GHS and its new Language Skills, but they are still Chemicals!

OHS Law Enforcement in North America is knocking and they may be closer than you think! OSHA has cited over 42,000 instances of HazCom violations in workplaces across the United States. In 2016, HazCom moved up from the #3 spot to #2 on OSHA's most frequently cited standards list (behind only fall protection).

And in Canada, WHMIS penalties of up to $1 million in fines and two years in prison will remain a serious consideration for anyone with obligations under Canada’s hazard communication standard. The goal of GHS is to apply the same set of rules for classifying hazards, and the same format and content for labels and safety data sheets (SDS). The SDS and label must be delivered to the end user in the country’s national language.

The new GHS system gave us;

• Hazard classification
• Labels
• Safety Data Sheets
• Information and training

Remember under GHS, Chemical will now be Substance

– Chemical Name will now be Chemical Identity

– Health Hazard will be broken into ? Hazard Class (e.g. flammable, corrosive, etc.) ? Hazard Category – Division of the Hazard Class (e.g. acute oral toxicity)

– Hazard Warning will be changed to: ? Hazards Statement

– Describes the nature of the hazard ? Pictogram – A composition intended to convey specific information.

• Employees must be trained on the GHS-aligned SDS format, and retrained whenever information is no longer retained.
• Each GHS-aligned safety data sheet must include Sections 12 through 15, though OSHA in the USA will not enforce the content covered within them, since it applies to areas outside of its jurisdiction.
• NFPA and HMIS? information is still permitted on SDSs, but it is not — and was never — required.

The main elements of the hazard classification criteria are summarized below:

• Physical
• Health
• Environmental (not mandatory in the USA)
• Hazards Not Otherwise Classified (USA only)

And yes of course:

– Labels will have much more information to assist in identifying hazards. Product identifier; Signal word; Hazard statement(s); Pictogram(s); Precautionary statement(s); and, Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

And 3 key options for workplace labels

Other label requirements include:

• Must be labeled in the official language where the product is being placed on the market.
• Additional information may be required on the label based on local regulations of end user’s country.

It is important to note that the GHS pictograms do not replace the diamond shaped labels that the US Department of Transportation (DOT) of Canada TDG requires for transport. 

Two simple words with GREAT meaning;

? Use of Danger and Warning. – Danger is used for more sever hazards

·        Warning is used for for less sever hazards – Some substances that have lower level hazards will not have a signal word.

When Teaching GHS remember it’s a SYSTEM not a Law ( each country makes it a law)

GHS is not a law unto itself; rather it is a system with components countries can adopt into their own systems. In other words, HCS remains the law in the U.S., and WHMIS2015 will continue to be the law in Canada; however, their alignment with GHS changes both HCS and WHMIS in ways that have significant consequences for chemical manufacturers and employers in both countries.

In Canada and the USA DOT and GHS are getting to the same page

The Occupational Safety and Health Administration (OSHA) and Pipeline and Hazardous Materials Safety Administration (PHMSA) — a Department of Transportation (DOT) agency that develops regulations for the safe transport of hazardous materials — issued a joint memorandum on September 19, 2016 to clarify each agencies’ requirements for labels on bulk hazardous material shipments.

The main thrust is that HCS-compliant labels and DOT-required labels can be on the same immediate container with no conflicts.

More specifically, the memorandum clarifies that:

• PHMSA labeling requirements are contained in the U.S. Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) and apply to transportation of hazardous materials in commerce. During transportation, the HMR governs hazard communication labeling requirements.
• OSHA’s HCS 2012 requires labeling of immediate containers of hazardous chemicals in the workplace, both before and after transportation in commerce.
• OSHA's HCS 2012 labeling is not required on outer shipping containers in transport, even when DOT's HMR does not require labeling in transportation.
• The HCS requires communication of hazards for chemicals in bulk DOT shipping containers (e.g., tanker trucks, railcars, etc.) when these containers are also the immediate containers of the chemical by either labeling them with hazard information in the form of an OSHA shipped label, or transmitting the required OSHA shipped labels along with shipping papers, bills of lading or through an electronic means, in such a way they are immediately available in printed form to workers on the receiving end of a shipment.
• Section 49 CFR § 172.401(b) of the HMR states that any markings or labels that could be confused or conflict with HMR requirements are prohibited, but 49 CFR § 172.401(c) of the rule also states that this prohibition does not apply to packages labeled in conformance with certain international standards, including the UN Globally Harmonized System of Classification and Labelling of Chemicals (i.e., GHS as implemented by OSHA). As such, this memo clarifies and confirms that it is acceptable for bulk packages or containers to include both a DOT HMR label or marking and an OSHA GHS-aligned HCS label.

DID YOU COVER do STAFF understand the H an P Codes on the new system by the numbers!

H-200 PHYSICAL HAZARDS H200 Unstable Explosive H201 Explosive; mass explosion hazard. H202 Explosive; severe projection hazard. H203 Explosive; fi re, blast or projection hazard. H204 Fire or projection hazard. H205 May mass explode in fi re. H220 Extremely fl ammable gas. H221 Flammable gas. H222 Extremely fl ammable aerosol. H223 Flammable aerosol. H224 Extremely fl ammable liquid and vapour. H225 Highly Flammable liquid and vapour. H226 Flammable liquid and vapour. H228 Flammable solid. H240 Heating may cause an explosion. H241 Heating may cause a fi re or explosion. H242 Heating may cause a fi re. H250 Catches fi re spontaneously if exposed to air. H251 Self-heating; may catch fi re. H252 Self-heating in large quantities; may catch fi re. H260 In contact with water releases fl ammable gases which may ignite spontaneously. H261 In contact with water releases fl ammable gas . H270 May cause or intensify fi re; oxidizer. H271 May cause fi re or explosion; strong oxidiser. H272 May intensify fi re; oxidizer. H280 Contains gas under pressure; may explode if heated. H281 Contains refrigerated gas; may cause cryogenic burns or injury. H290 May be corrosive to metals. H-300 HEALTH HAZARDS H300 Fatal if swallowed. H301 Toxic if swalloed. H302 Harmful if swallowed. H304 May be fatal if swallowed and enters airways. H305 May be fatal if swallowed and enters airways. H310 Fatal in contact with skin. H311 Toxic in contact with skin H312 Harmful in contact with skin. H314 Causes severe skin burns and eye damage. H315 Causes skin irritation. H317 May cause an allergic skin reaction. H318 Causes serious eye damage. H319 Causes serious eye irritation. H330 Fatal if inhaled. H331 Toxic if inhaled. H332 Harmful if inhaled. H334 May cause allergy or asthma symptoms or breathing diffi culties if inhaled. H335 May cause respiratory irritation. H336 May cause drowsiness or dizziness. H340 May cause genetic defects. H341 Suspected of causing genetic defects. H350 May cause cancer. H350i May cause cancer by inhalation. H351 Suspected of causing cancer. H360 May damage fertility or the unborn child. H360F May damage fertility. H360D May damage the unborn child. H360FD May damage fertility. May damage the unborn child. H360Fd May damage fertility.Suspected of damaging unborn child. H360Df May damage the unborn child.Suspected of damaging fertility. H361 Suspected of damaging fertility or the unborn child. H361f Suspected of damaging fertility. H361d Suspected of damaging the unborn child. H361fd Suspected of damaging fertility.Suspected of damaging the unborn child. H362 May cause harm to breast-fed children. H370 Causes damage to organs. H371 May cause damage to organs. H372 Causes damage to organs through prolonged or repeated exposure. H373 Causes damage to organs through prolonged or repeated exposure. H-400 ENVIRONMENTAL HAZARDS H400 Very toxic to aquatic life. H410 Very toxic to aquatic life with long lasting eff ects. H411 Toxic to aquatic life with long lasting eff ects. H412 Harmful to aquatic life with long lasting eff ects. H413 May cause long lasting harmful eff ects to aquatic life. H420 Harms public health and the environment by destroying ozone in the upper atmosphere. COMBINATION OF H-CODES H300 + H310 Fatal if swallowed or in contact with skin. H300 + H330 Fatal if swallowed or if inhaled. H310 + H330 Fatal in contact with skin or if inhaled H300 + H310 + H330 Fatal if swallowed, in contact with skin or if inhaled. H301 +H311 Toxic if swallowed or in contact with skin. H301 +H311 Toxic if swallowed or if inhaled. H311 + H331 Toxic in contact with skin or if inhaled. H301 + H311 + H331 Toxic if swallowed, in contact with skin or if inhaled. H302 +H312 Harmful if swallowed or in contact with skin. H312 + H332 Harmful in contact with skin or if inhaled. H302 + H312 + H332 Harmful if swallowed, in contact with skin or if inhaled. ADDITIONAL HAZARD STATEMENTS EUH001 Explosive when dry. EUH006 Explosive with or without contact with air. EUH014 Reacts violently with water. EUH018 In use may form fl ammable/explosive vapour-air mixture. EUH019 May form explosive peroxides. EUH029 Contact with water liberates toxic gas. EUH031 Contact with acids liberates toxic gas. EUH032 Contact with acids liberates very toxic gas. EUH044 Risk of explosion if heated under confi nement. EUH059 Hazardous to the ozone layer. EUH066 Repeated exposure may cause skin dryness or cracking EUH070 Toxic by eye contact. EUH071 Corrosive to the respiratory tract. Contains lead. Should not be used on surfaces liable to the chewed or sucked by children. Warning! Contains lead. EUH202 Cyanoacrylate. Danger. Bonds skin and eyes in seconds. Keep out of the reach of children. EUH203 Contains chromium (VI). May produce an allergic reaction. EHU204 Contains isocyanates. May produce an allergic reaction. EUH205 Contains epoxy constituents. May produce an allergic reaction. EUH206 Warning! Do not use together with other products. May release gangerous gases (chlorine). EUH207 Warning! Contains cadmium. Dangerous fumes are formed dur- ing use. See information supplied by the manufacturer. EUH208 Contains . May produce an al- lergic reaction. Can become highly fl ammable in use. Can become fl ammable in use. EUH210 Safety data sheet available on request. EUH401 To avoid risks to human health and the environment, comply with the instructionsfor use. P-100 GENERAL P101 If medical advice is needed,have product container or label at hand. P102 Keep out of reach of children. P103 Read label before use. P-200 PREVENTION P201 Obtain special instructions before use. P202 Do not handle until all safety precautions have been read and un- derstood. P210 Keep away from heat/sparks/open fl ames/hot surfaces. — No smoking. P211 Do not spray on an open fl ame or other ignition source. P220 Keep/Store away from clothing/…/combustible materials. P221 Take any precaution to avoid mixing with combustibles/… P222 Do not allow contact with air. P223 Keep away from any possible contact with water, because of vio- lent reaction and possible fl ash fi re. P230 Keep wetted with … P231 Handle under inert gas. P232 Protect from moisture. P233 Keep container tightly closed. P234 Keep only in original container. P235 Keep cool. P240 Ground/bond container and receiving equipment. P241 Use explosion-proof electrical/ventilating/lighting/…/equipment. P242 Use only non-sparking tools. P243 Take precautionary measures against static discharge. P244 Keep reduction valves free from grease and oil. P250 Do not subject to grinding/shock/…/friction. P251 Pressurized container: Do not pierce or burn, even after use. P260 Do not breathe dust/fume/gas/mist/vapours/spray. P261 Avoid breathing dust/fume/gas/mist/vapours/spray. P262 Do not get in eyes, on skin, or on clothing. P263 Avoid contact during pregnancy/while nursing. P264 Wash hands thoroughly after handling. P264 Wash skin thouroughly after handling. P270 Do not eat, drink or smoke when using this product. P271 Use only outdoors or in a well-ventilated area. P272 Contaminated work clothing should not be allowed out of the workplace. P273 Avoid release to the environment. P280 Wear protective gloves/protective clothing/eye protection/face protection. P281 Use personal protective equipment as required. P282 Wear cold insulating gloves/face shield/eye protection. P283 Wear fi re/fl ame resistant/retardant clothing. P284 Wear respiratory protection. P285 In case of inadequate ventilation wear respiratory protection. P231 + P232 Handle under inert gas. Protect from moisture. P235 + P410 Keep cool. Protect from sunlight. P-300 RESPONSE P301 IF SWALLOWED P302 IF ON SKIN P303 IF ON SKIN (or hair) P304 IF INHALED P305 IF IN EYES P306 IF ON CLOTHING P307 IF exposed P308 IF exposed or concerned P309 IF exposed or if you feel unwell P310 Immediately call a POISON CENTER or doctor/physician. P311 Call a POISON CENTER or doctor/physician. P312 Call a POISON CENTER or doctor/physician if you feel unwell. P313 Get medical advice/attention. P314 Get medical advice/attention if you feel unwell. P315 Get immediate medical advice/attention. P320 Specifi c treatment is urgent (see … on this label). P321 Specifi c treatment (see … on this label). P322 Specifi c measures (see …on this label). P330 Rinse mouth. P331 Do NOT induce vomiting. P332 IF SKIN irritation occurs: P333 If skin irritation or rash occurs: P334 Immerse in cool water/wrap n wet bandages. P335 Brush off loose particles from skin. P336 Thaw frosted parts with lukewarm water. Do not rub aff ected area. P337 If eye irritation persists: P338 Remove contact lenses, if present and easy to do. Continue rinsing. P340 Remove victim to fresh air and keep at rest in a position comfort- able for breathing. P341 If breathing is diffi cult, remove victim to fresh air and keep at rest in a position comfortable for breathing. P342 If experiencing respiratory symptoms: P350 Gently wash with plenty of soap and water. P351 Rinse cautiously with water for several minutes. P352 Wash with plenty of soap and water. P353 Rinse skin with water/shower. P360 Rinse immediately contaminated clothing and skin with plenty of water before removing clothes. P361 Remove/Take off immediately all contaminated clothing. P362 Take off contaminated clothing and wash before reuse. P363 Wash contaminated clothing before reuse. P370 In case of fi re: P371 In case of major fi re and large quantities: P372 Explosion risk in case of fi re. P373 DO NOT fi ght fi re when fi re reaches explosives. P374 Fight fi re with normal precautions from a reasonable distance. P376 Stop leak if safe to do so. Oxidising gases (section 2.4) 1 P377 Leaking gas fi re: Do not extinguish, unless leak can be stopped safely. P378 Use … for extinction. P380 Evacuate area. P381 Eliminate all ignition sources if safe to do so. P390 Absorb spillage to prevent material damage. P391 Collect spillage. Hazardous to the aquatic environment P301 + P310 IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician. P301 + P312 IF SWALLOWED: call a POISON CENTER or doctor/physician IF you feel unwell. P301 + P330 + P331 IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. P302 + P334 IF ON SKIN: Immerse in cool water/wrap in wet bandages. P302 + P350 IF ON SKIN: Gently wash with plenty of soap and water. P302 + P352 IF ON SKIN: wash with plenty of soap and water. P303 + P361 + P353 IF ON SKIN (or hair): Remove/Take off Immediately all contaminated clothing. Rinse SKIN with water/shower. P304 + P312 IF INHALED: Call a POISON CENTER or doctor/physician if you feel unwell. P304 + P340 IF INHALED: Remove victim to fresh air and Keep at rest in a position comfortable for breathing. P304 + P341 IF INHALED: If breathing is diffi cult, remove victim to fresh air and keep at rest in a position comfortable for breathing. P305 + P351 + P338 IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. P306 + P360 IF ON CLOTHING: Rinse Immediately contaminated CLOTHING and SKIN with plenty of water before removing clothes. P307 + P311 IF exposed: call a POISON CENTER or doctor/physician. P308 + P313 IF exposed or concerned: Get medical advice/attention. P309 + P311 IF exposed or if you feel unwell: call a POISON CENTER or doctor/ physician. P332 + P313 IF SKIN irritation occurs: Get medical advice/attention. P333 + P313 IF SKIN irritation or rash occurs: Get medical advice/attention. P335 + P334 Brush off loose particles from skin. Immerse in cool water/wrap in wet bandages. P337 + P313 IF eye irritation persists: Get medical advice/attention. P342 + P311 IF experiencing respiratory symptoms: call a POISON CENTER or doctor/physician. P370 + P376 In case of fi re: Stop leak if safe to Do so. P370 + P378 In case of fi re: Use … for extinction. P370 + P380 In case of fi re: Evacuate area. P370 + P380 + P375 In case of fi re: Evacuate area. Fight fi re remotely due to the risk of explosion. P371 + P380 + P375 In case of major fi re and large quantities: Evacuate area. Fight fi re remotely due to the risk of explosion. P-400 STORAGE P401 Store … P402 Store in a dry place. P403 Store in a well-ventilated place. P404 Store in a closed container. P405 Store locked up. P406 Store in corrosive resistant/… container with a resistant inner liner. P407 Maintain air gap between stacks/pallets. P410 Protect from sunlight. P411 Store at temperatures not P412 Do not expose to temperatures exceeding 50 °C/ 122 °F. P413 Store bulk masses greater than … kg/…lbs at temperatures not exceeding … °C/…°F. P420 Store away from other materials. P422 Store contents under … P402 + P404 Store in a dry place. Store in a closed container. P403 + P233 Store in a well-ventilated place. Keep container tightly closed. P403 + P235 Store in a well-ventilated place. Keep cool. P410 + P403 Protect from sunlight. Store in a well-ventilated place. P410 + P412 Protect from sunlight. Do not expose to temperatures exceeding 50 °C/122 °F. P411 + P235 Store at temperatures not exceeding … °C/…°F. Keep cool. P-500 DISPOSAL P501 Dispose of contents/container to..… P502 Refer to manufacturer/supplier for information on recovery/ recycling

And to to be undone the EU Codes

Explosive when dry EUH001 Explosive with or without contact with air EUH006 Reacts violently with water EUH014 In use may form fl ammable/explosive vapour-air mixture EUH018 May form explosive peroxides EUH019 Contact with water liberates toxic gas EUH029 Contact with acids liberates toxic gas EUH031 Contact with acids liberates very toxic gas EUH032 Risk of explosion if heated under confi nement EUH044 Hazardous to the ozone layer EUH059 Repeated exposure may cause skin dryness or cracking EUH066 Toxic by eye contact EUH070 Contains lead. Should not be used on surfaces liable to the chewed or sucked by children. Warning! Contains lead. EUH201/ 201A Contains chromium (VI). May produce an allergic reaction. EUH203 Contains isocyanates. May produce an allergic reaction. EHU204 Contains epoxy constituents. May produce an allergic reaction. EUH205 Warning! Do not use together with other products. May release dangerous gases (chlorine). EUH206 Warning! Contains cadmium. Dangerous fumes are formed during use. See information supplied by the manufacturer EUH207 Contains . May produce an allergic reaction. EUH208 Can become highly flammable in use. Can become flammable in use. EUH209/ 209A Safety data sheet available on request EUH210 To avoid risks to human health and the environment, comply with the instructions for use. EUH401