HAZARDOUS CHEMICALS CHANGES TO HAZARD COMMUNICATION & CODE REQUIREMENTS FOR HEALTH CARE

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1 HAZARDOUS CHEMICALS CHANGES TO HAZARD COMMUNICATION & CODE REQUIREMENTS FOR HEALTH CARE

2 AGENDA 2 Global Harmonized System of Classification and Labelling of Chemicals (GHS) OSHA Communication Standard Life Safety Code Requirements for Hazardous Chemicals in Hospitals Building/Fire Code Requirements Resources

3 GLOBALLY HARMONIZED SYSTEM (GHS) 3 United Nations effort to standardize communication information 1992 Rio Conference mandate development of global standard 2003 First Edition published Update every 2 years OSHA adopted GHS Rev. 3 (2009)

4 OSHA HCS 4 Adopted Revised Hazard Communication Standard, 29 CFR (HCS) March 2012 Changed from performance-based to a structured standard for labeling Standardized Safety Data Sheets (SDS), formerly Material Safety Data Sheets Requires quick visual notification Requires handling requirements on label

5 OSHA HCS 5 Implementation Schedule Completion Date Requirement(s) Who December 1, 2013 Train employees on the new label elements and SDS format. Employers June 1, 2015 Chemical Compliance with all modified provisions of this final rule, manufacturers, except the distributor shall not ship containers labeled by the importers, chemical manufacturer or importer unless it is a GHS label. distributors and employers December 1, 2015 The distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label. Chemical distributors 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

6 OSHA SDS 6 SECTION TITLE SECTION TITLE 1 Identification 9 Physical and Chemical Properties 2 Hazard Identification 10 Stability and Reactivity 3 Composition 11 Toxicological Information 4 First-Aid Measures 12 Ecological Information* 5 Fire-Fighting Measures 13 Disposal Considerations* 6 Accidental Release Measures 14 Transport Information* 7 Handling and Storage 15 Regulatory Information* 8 Exposure Controls/Personal Protection 16 Other Information * Note: Sections required to be consistent with GHS

7 OSHA/GHS LABELS 7 Labels must contain Name, Address, Telephone Product Identifier Signal Word Hazard Statement(s) Precautionary Statement(s) Pictogram(s)

8 OSHA/GHS LABELS 8 Signal Word Used to signal relative severity Only one signal word on a label Danger more severe hazards Warning less severe hazards Hazard Statement(s) Describe nature of the hazard Ex. causes damage to kidneys from prolonged exposure Precautionary Statement(s) Recommended measures Types - Prevention - Response - Storage - Disposal Slash designates choice of options (e.g. dispose per local/state regs)

9 OSHA/GHS LABELS 9 Supplemental Information Optional Anything deemed helpful Could include PPE info Hazard Statement(s) Describe nature of the hazard Ex. causes damage to kidneys from prolonged exposure Precautionary Statement(s) Recommended measures Types - Prevention - Response - Storage - Disposal Slash designates choice of options (e.g. dispose per local/state regs)

10 OSHA/GHS LABELS 10 Workplace Labels No change to the OSHA requirements Can use current labeling but must have information in current requirements Can use pictograms with black border instead of red border Can use NFPA and/or HMIS labeling

11 OSHA/GHS LABELS 11 Employer Responsibilities Must maintain labels on all containers Not responsible for info on shipped containers However, if label becomes damaged, employer must replace No label requirements if transferring from a labeled container to a portable container

12 OSHA/GHS PICTOGRAMS 12

13 COMPARISON OF OSHA AND NFPA LABELS 13

14 OSHA HAZCOM PROGRAM 14 Learn the Standard/Identify staff Get the OSHA Standard Get familiar with provisions Ensure a primary responsible party Identify staff for various activities Prepare and implement a written program Prepare written plan Prepare inventory Ensure containers are labeled Keep labels on shipped containers Label workplace containers

15 OSHA HAZCOM PROGRAM 15 Maintain Safety Data Sheets SDS for each hazardous chemical Readily accessible Inform and Train Employees Train on hazards in work area before assignment New hazards introduced Requirements of the standard, hazards, PPE, where to get additional info Evaluate and reassess program Review periodically to ensure effectiveness Revise to reflect changed conditions

16 TEXAS HAZARD COMMUNICATION ACT TDSHS NOTICE 16

17 LIFE SAFETY CODE Life Safety Code references 1996 NFPA 30, Flammable and Combustible Liquids Code 1996 NFPA 45, Laboratories Using Chemicals 1999 NFPA 99, Standard for Health Care Facilities 2003 Life Safety Code references 2000 NFPA 30, Flammable and Combustible Liquids Code 2000 NFPA 45, Laboratories Using Chemicals 2002 NFPA 99, Standard for Health Care Facilities 2012 Life Safety Code references 2012 NFPA 30, Flammable and Combustible Liquids Code 2011 NFPA 45, Laboratories Using Chemicals 2012 NFPA 99, Health Care Facilities Code

18 LIFE SAFETY CODE 18 NFPA 30 Standard to protect bulk storage of flammable and combustible liquids Classified by total quantity and type of storage container NFPA 45 Standard used to protect laboratories Classified by Class A, B, C, D lab units Controls quantities based on small container sizes that would be in use and storage within a lab unit NFPA 99 Health Care specific code Separate occupancy requirements in older editions NFPA 101 Requires 1 hr. for severe hazards

19 LIFE SAFETY CODE LAB LIMITATIONS Life Safety Code 1996 NFPA 45 limits Health Care labs to Class D 2003 Life Safety Code 2000 NFPA 45 limits Health Care labs to Class D 2012 Life Safety Code 2011 NFPA 45 limitation for health care removed 2012 NFPA 99 requirements for labs health care facilities removed Labs within hospitals can be designed per NFPA 45 Consistent with hazard classifications within Chapter 18/19 of LSC

20 CHANGES TO NFPA NFPA 30 Requirements Decreased amounts allowed as floor level in building is increased Attempt to match IBC/IFC limitations for control areas Further reduction for special occupancies (incl. health care)

21 CHANGES TO NFPA /2000 NFPA 45 Requirements Lab Unit D has no rating requirements

22 CHANGES TO NFPA NFPA 45 Requirements Lab unit quantities limited as height in building increased Allows for higher total quantity of chemicals than NFPA 30/IFC control amounts but in smaller containers Reductions above 3 rd floor and 6 th floor

23 BUILDING/FIRE CODE REQUIREMENTS /2012 IFC Control amounts based on total volume Otherwise Group H Occupancy Group H Requirements - Drainage/containment - Ventilation - Standby/Emergency power - Emergency alarm - Temperature/pressure controls Medical Gas Storage Amounts larger than permit amount (504 cu. ft. for O 2 ) Interior locations in 1-hr. rated rooms Ventilation to exterior in 1-hr. rated shaft enclosure

24 CITY OF HOUSTON HAZARDOUS ENTERPRISE ORDINANCE (HEO) 24 HEO Enacted in 1996 Houston Distribution Fire - Burned for 2 weeks - Warehouse designed for aluminum cans; used for storage of plastics and chemicals Overtax sprinkler system - Chemical runoff into adjacent residential neighborhood Requires special permit to be classified as Group H occupancy Notice to Public Not allowed if adjacent to certain special risks (schools, daycare, hospitals, residential, etc.) HEO Revised 2002 Allow limited size Group H rooms in Hospitals and Universities Allow spaces for fuel storage for generators and fire pumps

25 RESOURCES 25 GHS Rev. 3 (2009) Comparison of Current/Previous OSHA and GHS OSHA HazComHome Page OSHA Quick Card (Pictograms) TDSHS HazCom Right to Know NFPA Codes ICC Codes

26 QUESTIONS 26 Robert S. Hicks, PE Sr. Fire Protection Engineer WSP+ccrd

11/22/2013. Where are we now? How did we get here? MSDS Sheets. CA MSDS Standard. Right To Know. Director s List. T8 CCR 5194 Hazard Communication

11/22/2013. Where are we now? How did we get here? MSDS Sheets. CA MSDS Standard. Right To Know. Director s List. T8 CCR 5194 Hazard Communication Proposition 65 Hazard Communication Global Harmonization Fall 2013 Uniformity of Safety Data Sheets and Labels Today s Discussion Where are we now? How did we get here? Where are we now? T8 CCR 5194 Hazard