OSHA Flammable
“Light My Fire” – Calculating Flash Points for Flammable Liquids

One of the most common tests for determining hazard classification is the flash point. This humble piece of physical information is defined in various ways in various regulations, but generally is the lowest temperature at which the vapours from a flammable liquid will ignite near the surface of the liquid, or in a test vessel. This can be critical for safety, because this temperature will be the lowest possible for the liquid to cause a flash fire if released or spilled. If the material can be handled and transported at temperatures lower than the flash point, the fire risk will be much smaller.

The flash point has become the standard test for classifying flammable liquids. It’s used by the U.S. OSHA (Occupational Health and Safety Act) and HMR (Hazardous Materials Regulations) classification systems, as well as Canada’s WHMIS (Workplace Hazardous Materials Information System) and TDG (Transportation of Dangerous Goods Regulations).

Obtaining a flash point on a new product is usually easy enough. Many laboratories, particularly those that deal with petrochemicals, can perform the test for a reasonable charge. If your company has too many products to make outsourcing practicable, a flash point tester itself is comparatively low cost (as scientific apparatus goes), and a trained person can obtain data quickly and efficiently. However, both of these options do cost money. Wouldn’t it be nice if there were a Continue Reading…

GHS
GHS Revision 6 is Coming!

Ch-Ch-Ch-Ch-Changes

David Bowie’s 1971 album “Hunky Dory” included the song “Changes” which was released in January 1972. While being recognized as one of Bowie’s most well-known songs, it never made it in into the “Top 40”. One of the lyrics from that song is

“Ch-ch-ch-ch-Changes / (Turn and face the strain) Ch-ch-Changes”.

Those lyrics are most appropriate given the release of the UN ECE Secretariat’s publication of the changes to the 5th Revised edition, which will lead to the creation of Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Sixth Revised Edition.

Here is the link to published changes document.

Six of the changes coming to Revision 6 are as follows:

  1. Desensitized Explosives. A new hazard class for Revision 6 which carries the definition of “solid or liquid explosive substances or mixtures which are phlegmatized to suppress their explosive properties in such a manner that they do not mass explode and do not burn too rapidly and therefore may be exempted from the hazard class “Explosives” (see Chapter 2.1; see also Note 2 to paragraph 2.1.2.2).”  This new class will have four categories and include its own label elements, H phrases and P phrases.
  2. Pyrophoric Gases. Chapter 2.2 entitled “Flammable Gases (Including Chemically Unstable Gases) is changing to “Flammable Gases”. While the title change is not necessarily newsworthy, the inclusion of the hazard class pyrophoric gases” is. This hazard class now Continue Reading…
Safety Data Sheets (SDS)
OSHA’s Safety Data Sheet Changes

One of the major changes that workplaces will see under OSHA’s new Hazcom 2012 regulations has to do with Material Safety Data Sheets. OSHA has decided to align their requirements with the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Safety Data Sheet (SDS) preparation requirements. What industry has historically called a Material Safety Data Sheet, or MSDS, will now be referred to as simply a Safety Data Sheet, or SDS.

Along with the new name, the SDS’s will have specific requirements for content. SDS’s under the Hazcom 2012 regulations are required to follow a 16 section format and include specific information in each section. The required sections are as follows:

  • Section 1, Identification
    • Includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
  • Section 2, Hazard(s) identification
    • Includes all hazards regarding the chemical; required label elements.
  • Section 3, Composition/information on ingredients
    • Includes information on chemical ingredients; trade secret claims.
  • Section 4, First-aid measures
    • Includes important symptoms/effects, acute, delayed; required treatment.
  • Section 5, Fire-fighting measures
    • Lists suitable extinguishing techniques, equipment; chemical hazards from fire.
  • Section 6, Accidental release measures
    • Lists emergency procedures; protective equipment; proper methods of containment and cleanup.
  • Section 7, Handling and storage
    • Lists precautions for safe handling and storage, including incompatibilities.
  • Section 8, Exposure controls/personal protection
    • Lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
  • Section 9, Physical and chemical properties
We’re Ready When OSHA Is!

ICC is ready for GHS

In January 2011, OSHA proposed that in August of this year, they would publish the final rule to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The more recent DOL Spring semi-annual regulatory agenda released in June revisits the scheduling of the release of the HCS revision to an unspecified date in September of this year. September has now come and gone, and we are still without a final rule from OSHA.

This leads to the question of “If not now, then when?”. It is probably a safe assumption that OSHA’s lack of implementation of GHS to date will be a major topic of discussion at the October 1st – 5th Society for Chemical Hazard Communication (SCHC) fall conference in Washington, DC. Many health and safety professionals, myself included, will be impatiently waiting for word of a revised deadline.

At ICC, we have been preparing for the new requirements so that we are ready when OSHA is. Updates and products related to GHS can be found on our website at: http://www.thecompliancecenter.com/regulations/ghs.htm

Mexico First NAFTA Member to Adopt GHS

On June 4, 2011, Mexico became the first NAFTA member to adopt the GHS as a basis for national health and safety regulations, by proclaiming a new Mexican standard, NMX-R-019-SCFI-2011.

This standard will be based on the Purple Book (Globally Harmonized System of Classification and Labelling of Chemicals), published by the United Nations. However, unlike the changes planned for the United States and Canada, this standard is voluntary. It will allow use of the GHS to be in compliance with the existing standard NOM-018-STPS-2000, which covers classification, labeling and safety data sheets. Suppliers may, however, choose to remain in compliance with the existing standard, without updating to GHS.

Unfortunately, there has not yet been an English translation of this new standard published. Further information (in Spanish) can be found at:

http://dof.gob.mx/nota_detalle.php?codigo=5166277&fecha=04/11/2010

If you have any questions regarding this issue, please contact ICC The Compliance Center Inc at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

4th Revised Edition of the ‘Purple Book’ (GHS) – What’s new

In June of 2011, the fourth revised edition of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS, Rev.4) was issued.
 
The changes in the latest revision include two new hazard categories : chemically unstable gases and non-flammable aerosols.  These new categories account for hazards not previously addressed where special precautions are needed when handling, storing or transporting these items.  Acetylene, a commonly used welding gas is an example of a ‘chemically unstable gas’.  Acetylene is unstable and can explode without an ignition source at pressures as low as 25 psi (172 kPa).  For that reason, Acetylene is normally sold ‘dissolved’ in porous Acetone to allow for higher pressures.  Additionally, a non-flammable aerosol, still presents a pressurization hazard and can explode if heated, even though it is not technically ‘flammable’.

The 4th Revised Purple Book provides additional clarification of some of the hazard criteria, such as for gases under pressure or mixture cutoffs for Category 1 Carcinogens; and further rationalization of precautionary statements, such as ‘P251 – Do not pierce or burn, even after use’ for non-flammable aerosols as well as flammable aerosols.

Also added, is a new special labelling arrangement for materials that are only corrosive to metals and not corrosive to the skin and eyes.  The new option for the Competent Authority is to allow the hazard pictogram for the ‘Corrosive to metals’ category to Continue Reading…

GHS Implementation – A Quick Guide for International Suppliers

Slowly but surely, the Globally Harmonized System (GHS) is becoming "the way things are done" for hazard communication around the world. Many countries have already implemented internal versions of the GHS. Others, such as the United States and Canada, are on the verge of introducing their own. How does one keep track of who’s doing what? Here’s a list of some of the most vital resources for those concerned about hazard communication worldwide.

  • The UN "Purple Book" (Globally Harmonized System of Classification and Labelling of Chemicals). This document is the basis of the GHS around the world. It is developed by the UN Subcommittee of Experts on the Globally Harmonized System (UNSCEGHS). The GHS Subcommittee has been tasked with producing biennial updates to this document; currently, the book is in the third revision (2009-2010). You can obtain a downloadable PDF version of the Purple Book at unece.org. The download is free and you do not have to register. Hard copies are available through our online store (US | Canada).
  • UN Guidance documents. Although the Purple Book is, at first glance, written in reasonably clear language, some of the sections are very technical. The UN has provided some guidance documents that can help readers understand the rules in more general terms. These guides include: