HAZARD COMMUNICATION: Hazard Classification Guidance For .

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HAZARD COMMUNICATIONHazard Classification Guidancefor Manufacturers, Importers, and EmployersOSHA 3844-02 2016

Occupational Safety and Health Act of 1970“To assure safe and healthful working conditions forworking men and women; by authorizing enforcementof the standards developed under the Act; by assistingand encouraging the States in their efforts to assuresafe and healthful working conditions; by providing forresearch, information, education, and training in the fieldof occupational safety and health.”Material contained in this publication is in the publicdomain and may be reproduced, fully or partially, withoutpermission. Source credit is requested but not required.This information will be made available to sensoryimpaired individuals upon request.Voice phone: (202) 693-1999;teletypewriter (TTY) number: 1-877-889-5627.This publication provides a general overview of a particularstandards-related topic. This publication does not alter ordetermine compliance responsibilities which are set forthin OSHA standards, and the Occupational Safety and HealthAct. Moreover, because interpretations and enforcementpolicy may change over time, for additional guidance onOSHA compliance requirements, the reader should consultcurrent administrative interpretations and decisions by theOccupational Safety and Health Review Commission andthe courts.This guidance document is not a standard or regulation, and it creates no new legal obligations. It containsrecommendations as well as descriptions of mandatory safety and health standards. The recommendationsare advisory in nature, informational in content, and are intended to assist employers in providing a safeand healthful workplace. The Occupational Safety and Health Act requires employers to comply withsafety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approvedstate plan. In addition, the Act’s General Duty Clause, Section 5(a)(1), requires employers to provide theiremployees with a workplace free from recognized hazards likely to cause death or serious physical harm.Cover Image: Photodisc

HAZARD COMMUNICATIONHazard Classification Guidancefor Manufacturers, Importers,and EmployersOccupational Safety and Health AdministrationU.S. Department of LaborOSHA 3844-02 2016

TABLE OF CONTENTSOVERVIEW . 1I.INTRODUCTION . 3II.THE HAZARD CLASSIFICATION PROCESS . 6III.IDENTIFYING HAZARDOUS CHEMICALS . 14IV. DATA COLLECTION . 15V.DATA ANALYSIS. 19VI. RECORDING THE RATIONALE BEHIND THE RESULTS OBTAINED . 28VII. CLASSIFICATION OF HEALTH HAZARDS . .10VII.11Acute Toxicity . 32Skin Corrosion/Irritation . 63Serious Eye Damage/Eye Irritation . 86Respiratory or Skin Sensitization. 115Germ Cell Mutagenicity . 135Carcinogenicity . 149Reproductive Toxicity . 170Specific Target Organ Toxicity – Single Exposure . 189Specific Target Organ Toxicity – Repeated or Prolonged Exposure . 210Aspiration Hazard . 227Simple Asphyxiants . 237VIII. CLASSIFICATION OF PHYSICAL HAZARDS . xplosives . 240Flammable Gases . 258Flammable Aerosols . 266Oxidizing Gases . 279Gases under Pressure . 286Flammable Liquids . 294Flammable Solids. 301Self-Reactive Chemicals . 307Pyrophoric Chemicals . 322Self-Heating Chemicals . 332Chemicals Which, in Contact with Water, Emit Flammable Gases . 339Oxidizing Liquids and Solids. 346Organic Peroxides . 358Corrosive to Metals . 372Combustible Dust. 380IX. HAZARDS NOT OTHERWISE CLASSIFIED. 385i

APPENDIX A. Glossary of Terms and Definitions . 386APPENDIX B. Information Sources to Assist with Hazard Classification . 397APPENDIX C. List of Substances Deemed Toxic or Hazardous by an Authoritative Process . 406APPENDIX D. OSHA-Designated Carcinogens . 419Workers’ Rights . 420OSHA Assistance, Services and Programs . 420NIOSH Health Hazard Evaluation Program . 423OSHA Regional Offices . 423How to Contact OSHA . 424ii

OVERVIEWIn March 2012, the Occupational Safety and Health Administration (OSHA) revised its HazardCommunication Standard to align it with the United Nations Globally Harmonized System ofClassification and Labelling of Chemicals (GHS), Revision 3. The revision to the HazardCommunication Standard (HCS) built on the existing standard, by requiring chemicalmanufacturers and importers to follow specific criteria when evaluating the hazardous chemicalsand when communicating the hazards through labels and safety data sheets (SDSs).This document is designed to help manufacturers and importers of chemicals not only identifychemical hazards, but also to classify these hazards so that workers and downstream users can beinformed about and better understand these hazards as required by OSHA’s HazardCommunication Standard. This guidance may also be useful to employers who decide toconduct hazard classifications to assure the accuracy and completeness of information providedto them by suppliers.Understanding the hazards is the critically important first stage in the process of establishing aneffective hazard communication program. The process of hazard classification consists of fourbasic steps. Selection of chemicals to evaluate;Collection of data;Analysis of the collected data; andRecords of the rationale behind the results obtained.This document provides guidance on the processes involved and identifies considerations in theconduct of hazard classifications. Guidance on the allocation of the hazard communication labelelements is provided in an OSHA Brief on Labels and Pictograms, located on the HazardCommunication webpage, at www.osha.gov/hazcom.Material contained in this publication is in the public domain and may be reproduced, fully orpartially, without permission. Source credit is requested but not required.How this Document is OrganizedThis guidance is organized into several chapters. Chapter I introduces the guidance. Chapter IIprovides an overview of the hazard classification process. Chapter III discusses how to identifythe chemicals to be classified. Chapter IV explains the process of data collection. Chapter Vdescribes the process and information needed for data analysis. Chapter VI discusses theinformation that may be useful to note in recording the rationale used to develop theclassification of the various hazards. Chapters VII, VIII, and IX present the guidance to classifyhealth hazards, physical hazards, and hazards not otherwise classified covered by the HazardCommunication Standard, respectively.1

In addition, several appendices are provided at the end of this document: A glossary of terms and definitions is included in Appendix A, since much of thediscussion in this document is of a technical nature.A list of sources is provided in Appendix B. This list is by no means exhaustive, but itcontains many useful resources.Appendix C contains a list of chemicals for which OSHA has adopted permissibleexposure limits. This is a helpful starting point for identifying chemicals that are toxic orhazardous The HCS does not contain a “floor” (list) of chemicals pre-determined to behazardous under the standard (except for chemicals OSHA has already determined to becarcinogens); however, there are lists of hazardous chemicals compiled by authoritativesources that classifiers may find useful to consult. The chemicals listed in Appendix Care an example of one such list. Classifiers should also consult the American Conferenceof Governmental Industrial Hygienists’ (ACGIH’s) list of Threshold Limit Values(TLVs) and the items identified as carcinogens by the International Agency for Researchon Cancer (IARC) Monographs on the Evaluation of Carcinogenic Risks to Humans, orthe Report on Carcinogens from the National Toxicology Program (NTP). These lists areupdated periodically, and users should check to determine whether there has been anupdate.A list of OSHA-designated carcinogens is provided in Appendix D. Please see ChapterVII.6, Carcinogenicity, for guidance on classification of these chemicals.2

I. INTRODUCTIONOSHA's Hazard Communication Standard (HCS) is designed to protect against chemical-sourceinjuries and illnesses by ensuring that employers and workers are provided with sufficientinformation to anticipate, recognize, evaluate, and control chemical hazards and take appropriateprotective measures. This information is provided through safety data sheets (SDSs), labels, andemployee training. In order for SDSs, labels, and training to be effective, the hazard informationthey convey must be complete and accurate. Thus, it is critically important to obtaincomprehensive and correct information about the hazards associated with particular chemicals.What is Hazard Classification?Hazard classification is the process of evaluating the full range of available scientific evidence todetermine if a chemical is hazardous, as well as to identify the level of severity of the hazardouseffect. When complete, the evaluation identifies the hazard class(es) and associated hazardcategory of the chemical.The HCS defines hazard class as the nature of a physical or health hazard, e.g., flammable solid,carcinogen, and acute toxicity. Hazard category means the division of criteria within eachhazard class, e.g., acute toxicity and flammable liquids each include four hazard categoriesnumbered from category 1 through category 4. These categories compare hazard severity withina hazard class and should not be taken as a comparison of hazard categories more generally.That is, a chemical identified as a category 2 in the acute toxicity hazard class is not necessarilyless toxic than a chemical assigned a category 1 of another hazard class. The hierarchy of thecategories is only specific to the hazard class. The hazard classification process provides thebasis for the hazard information that is provided in SDSs, labels, and worker training.The hazard classification process, as provided in the Hazard Communication Standard, hasseveral steps, including: Identifying the chemical; Identifying the relevant data regarding the hazards of a chemical;Reviewing the relevant data to ascertain the hazards associated with the chemical;Determining whether the chemical will be classified as hazardous according to thedefinition of hazardous chemical in the standard; andDetermining the degree of the hazard, where appropriate, by comparing the data withthe criteria for health and physical hazards. The HCS provides specific criteria for hazard classification to ensure that chemicalmanufacturers, importers, and other classification experts come to similar conclusions regardingthe hazards of chemicals. The resulting classification is then used to determine appropriatehazard warnings. This method not only provides employers and workers with more consistentclassification of hazards, but the hazard information on SDSs and labels is in a form that is more3

consistent and presented in a way that facilitates the understanding of the hazards of chemicals.This hazard information can then be used when evaluating the workplace conditions to determinethe hazards in the workplace, as well as to respond to exposure incidents.The information and criteria provided in Appendix A to 29 CFR 1910.1200 are used to classifythe health hazards posed by hazardous chemicals. Similarly, the information and criteriaprovided in Appendix B to 29 CFR 1910.1200 are used to classify the physical hazards posed byhazardous chemicals.Hazard classification does not involve an estimation of risk. The difference between the termshazard and risk is often poorly understood. Hazard refers to an inherent property of a substancethat is capable of causing an adverse effect. Risk, on the otherhand, refers to the probability that an adverse effect will occurRisk is often expressedwith specific exposure conditions. Thus, a chemical willas the simple equation:present the same hazard in all situations due to its innateHazard X Exposure Risk.chemical or physical properties and its actions on cells andtissues. However, considerable differences may exist in therisk posed by a chemical, depending on how the chemical is contained or handled, personalprotective measures used, and other conditions that result in or limit exposure. This documentaddresses only the hazard classification process, and will not discuss risk assessment, which isnot performed under the HCS.Who Must Conduct Hazard Classifications?Only chemical manufacturers and importers are required to perform hazard classifications on thechemicals they produce or import. Under the HCS, an employer that manufactures, processes,formulates, blends, mixes, repackages, or otherwise changes the composition of a hazardouschemical is considered a "chemical manufacturer." Distributors and employers may also chooseto conduct hazard classifications if they are concerned about the adequacy of the hazardinformation received for the chemicals they use in their business or distribute to others.What Resources are Needed to Conduct a Hazard Classification?Three primary resources are required for hazard classification. First is the complete, accurate,most up-to-date literature and data concerning the hazardous chemical in question (discussedbelow in Chapter V, Data Analysis). Second, is the ability to properly understand and interpretthe information retrieved in order to identify and document hazards. Third, is the specificcriteria for each health and physical hazard class and category defined in the HazardCommunication Standard. As mentioned above, Appendix A to 29 CFR 1910.1200 provides theclassification criteria for health hazards, and Appendix B to 29 CFR 1910.1200 provides theclassification criteria for physical hazards.Manufacturers and importers of hazardous chemicals are responsible for ensuring that hazardinformation provided to their workers and downstream users is complete and accurate. Toachieve this, the person(s) assigned to conduct hazard classifications must have the ability to4

conduct complete and effective literature research and data retrieval. They should also be able toeffectively interpret the literature and data in order to determine the nature and extent of physicaland health hazards. A lack of qualified workers does not exempt a manufacturer or importerfrom compliance with the HCS.How to Use This Guidance DocumentThe hazard classification requirements of the HCS are specification-oriented. That is, chemicalmanufacturers, importers, and employers evaluating chemicals are required to follow specificcriteria for evaluating and classifying hazards, and they must be able to demonstrate that theyhave accurately reported the hazards of the chemicals produced or imported in accordance withthe criteria set forth in the HCS.This document provides a detailed description of the criteria used to classify a hazardouschemical and guidance on how to apply them. In addition, a basic framework for hazardclassification is provided, along with a description of the process that can be used to comply withthe requirements of the HCS. An example using a mock chemical is also provided to illustratethe classification process of the given hazard.The interpretation of information relating to the physical and health hazards associated with achemical can be a highly technical undertaking, and should be conducted by trained staff such astoxicologists, industrial hygienists, and safety professionals. This document will not replace theneed for such professional expertise. It is intended to serve only as useful guidance on the basicconsiderations and operational aspects involved in the conduct of hazard classifications.Once hazard classification is complete, classifiers must select the appropriate label elements forthe hazards identified. Appendix C to 29 CFR 1910.1200, Allocation of Label Elements,identifies the proper pictogram, signal word, hazard and precautionary statements for eachhazard class and category in the HCS.This document does not address detailed labeling requirements or SDSs. OSHA has developedQuickCards and OSHA Briefs on labels, pictograms, and SDSs, as well as other guidance.These materials can be found on the HCS website at: www.osha.gov/h

What is Hazard Classification? Hazard classification is the process of evaluating the full range of available scientific evidence to determine if a chemical is hazardous, as well as to identify the level of severity of the hazardous effect. When complete, the evaluation identifies the hazard class(es) and associated hazard category of the chemical.

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