Occupational Safety And Utility Compliance: An Overview Of The New Hazard Communication Standard With The GHS

By Sheldon Primus

The Globally Harmonized System (GHS) for classification and labeling of chemicals is a logical, comprehensive, and international approach to:

• Defining the three hazards of chemicals: health, physical, and environmental.
• Creates a process in which to classify chemical hazards by using available data on the chemicals.
• Establish a globalized way to communicate hazard information and protective measures through labels and the new Safety Data Sheets (SDS).

The Hazard Communication standard is found in 29 CFR 1910.1200 (https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099) and is mandatory for all employers, under OSHA, that have chemicals that fall under 1910.1200(b)(5). Wastewater facilities have several of these chemicals for laboratory testing, disinfection, carbon sources, or other processes.  Therefore, the GHS changes will affect all facilities and not just those within a State OSHA program.

“The Purple Book” from the UN on the GHS (Credit: https://www.osha.gov/dsg/hazcom/ghs.html)

The GHS is a brainchild of a special committee in the United Nations (UN) from as far back as 1992. At that time compliance was expected by 2000, but the first GHS document wasn’t published until 2003 (OSHA, 2013 https://www.osha.gov/dsg/hazcom/ghs.html). However, only portions of the program have been implemented in the international community. In the US, agencies such as OSHA, DOT, Department of Agriculture, and others are rapidly transitioning to the labeling and hazard classification.

Utilities workers are surrounded by hazardous chemicals in large and small quantities throughout their workday. Some laboratory procedures use multiple reagents, acids, and alkaline to yield readings of process control activities. If there were an accident in the laboratory, how would the operator know how to protect themselves, properly clean the spills, or even storage and handling of these chemicals? This information is found in the Material Safety Data Sheet (MSDS) provided by the chemical manufacturer to the end user.

The GHS will change MSDS to SDS (Safety Data Sheets) with mandated and uniformed sections for the global chemical manufacturer.   Now all sections will have to be standardized as follows:

1. Identification
   1. Product identifier, emergency number
2. Hazard(s) identification
   1. Class/category
   2. Signal word (Danger or Warning)
   3. HNOC (Hazard not otherwise classified)
   4. Mixture comment
3. Composition/information on ingredients
   1. Chemical name, common name, CAS, ingredient % or cut off limits
4. First-aid measures
   1. Necessary measures, symptoms/effects
5. Fire-Fighting measures
   1. Suitable and unsuitable & Hazards from fire
6. Accidental release measures
   1. Precautions, PPE, emergency procedures
7. Handling and Storage
   1. Precautions, special handling
8. Exposure control/personal protection
   1. PEL, TLV, NTP, IARC, engineering controls
9. Physical and chemical properties
   1. Appearance, odor threshold, pH, flash point, LEL/UEL, vapor pressure/density
10. Stability and reactivity
    1. Possible hazardous reactions, incompatible materials
11. Toxicological information
    1. Routes of exposure, symptoms, acute/chronic
12. Ecological information (non-mandatory)
13. Disposal consideration (non-mandatory)
14. Transport information (non-mandatory)
15. Regulatory information (non-mandatory)
16. Date of preparation/last revision (mandatory)

Another monumental change in the new system is the shift from the NFPA (National Fire Protection Association)/HMIS (Hazardous Material Identification System) rating and color coding chemicals to the Hazard Communication System (HCS) pictogram. A “4” in the current system means a severe hazard in the color category. Now a “4” is only a slight hazard in the GHS. A change such as this will take a little while to “sink in” for workers that have always used the NFPA/HMIS system.

To further the confusion for the American workers, the color code is not being replaced with pictograms as presented below. Each pictogram is associated with a hazard that the chemical manufacturer identified is present or suspected in their product.    

(Credit: https://www.osha.gov/dsg/hazcom/ghs.html)

Following the pictogram must be a “signal word,” either DANGER or WARNING, with a statement of why the product has that particular signal word.  These words and the number system are tied to the GHS hazard index as shown on the following charts.

(Credit: https://www.osha.gov/dsg/hazcom/ghs.html)

 

(Credit: https://www.osha.gov/dsg/hazcom/ghs.html)

On the health toxicity scale the LD₅₀ indicates that out of 100 test animals that 50 or half died at a specific dosage in mg/kg.  Therefore, the more toxic the chemical the lower the dose needed to kill half of the test subjects. So, the GHS scale ranks the #1 as being a lower dose and #5 being a higher dose. See the below chart for a visual depiction of the GHS scaling.

(Credit: "Global Harmonization: The New Face of HazCom" by Don Weatherbee)

In addition, the flammable products follow a temperature scale in Celsius, boiling point, and flashpoints. The boiling point is described as “the boiling point of a liquid at a pressure of 14.7 pounds per square inch absolute (psia). This pressure is equivalent to 760 millimeters of mercury (760 mm Hg). At temperatures above the boiling point, the pressure of the atmosphere can no longer hold the liquid in the liquid state and bubbles begin to form. The lower the boiling point, the greater the vapor pressure at normal ambient temperatures and consequently the greater the fire risk.” (OSHA, 2013 https://www.osha.gov/dte/library/flammable_liquids/flammable_liquids.pdf)

OSHA defines flashpoint as, “the minimum temperature at which a liquid gives off vapor within a test vessel in sufficient concentration to form an ignitable mixture with air near the surface of the liquid. The flash point is normally an indication of susceptibility to ignition.”  (OSHA, 2013 https://www.osha.gov/dte/library/flammable_liquids/flammable_liquids.pdf).

(Credit: "Global Harmonization: The New Face of HazCom" by Don Weatherbee)

(Credit: "Global Harmonization: The New Face of HazCom" by Don Weatherbee)

The labeling of chemicals is changing to the new system, though utilities can use the old labeling system for secondary containers. However, if they choose to use both systems, then the workers must be trained on both systems.  Labels will now look as follows:

(Credit: The Purple Book: https://www.osha.gov/dsg/hazcom/ghs.html)

As a Utility, these many changes and all information regarding the handling, use, storage, and cleanup must be in a hazard communication (HazCom) program. It’s the employees right to know what hazardous material they are working around in their daily job. A written HazCom program can be done by a consultant or an in-house safety and compliance officer by following the 29 CFR 1910.1200(e) guidelines.

Worker training is an important part of this standard. Training is required (under OSHA jurisdiction) initially when a worker is introduced to a hazardous chemical, when their roles change to working with these chemicals, and annually. The training requirements for the Hazard Communication program are 29 CFR 1910.1200(h).  The compliance schedule for the GHS transition is as follows:

(Credit: https://www.osha.gov/dsg/hazcom/hazcom-faq.html#12)

This new system will leave some workers confused as to how to handle spills, perform cleanup efforts, or to decide which personal protective equipment to wear.  Remove that confusion through effective training and awareness.