SIX OF THESE THINGS ARE KIND OF THE SAME

January 27,2015 HAZMAT ROB

I always tell my seminar attendees, the key to any regulation is the section or paragraph that covers the regulation’s definitions. This is especially true when preparing the New OSHA GHS safety data sheets and GHS container labels for your hazardous chemicals. Without the definitions, it would be impossible to explain how similar the mandatory information on the SDS and label is, using 1910.1200 Appendix C when formatting and preparing Section 1 Identification and Section 2 Hazard(s) Identification. 29 CFR Section 1910.1200(f) Labels mandates the use of the 6-part container labels, 2 parts of which are chemical specific statements and 4 parts are mandatory phraseology statements outlined in Appendix C. Appendix D of 1910.1200 mandates the required SDS information and format. It is the similarity between Sections 1 and 2 of the SDS and the container labels that I want to discuss. But first, what is a container, a label or even a hazard class under 1910.1200?

GHS OSHA CONTAINER

In 1910.1200(c) OSHA defines Container as any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of Section 1910.1200, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers.

Hazard category means the division of criteria within each hazard class, e.g., oral acute toxicity and flammable liquids include four hazard categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally.

Hazard class means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity.

Health hazard means 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 Appendix A to §1910.1200—Health Hazard Criteria

Physical hazard means 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.

Label means an appropriate group of written, printed or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.

GHS 6-PART LABELS

Label Elements means the: Product identifier Signal word Hazard statement Specified pictogram Precautionary statement for each hazard class and category, and Name, telephone number and address.

6-PART LABEL GHS HAZARD COMMUNICATION CONTAINER INFORMATION

.The GHS container labels and Sections 1 and 2 of the SDS must both include: The CHEMICAL SPECIFIC Product identifier. Product identifier means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. (See label and SDS Section 1 heading (a) below) The MANDATORY PHRASEOLOGY (App C) Signal word. Signal word means a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in Section 1910.1200 are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for the less severe. (See label and SDS Section 2 heading (b) below) The MANDATORY PHRASEOLOGY (App C) Hazard statement(s). Hazard statement means a statement assigned to a hazard class. Hazard class means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity) in Appendix A to §1910.1200 Health Hazard Criteria. See Appendix B to §1910.1200—Physical Hazard Criteria) (See label and SDS Section 2 heading (b) below) The MANDATORY PHRASEOLOGY (App C) Pictograms. Pictogram means a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category. (See label and SDS Section 2 heading (b) below) The MANDATORY PHRASEOLOGY (App C) Precautionary statement(s). Precautionary statement (Prevention, Response, Storage, Disposal) means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. (See label and SDS Section 2 heading (b) below) The CHEMICAL SPECIFIC Responsible party Information for the chemical manufacturer, importer, or other responsible party. This includes name, address, and telephone number. (See label and SDS Section 2 heading (b) below)

GHS LABEL = SDS SECTIONS 1 AND 2

.Now if you check out the mandatory chemical specific and mandatory phraseology from Appendix C on the container label, you will see that it is the same mandatory information in Section 1 and 2 of the SDS.

SDS SECTION 1 INFORMATION and 2 HAZARD(s) IN APPENDIX C

1. Identification Product identifier used on the label (1910.1200(f)(1)(i) same as container label) Other means of identification Recommended use of the chemical and restrictions on use Name, address, and telephone number of the chemical manufacturer, importer, or other esponsible party (1910.1200(f)(1)(vi) same as container label) Emergency phone number ( 1910.1200(f)(1)(vi) same as container label) 2. Hazard(s) Identification Classification of the chemical in accordance with paragraph (d) of §1910.1200 Signal word, hazard statement(s), symbol(s) and precautionary statement(s) in accordance with paragraph (f) of §1910.1200. (Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol, e.g., flame, skull and crossbones) (1910.1200(f)(1)(ii)(iii) same as container label) Describe any hazards not otherwise classified that have been identified during the classification process. Where an ingredient with unknown acute toxicity is used in a mixture at a concentration ≥1% and the mixture is not classified based on testing of the mixture as a whole, a statement that X% of the mixture consists of ingredient(s) of unknown acute toxicity is required

HEART CENTER SOUL

The chemical specific and mandatory phraseology information on the container label and Sections 1 and 2 on the SDS would have to be the heart, center, soul and the starting point of the GHS Hazard Communication Regulations. You should start with the mandatory information that must be displayed on the container labels, which is the same chemical specific and mandatory phraseology from Appendix C required on the SDS in Section 1 Identification and Section 2 Hazard(s) Identification, that will lay down the foundation for the SDS.

GHS CONTAINER LABEL

DANGER Highly flammable liquid & vapor  Causes severe eye irritation  May cause drowsiness or dizziness  Flammable Liquid Category 2  Eye Irritant Category 2A  Specific Target Organ Toxicity (Single Exposure)  Category 3 Precautionary statements Prevention Keep away from heat/sparks/open flames/hot surfaces – No smoking. Keep containers tightly closed. Use only non-sparking tools. Take precautionary measures against static discharge. Wear protective gloves/eye protection/face protection. Wash hands thoroughly after handling. Avoid breathing dust/fume/gas/mist/vapors/spray. Use only outdoors or in a well-ventilated area. Response If on skin (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower. In case of fire: Use carbon dioxide, dry chemical powder or foam to extinguish. If in eyes, rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: Get medical advice/attention. If inhaled: Remove person to fresh air and keep comfortable for breathing. Call a poison center/doctor if you feel unwell. Storage Store in a well-ventilated place. Keep cool. Keep container tightly closed. Store locked up. Disposal Dispose of contents/containers in accordance with the EPA CFR Part 260 Hazardous Waste Management System or in accordance with local, regional, national, and international regulations. ABC Corp., 555 Main St., Anytown, PA 19530, (555) 555-1212 *Hazard classification/category information not mandatory

GHS SAFETY DATA SHEET (SDS) ACETONE SECTION 1 IDENTIFICATION a) Acetone b) 2-Propanone, dimethyl ketone, ketone propane c) Parts cleaning, laboratory reagent, cleaning solvent d) ABC Corp. 555 Main Street Anytown, Pa 19530 Office Telephone 555-555-5556 email: abcchemical@cmail.com Emergency Telephone; 555-555-5555  24-hr/day and 7 days/week SECTION 2 DANGER DANGER HAZARD(S) IDENTIFICATION FLAMMABLE LIQUID CATEGORY 2 EYE IRRITATION CATEGORY 2A SPECIFIC TARGET ORGAN TOXICITY SINGLE EXPOSURE CATEGORY 3 HIGHLY FLAMMABLE LIQUID AND VAPOR CAUSES SERIOUS EYE IRRITATION MAY CAUSE DROWSINESS OR DIZZINESS i) Prevention Keep away from heat/sparks/open flames/hot surfaces – No smoking. Keep containers tightly closed. Use only non-sparking tools. Take precautionary measures against static discharge. Wear protective gloves/eye protection/face protection. Wash hands thoroughly after handling. Avoid breathing dust/fume/gas/mist/vapors/spray. Use only outdoors or in a well-ventilated area. ii) Response If on skin (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower. In case of fire: Use carbon dioxide, dry chemical powder or foam to extinguish. If in eyes, rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: Get medical advice/attention. If inhaled: Remove person to fresh air and keep comfortable for breathing. Call a poison center/doctor if you feel unwell. iii) Storage Store in a well-ventilated place. Keep cool. Keep container tightly closed. Store locked up. iv) Disposal Dispose of contents/containers in accordance with the EPA CFR Part 260 Hazardous Waste Management System or in accordance with local, regional, national, and international regulations. Other hazards: Not Available Acute toxicity: Not Available

Sections 1 and 2 of the SDS display the same chemical specific and mandatory phraseology information that must be on the container labels, and the container labels must display the same information mandatory phraseology as in in Section 1 and 2 on the SDS. All the additional information in Sections 3 through 16 on your SDS can be extracted off your old MSDSs using any appropriate non-mandatory terminology AFTER determining the mandatory phraseology statements in Sections 1 and 2. Having trouble with your GHS compliance? Give us a call if you need some help finding the required information before the compliance date of June 1, 2015. Or sign up for one of my upcoming seminars. If you bring some of your SDSs and labels, I can take a look and tell you what I think. Thank you for your readership and support.