may also be used, as long as there is a 15 ft. restricted area from the warning line and the edge.

June 4, 2013
1926.1200 Hazard Communication Standard (HCS) labeling of small containers
Q. The small vials shipped are too small to put all the required label information on them, are any of the following situations viable:
• Put a key on the product that references the required information.
• Apply the Department of Transportation (DOT) exceptions for small quantities.
• Apply the European Classification, Labelling and Packaging (CLP) regulation exceptions.
A. The HCS does not allow any of the possible solutions, but possible labeling solutions can include pull-out or fold back labels, or tags. Where the manufacturer can show it is not feasible to use pull-out or fold back labels or tags the shipped small container must have at least: product identifier, appropriate pictograms, manufacturer’s name and phone number, signal word and a statement that the full label information is on the outside package.
The outside package then must: have all necessary label elements, inform users that the small container must be stored in the outer container, and maintain a label on the outer package.
The outside package must not cause a hazard by storing the material.

May 2, 2013
1926.562 Excavations Protective Systems engineer designed requirements
Q. Does a registered professional engineer have to follow the sloping and benching requirements?
A. The engineer’s designs must be written and include the magintued of the slopes determined and the configurations that were determined to be safe, but there are no specific restrictions to maximum allowed slopes or configurations.
OSHA is not going to approve or endorse a specific plan, but warns that working conditions and changing or incorrectly applying equipment, service or system can easily create a hazardous condition.

April 29, 2013
Guidance for OSHA inspectors when encountering temporary workers exposed to a hazardous condition.
Because of a series of increased reports of temporary workers suffering fatal injuries during the first days on a job, OSHA instructed its regional administrators to have their investigators to determine if the employees they encounter in an investigation are temporary workers, if they are exposed to a violative condition, and through records and interviews, whether those workers have the required training in a language they can understand.
There is a new OSHA form field for temporary workers that inspectors will enter when they have determined temporary employees are exposed to a violative condition. The inspectors are also to document the name of the temporary workers’ staffing agency, the agency’s location, and who is supervising the temporary workers each day.
OSHA acknowledges that a temporary worker is broadly defined as anybody paid by a temporary help agency, whether or not their job is temporary.

March 25, 2013
1910.1200 Hazard Communication Standard (HCS) for Combustible Dust
Q. For chemicals that pose a combustible dust hazard when process but not in the current form it is shipped in, can additional hazard statements be included?
A. Additional information may be provided on a label: “when it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information”

March 11, 2013
1926.652 Excavations Requirements for Protective Systems on allowable gap between trench shield and trench sides.
Q. Can OSHA make a guideline provided by trench shield manufacturers to have no more than a 12 in. gap for both sides of the trench shield, an allowable gap requirement of no more than 3-6 in. on each side of the trench shield?
A. The OSHA regulation’s standard requires trench shields to restrict lateral or other hazardous movement and recognizes that the closer the trench shield is to the trench side, the less likely it is to move. But OSHA is unlikely to initiate the rulemaking needed to require a minimum gap.

February 21, 2013
1903.8 Representatives of employers and employees
Q. May workers designate someone with a union without a collective bargaining agreement at their workplace, or with a community organizations act as their personal representative for OSHA.
A. Yes, OSHA recognizes the role of “employee representative” who may represent employees’ interest.
Q. Can workers without a collective bargaining agreement designate a person with a union or community organization act as a representative during the walkaround portion of an inspection?
A. Yes, employees have the right to the representative they have chosen a representative. Inspectors do have some discretion to who participates in workplace inspections in order to allow OSHA to effectively conduct its investigations.

February 4, 2013
1910.119 Process safety management of highly hazardous chemicals training of mechanics repairing pressure relief devices
Q. Are mechanics required to be initially trained for Pressure Relief Devices (PRD)? Do maintenance personnel need refresher training every three years? Do you have to follow the equipment manufacturers training recommendations? Does maintenance have to be trained on new equipment?
A. The employer must train each employee involved in maintaining equipment integrity, but there isn’t a recurring training requirement or an obligation the follow the manufacturer’s recommendations. And maintenance personnel must be able to maintain the integrity of process equipment with applicable maintenance procedures.
Q. Do maintenance personnel have to be involved in the process hazard analysis (PSA)?
A. The PHA must be performed by a team with expertise in engineering and process operations, including at least one employee who has experience and knowledge specific to the process being evaluated. This does not specifically require a maintenance person, unless the employer’s written plan of action regarding employee participation by maintenance personnel on a facility’s PHA team.

January 13, 2013
1910.1200 Hazard Communication Standard (HCS) clarification on labeling and SDS requirements
Q. Do I need to create the new format Safety Data Sheets (SDS) for hazardous chemicals from manufacturers or importers who have gone out of business.
A. The employer’s responsibility is to maintain the previous format Material Safety Data Sheet (MSDS). OSHA isn’t going to cite companies for maintaining MSDSs for products received before June 1, 2015.
But because companies need to maintain the most recently received version , replace the most current SDS for the previous MSDS. Any product receive after June 1, 2015, must be shipped with an SDS, and when received, the new SDS must be maintained.
An employer may request a SDS from manufacturers or distributers, and they must comply.
When an employer maintains MSDS and SDS, employees need to be trained to understand both formats, including the potential differences between the two.

Q. Does supplemental information on a label, like environmental hazard or a Hazard Not Otherwise Classified (HNOC) need to be physically separated from the harmonized information?
A. The HCS does not say how the label must be formatted, so supplemental information does not need to be physically separate, as long as it isn’t confused with the required information.

Q. Is it possible to include signal words on the SDS and label for an HNOC?
A. There are no label requirements for HNOCs, and the only two signal words that may appear on the label are “danger” and “warning”, and only one may be used, so when “danger” appears “warning” cannot. The correct signal word for HNOCs must appear on the SDS.

Q. Can you include hazard symbols on the SDS and label for an HNOC?
A. There are eight pictograms that must be used depending on the classification of the hazardous chemical, but the manufacturer may add additional labels to the SDS as long as the symbol is not an HCS pictogram and doesn’t contradict required information.

Q. Can HNOCs be included with other classifications, or do they need their own subheader?
A. HNOCs are identified through the hazard classification process, so you can include HNOC information under the required subheads.

#2 Hazard Communication: Understanding Top OSHA Violations of 2013

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Already the second most cited violation in 2013 with 6,156 instances, The General Industry Hazard Communication (1910.1200) standard, has only become more complicated with a December 1st, 2013 deadline requiring employers to train employees on the new label elements and safety data sheet (SDS) format.

To make it easy, employees need to know:

  1. The type of information on the new labels
  2. How to use the labels in the workplace
  3. How the elements work together on a label
  4. The format of the new Safety Data Sheets (SDS)
  5. How the label information is related to the SDS

1. Label elements

Employees will see the following elements on the new labels.

Product Identifier – This can be the chemical name, code number or batch number.

Signal Word – Indicates the severity of the hazard. Within a hazard class “Danger” is for more severe hazards and “Warning” is for less severe. Regardless of how many hazards a chemical may have, if one warrants a “Danger” warning then it will be used on the label.

Pictogram – Know what hazards the following pictograms represent

Health HazardHealth Hazard – carcinogen, mutagenicity, reproductive toxicity, respiratory sensitizer, target organ toxicity, aspiration toxicity


FlameFlame – flammables, pyrophorics, self-heating, emits flammable gas, self-reactives, organic peroxides


Exclamation MarkExclamation Mark – irritant (skin and eye), skin sensitizer, acute toxicity (harmful), narcotic effects, respiratory tract irritant, hazardous to ozone layer (non-mandatory


Gas CylinderGas Cylinder – gases under pressure


CorrosionCorrosion – skin corrosion/burns, eye damage, corrosive to metal.


Exploding BombExploding bomb – explosives, self-reactives, organic peroxides


Flame Over CircleFlame Over Circle – oxidizers


EnvironmentEnvironment – aquatic toxicity


Skull and CrossbonesSkull and Crossbones – acute toxicity (fatal or toxic)


Hazard Statements – Describe the nature and degree of the hazard. All applicable hazard statements will appear on the label, specific to the hazard classification category and users will see the same statement for the same hazards regardless of the chemical or who produces it.

Precautionary Statement – Phrases describing recommended measures to minimize or prevent effects of exposure, improper storage or handling.

Supplier Information – Name, address and phone number of the chemical manufacturer, distributor, or importer.

2. Using the labels

The information on the labels will show employees the proper way to use and store the hazardous chemical, and how to quickly locate first aid information for emergency personnel.

3. How the elements work together

A chemical with multiple hazards will have all of the necessary pictograms for the corresponding hazard class. Also when there could be similar precautionary statements, the one providing the most information will be on the label.

4. Safety Data Sheets (SDS)

Material Safety Data Sheets (MSDS), which could be in hundreds of different formats depending on the whim of the manufacturer are out, and Safety Data Sheets (SDS) with a standardized 16-section format, are in.

By June 1, 2015, all SDSs will adhere to the following sections:

  1. Identification – Product identifier; manufacturer or distributor name, address, phone number, emergency phone number; recommended use; restrictions on use.
  2. Hazard Identification – All hazards regarding the chemical; required label elements.
  3. Composition/Information on Ingredients – Information on chemical ingredients, trade secret claims.
  4. First-Aid Measures – Important symptoms / effects, acute, delayed; required treatments.
  5. Fire-Fighting Measures – Suitable extinguishing techniques, equipment; chemical hazards from fire.
  6. Accidental Release Measures – Emergency procedures; protective equipment; proper methods of containment and cleanup.
  7. Handling and Storage – Precautions for safe handling and storage, including incompatibilities.
  8. Exposure Controls / Personal Protection – OSHA’s Permissible Exposure Limits (PEL); Threshold Limit Values (TLV); appropriate engineering controls; personal protective equipment (PPE).
  9. Physical and Chemical Properties – The chemical’s characteristics.
  10. Stability and Reactivity – Chemical stability and possibility of hazardous reactions.
  11. Toxicological Information – Routes of exposure; related symptoms, acute and chronic effects; numerical measures of Toxicity.
  12. Ecological Information – Environmental impact; organism toxicity results; environmental persistence; bioaccumulation potential. Not regulated or enforced by OSHA.
  13. Disposal Considerations – Proper disposal, recycling, reclamation. Not regulated or enforced by OSHA.
  14. Transport Information – UN number; UN proper shipping name; transport hazard classes; environmental hazard; bulk transportation; special precautions. Not regulated or enforced by OSHA.
  15. Regulatory Information – Additional safety, health, and environmental regulations. Not regulated or enforced by OSHA.
  16. Other Information – Date of preparation or last revision.

5. Label and SDS Similarities

Employees need to know how the label information is related to information on the SDS.

Precautionary statements are the same. The same product identifier is on the label and in Section 1 of the SDS (Identification).

Use a hazardous chemical in your workplace that employees may be exposed to and go over its label and SDS to find the similarities and what they mean to your workplace.

Hazardous Communication Training Kit

The Hazardous Communication Training Kit, available from Safety Services Company, provides detailed information on the new and existing requirements including: safety data sheets, policy creation, physical hazards, Global Harmonized System (GHS), chronic effects, spills, and leaks.

Top 10 OSHA Violations Examined

Check with us every Wednesday for the rest of the year as we understand the Top 10 OSHA Violations for 2013. Next week’s topic is construction’s scaffolding regulation (1926.451).

1. Fall Protection (1926.501) – October 23

2. Hazard Communication (1910.1200) – October 30

3. Scaffolding (1926.451) – November 6

4. Respiratory Protection (1910.134) – November 13

5. Electrical, Wiring (1910.305) – November 20

6. Powered Industrial Trucks (1910.178) – November 27

7. Ladders (1926.1053) – December 4

8. Lockout / Tagout (1910.147) – December 18

9. Electrical, General (1910.303) – January 8

10. Machine Guarding (1910.212) – January 15

What You Need To Teach Your Employees by December about GHS changes to Hazard Communication Standard


You have until December 1, 2013 to show that you have trained your employees to understand the new Globally Harmonized System (GHS) of chemical labels, pictograms and Safety Data Sheets (SDS).

This is true if you are an employer that uses handles or stores chemicals that subject you to the OSHA Hazard Communication Standard. So if your workplace includes hazardous chemical warning labels or Material Safety Data Sheets (MSDS), please read on to find out what your employees need to know so that you meet the first deadline.

The information in this article will educate you on what is different with this new GHS rule you may have heard about, that you need to ensure your employees understand. Take the lessons and examples provided and combine them with the real life examples of the chemicals your employees work with to point out the differences between the old labels and sheets and the new and make sure your employees know how to be safe with the chemicals they work with.

Jay Acker

Jay Acker is a technical writer who creates material for conducting safety meetings, safety training programs, posters and other items.  Safety School is a twice monthly exploration into the next level of workplace safety, regulatory compliance and best practices for your business. The curriculum is wide ranging so check back with us on Wednesdays ready to take notes and ask questions.


According to the OSHA Fact Sheet of the Hazard Communication Standard Final Rule which came into effect May 25, 2012: “The Hazard Communication Standard in 1983 gave the workers the ‘right to know,’ but the new Globally Harmonized System gives workers the ‘right to understand.’”

The requirement for employers to train employees on the new label elements and SDS format by December 1, 2013 is the first deadline.

The second deadline requires chemical manufacturers, importers, distributers and employers to comply with all modified provisions of the final rule 29 CFR 1910.1200, by June 1 2015. Distributers may still ship products with old labels made by manufacturers until December 1, 2015.

And ultimately by June 1, 2016, all employers need to update to the new workplace labeling and hazard communication program.

What’s New in Your Hazardous Chemicals Training Requirements

The changes to the training element of your standard Hazard Communication Program (HCP) brought about by the GHS, that we will be covering today, include:

  • Standardized content of formatting of Safety Data Sheets (SDS).
  • Changes to the hazard categories of hazardous chemicals
  • Hazardous chemical label elements
  • New pictograms, new and different signal words, hazard statements and precautionary statements.

What’s Not New in Training

This update means a different, standardized way of presenting important safety information about the chemicals you work with. These changes don’t mean an overhaul in the HCP training requirements. Your company’s training program needs to include these same topics that it always had.

  • The requirements of regulatory bodies, industry standards and best safety practices regarding hazardous chemicals.
  • Operations in the employee’s work areas that involve hazardous chemicals.
  • The availability and location of the written HCP, list of hazardous chemicals, and safety data sheets (SDSs).
  • Labeling systems and the meanings of the elements of hazardous material labels.
  • How to detect the presence or release of a hazardous chemical in the work area.
  • The classified and unclassified hazards of chemicals in the work area.
  • Steps employees can take to protect themselves, including procedures you have implemented in both regular operations and emergencies.
  • HCP details, including an explanation of all labels and SDS, and how employees can obtain and use the appropriate hazard information.

Put the Training in Writing

Safety Services Company recommends keeping a record of all training sessions to demonstrate compliance with employer responsibilities, show a commitment to safety in the workplace and create accountability for employees to follow their responsibility of understanding the hazards of the chemicals in their workplace and following safety policy adhering to all precautions and safety requirements.

Make sure your training records include: the dates of the training sessions; contents or a summary of the material; names and qualifications of persons conducting the training; names of all persons attending the training sessions.

Keep all employee training for at least three years.

Specific Criteria to Hazard Statements

One of the major changes: Requiring chemical manufacturers and importers to determine the hazards based on updated standard to provide specific criteria to address health and physical hazards.

Unless your business is one of those manufacturers creating chemicals or bringing them into the country, you won’t be making the designations, but you need to know that the Hazard Statement(s) on a GHS Label has a specific meaning that corresponds with the new pictograms.

And your employees need to know what each hazard statement phrase means, and how it affects their safety.

For example the pictograph (or symbol) of a fire is a physical hazard designated Flame that encompasses the following hazard statements: Flammables, Emits Flammable Gas, Self-Reactive, Pyrophorics, Organic Peroxides, and Self-Healing.

Acetone is a popular solvent in general use and industries like laboratories and medicine. The SDS of acetone has the flame and exclamation mark pictogram and the GHS hazard statements: Highly flammable liquid and vapor; Causes serious eye Irritation; May cause drowsiness or dizziness.

According to the GHS standard, acetone is a flammable liquid because it has a flash point of not more than 93CC (199.4°F). And because it has a flash point of -17°C it ranks as a category 1 flammable liquid, or “highly flammable”. The eye irritation and drowsiness hazard statements further describe the exclamation mark pictogram since it symbolizes skin & eye irritation and narcotic effects like drowsiness and dizziness.

This infographic shows the new GHS pictograms, what they represent and some specific hazard statements associated with them. Also note that they are broken up into physical, health and environmental hazards.

GHS Hazard Pictograms 791x1024 What You Need To Teach Your Employees by December about GHS changes to Hazard Communication Standard

Label elements

The GHS does not specify a label format our layout, but requires the inclusion of several elements.

1. Product Identifier. The product identifier must match the identifier on the safety data sheet and include the chemical identity of the substance or ingredients in a mixture that contribute to the product’s hazards.

2. Pictograms. Pictograms are combinations of graphical elements that convey information about the product’s hazards. GHS hazard pictograms are a black symbol on a white field within a red diamond.

3. Signal Word. Signal words indicate the severity of the product’s hazard. “Danger” indicates severe hazards while “Warning” indicates less sever hazards.

4. Hazard Statements. Hazard statements are assigned based on the nature of the product’s hazards.

5. Precautionary Statements. Precautionary statements inform the reader about how to prevent or minimize the negative effects of storing or handling the product unsafely. They fall into four categories: prevention, response, storage, and disposal.

6. Supplier Identification. The supplier identification includes the name, address and telephone number that can be used to locate or communicate with the manufacturer or supplier.

Other Elements. GHS permits competent authorities to require or allow additional information and specify where it must be presented on the product label as long as it does not impede, contradict or confuse the standard information. Examples include: transport pictograms, precautionary pictograms, first-aid recommendations, universal product codes, general usage information, etc.

GHS Label Elements cropped 1024x863 What You Need To Teach Your Employees by December about GHS changes to Hazard Communication Standard


Safety Data Sheets (SDS)

Those different types of sheets that you get with incoming shipments of hazardous chemicals with information about the chemical, are getting a facelift with 16 standardized sections that must be addressed.

You may have known them as Material Safety Data Sheets (MSDS), but they are now known as Safety Data Sheets (SDS), and regardless of where they come from will have the following sections.

  • Identification
  • Hazard(s) identification
  • Composition / information on ingredients
  • First-aid measures
  • Fire-fighting measures
  • Accidental release measures
  • Handling and storage
  • Exposure controls/personal protection
  • Physical and chemical properties
  • Stability and reactivity
  • Toxicological information
  • Ecological information
  • Disposal considerations
  • Transport information
  • Regulatory information
  • Other information including last revision

The new category Section 12, Ecological information covers the following information: ecotoxicity, either aquatic or terrestrial; persistence and degradability; bioaccumulative potential; mobility in soil; other adverse effects.

Section 13, Disposal considerations covers a description of waste residues and information on their safe handling and methods of disposal, including any contaminated packaging.

Section 14, Transport information covers: United Nations number and proper shipping name; Transport Hazard class(es); packing group; marine pollutant capabilities; special transport or conveyance precautions.

Section 15, Regulatory information covers: Safety, health and environmental regulations for the specific product.

Changes to GHS Looming

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The Occupational Safety and Health Administration is considering possible modifications to the recently adopted Globally Harmonized System (GHS) of Classification and Labeling of Chemicals after the United Nations made revisions to the universal standard in December.

The major change in the revision requires chemical manufactures to include language on new risks created when products are altered in the safety data sheet.

Other changers are minor corrections in verbiage or expanding descriptions to improve clarity and facilitate the adoption of the GHS by multiple countries.

According to Maureen Ruskin, director of the Office of Chemical Hazards-Metals OSHA’s Directorate of Standards and Guidance, the editorial changes to sections on physical, environmental, and health hazards stood out the most. Those amendments included revisions to language on mixtures and eye irritants.

OSHA does not have a clear timetable for its consideration of the U.N. changes, spokeswoman Diana Petterson told BNA.

OSHA issued its final rule its new Hazard Communication Standard, featuring the implementation of the Globally Harmonized System (GHS), on March 26, 2012.

The standard was based on the third edition of the United Nation’s Purple Book, which outlines the requirements of the GHS. The recently adopted changes will be released in the fifth edition of the book.

The U.N. Subcommittee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals meets twice a year in Geneva, with the next meeting scheduled for July, to discuss changes to the standard.

Below are the OSHA deadlines for GHS adoption.

Important deadline of the standard implementation include:

December 1, 2013

All employers that use, handle, store chemicals

Train employees about the new chemical labels and safety data sheets or SDSs (formally material safety data sheets or MSDSs).

June 1, 2015

Chemical manufacturers, importers, distributors

Must comply with all the requirements of the GHS rule, except voluntary compliance with GHS label until December 1, 2015.

December 1, 2015

Chemical manufacturers, importers, distributors

All shipments of chemical containers must include the GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement).

June 1, 2016

All employers that use, handle, store chemicals

Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

The final rule revising the standard is available at*.

Illinois Gym Dinged by OSHA

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The U.S. Department of Labor’s Occupational Health and Safety Division (OSHA) is proposing more than $60,000 in fines against a fitness club in Illinois for failing to protect workers from hazardous chemicals.

The fines come after OSHA found four repeat safety violations at the Xsport Fitness facility in Libertyville, Illinois. Those violations were for failing to provide eye, face and hand protection for workers using liquid and other hazardous chemicals.

Labor department spokesman Scott Allen said Capital Fitness Inc., the Libertyville facility’s parent, had 15 business days to respond after receiving the complaint Dec. 21.

“We’re still waiting to hear from the company if they want to do an informal conference or contest it,” Allen said.

In addition to the repeat offenses OSHA cited the gym for not having a hazardous communication program and a failure to have material safety data sheets for chemicals onsite. Des Plaines-based OSHA area director Diane Turek was critical of XSport in a statement issued Monday.

“XSport Fitness has a responsibility to know the hazards that exist in their workplace and to provide employees with appropriate personal protective equipment,” Turek said. “Employers who are cited for repeat violations demonstrate a lack of commitment to employee safety and health.”

CDC: Language barrier contributed to chlorine leak at chicken plant

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In a report released Friday, the Centers for Disease Control discusses their findings in a chlorine gas release that occurred at a Tyson chicken processing plant in Springdale, Ark., last summer. The gas release that left nearly 200 sickened resulted from a worker pouring bleach into a barrel that still contained the acidic residue from an antimicrobial solution.

The CDC asserts the unnamed worker “who inadvertently mixed the two solutions indicated that the drum was labeled in English but he could only read Spanish.”

The CDC report finds that Spanish was the primary language for 68% of the workers it interviewed who were at the plant on the day of the accident, and 12% spoke primarily Marshallese.

Tyson — the largest meat producer in the world — refutes the claim that the language barrier led to the emergency that required an evacuation of all 600 workers at the plant and sent 152 to the hospital. In a press release, the company asserts “the worker responsible is not Hispanic and his primary language is English.”

A spokeperson told the Associated Press that Tyson believes the worker simply failed to look at the label on the drum before mixing the two chemicals.

OSHA’s hazard communication standard, recently updated to align with the UN Globally Harmonized System of Classification and Labelling of Chemicals (29 CFR 1910.1200) no longer specifically requires training appropriate to the language and education level of employees, as is the case for some other standards.

However, the standard does require employers to “provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area,” and an earlier memo from OSHA reminds employers of the expectation that information will be tailored to employees’ language and educational level.

In their press release, Tyson defends their training system: “While we do have a diverse workforce at this plant, we work hard to communicate with our team members, providing interpreters for those who may not be fluent in English.”

Chemical Exposure First Aid the Easy Way

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Demystifying Chemical Inhalation First Aid 

Each year, hundreds of thousands of workers are exposed to hazardous materials in the workplace. To protect these workers, government safety regulators require employers to train their employees on chemical inhalation first aid. Regardless of the amount of training your employees receive, at some point, an accident will happen. To help ensure their preparedness we assembled the standard treatments for different types of chemical exposure.

a) Skin Splashes

  • Remove contaminated clothing.
  • Flush skin with water for at least 10 minutes.
  • Seek medical treatment.

b) Eye Splashes

  • Flush the eyes with water for several minutes.
  • After the eyes have been rinsed, ask the employee to close both eyes and cover  the eyes with a clean cloth.
  • Seek medical treatment.

c) Inhalation of vapors or gasses

  • Remove affected person to safe area.
  • Apply CPR if breathing has stopped.
  • Send for immediate medical help.

d) Ingestion

  • Wash mouth with water.
  • Do not induce vomiting.
  • Call 911 or send to hospital.

e) First and second degree burns

Unless the SDS indicates otherwise, flush the injured area with gently running water for at least 15 minutes. If larger area, immerse the burned area in cold water or apply ice packs to the affected area.

If available, wrap the burn with Water Jel or place burn gell on the burn. Do not apply butter, oil, or cream to a burn. Cover the burned area with a clean cloth. Seek medi­cal attention. Treat the employee for shock, if necessary.

Remember before handling a chemical your employees need to read the SDS sheet of each chemical to beware of the particular first aid procedures. In all cases when a patient is transported to hospital give the SDS sheet of contaminating chemical to medical personnel.

Call (888) 247-6132 today to speak with one of our safety solutions experts.