Introduction to GHS with Envirox slide

1. The New Hazard Communication Standard
Presented by Peter Henson, I.C.E., CPMR, CSBA
Distributor Logo Here

2. Introduction to the Globally Harmonized
System of Classification and Labeling
of Chemicals (GHS)
The New Hazard Communication Standard

3. Agenda
• OSHA Revised Hazard Communication
Standard (HSC) – what is it?
• Why is OSHA changing the Standard?
• What are the changes?
• When is the timeline for implementation?
• How does this effect you?
• How can you provide value to your
customers and increase sales at the same
time

4. (a) Purpose.
(a)(1) The purpose of this section is to ensure that
the hazards of all chemicals produced or imported are
evaluated, and that information concerning their
hazards is transmitted to employers and employees.
This transmittal of information is to be accomplished
by means of comprehensive hazard communication
programs, which are to include container labeling and
other forms of warning, material safety data sheets and
employee training.
HazCom 1994 Regulatory Text

5. What is Changing?
• OSHA is revising the HCS to align with the
United Nations’ Globally Harmonized
System of classification and Labeling of
Chemicals
• Two Major Changes
• New Labeling Elements
• Standardized Format for Safety Data
Sheets (SDSs) formally known as
Material Safety Data Sheets (MSDS)
• First deadline is December 1st
, 2013

6. Be The “Go-To” Person
• Your customers will need
help with compliance
• Provide this service and
help your customer
thereby improving your
business on multiple
levels
• Great opportunity to
deepen your relationship
with key accounts

7. Global Harmonization System
• Improve worker
understanding of the
hazards associated with
the chemicals in the
work place
• Requirements phased in
over the next 3 years to
allow employers comply
• Employers MUST have
trained their employees on
the new labels and SDS
sheets by 12/1/13

8. Minimum Requirements
•Training on label elements must
include:
•Product Identifier
•Signal word
•Pictogram
•Hazard Statements
•Precautionary Statement(s)
•Contact info for mfg and/or distributor

9. Minimum Requirements
• How an employee might use the labels in
the workplace, i.e. – explain how
information on the label can be used to
insure proper storage of chemicals
• General understanding of how elements
work together on a label, i.e. – explain that
when a chemical has multiple hazards,
different pictograms are used to identify the
various hazards.

10. Why is this Important?
* Photos taken March 2013 at Healthcare Facility

11. OSHA Fines and Penalties
• Other Than Serious Violation
• A proposed penalty of up to $7,000 for each violation is discretionary. A penalty for an other-
than-serious violation may be adjusted downward by as much as 95 per cent, depending on the
employer’s good faith, history of previous violations, and size of business.
• Serious Violation
• A mandatory penalty of up to $7,000 for each violation is proposed. This may be adjusted
downward per above.
• Willful violation
• Up to $70,000 may be proposed with a minimum penalty of $5,000 for each violation. This may
be adjusted downward per above. Usually, no credit is given for good faith.
• If an employer is convicted of a willful violation of a standard that has resulted in the death of an
employee, the offense is punishable by a court-imposed fine or by imprisonment for up to six
months, or both. A fine of up to $250,000 for an individual, or $500,000 for a corporation, may
be imposed for a criminal conviction.
• Repeated Violation
• Upon re-inspection, a substantially similar violation can bring a fine of up to $70,000 for each
such violation.
• Failure to Abate Prior Violation
• May bring a civil penalty of up to $7,000 for each day the violation continues beyond the
prescribed abatement date.
• De Minimis Violation
• Violations of standards which have no direct or immediate relationship to safety or health.

12. OSHA Fines and Penalties
• Falsifying records, reports or applications can bring a fine
of $10,000 or up to six months in jail, or both.
• Violations of posting requirements can bring a civil penalty
of up to $7,000.
• Assaulting a compliance office, or otherwise resisting,
opposing, intimidating, or interfering with a compliance
officer while they are engaged in the performance of their
duties is a criminal offense, subject to a fine of not more
than $5,000 and imprisonment for not more than 3 years.

13. OSHA Fines and Penalties
OSHA Fines Eagle Janitorial for Violations at Le Moyne College
“Federal Occupational Safety and Health Administration (OSHA) inspectors found five
safety and/or health hazards to custodians at Le Moyne College, which contracts with
Eagle Janitorial Services to keep campus facilities clean. Eagle Janitorial has been fined
more than $10,000 for the violations, all of them deemed “serious.” OSHA inspected the
worksite Jan. 23, 2013; the fines come as a result of a formal complaint filed against
Eagle Janitorial by Service Employees International Union (SEIU) Local 200 United on
Jan. 14, 2013.
OSHA issued its ruling on Feb. 15, 2013, and gave Eagle Janitorial from two to four
weeks to abate the violations, or pay fines. An informal conference between Eagle
Janitorial and OSHA has been scheduled for Tuesday, March 5, at OSHA’s offices at
3300 Vickery Road, North Syracuse. As an interested party, SEIU representatives will be
present.
Among the violations cited:
• Employees have not been provided with hazard communication training;
• Employees who handle cleaning products have not been supplied with personal protective equipment;
• Translators are not in place to train non-English speaking employees about chemical hazards;
• Material Safety Data Sheets (MSDS) are not maintained and available to employees;
• Employee eyewash stations are not provided where corrosive chemicals are handled.
All violations are deemed serious by OSHA and carry varying fine amounts, all totaling
more than $10,000.”

14. Updated Labeling Requirements

15. Pictogram Standards

16. Category 1 Category 2 Category 3 Category 4 Category 5
LD50 £ 5 mg/kg > 5 < 50 mg/kg ³ 50 < 300 mg/kg ³ 300 < 2000
mg/kg
³ 2000 < 5000
mg/kg
Pictogram No symbol
Signal word Danger Danger Danger Warning Warning
Hazard
statement
Fatal if swallowed Fatal if
swallowed
Toxic if
swallowed
Harmful if
swallowed
May be harmful if
swallowed
HMIS vs. Category Levels

17. Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new
label elements and safety data
sheet (SDS) format.
Employers
June 1, 2015 December 1,
2015
Compliance with all modified
provisions of this final rule,
except: The Distributor shall
not ship containers labeled by
the chemical manufacturer or
importer unless it is a GHS
label
Chemical manufacturers,
importers, distributors and
employers
June 1, 2016 Update alternative workplace
labeling and hazard
communication program as
necessary, and provide
additional employee training
for newly identified physical or
health hazards.
Employers
Transition Period to the
effective completion dates
noted above
May comply with either 29
CFR 1910.1200 (the final
standard), or the current
standard, or both
Chemical manufacturers,
importers, distributors, and
employers
Important Dates

18. Next Steps
• Get the word out
• See what your
customers need support
with
• Use this opportunity to
review other potential
safety/OSHA workplace
compliance topics/issues
• Offer solutions that
translate to sales

19. Solution Selling
• Envirox: Safe, Simple, Savings
• Impact Products:
• OSHA Safety audit:
• Right to Know Centers,
• Eye Wash Stations,
• Back Supports, Eye Protection,
• Dust Masks,
• Non-slip Stripping Shoes,
• Gloves,
• Bloodborne Pathogen Kits,
• First Aid Kits
• Ergonomics: Microfiber, Mopping Equipment,
etc.

20. Thank you!