NFPA Journal - May/June 2013 - (Page 73)
NFPA2013
published in 2005 and available online
at unece.org. The new guidelines provide criteria for substance classification according to their physical, health,
and environmental hazards, as well
as hazard communication elements,
including labeling and safety data
sheets. Since OSHA represented the
U.S. in this international forum, it proposed to introduce the new guidelines
through the modifications it made last
year to its HazCom document.
Overlap and conflict
The diverse and sometimes conflicting
national and international requirements
can create confusion among those who
seek to use hazard information effectively, and the publication of HazCom
2012 created concern and confusion
regarding several key aspects of hazard
communication requirements. Because
NFPA 704 had previously been accepted
as a resource for HazCom compliance, employers were unclear whether
that would continue with the updated
regulation, and it has. Material safety
data sheet preparers and users wondered whether the NFPA 704 hazard
ratings would still be included, now that
HazCom 2012 had adopted the more
prescriptive format and content offered
by adoption of GHS, and it has.
A significant area of concern was the
GHS hazard category numerical values, which are inverted from the NFPA
704 hazard ratings. A material having
an NFPA 704 health hazard rating of 3
or 4 represents serious to severe health
hazard characteristics; the most severe
rating in the GHS system is 1, with 3 or
4 representing moderate to minor hazards. Problems could arise if users are
not aware of the source of a particular
rating and make an incorrect decision based on their understanding of
the numerical value. Additionally, the
GHS health hazard criteria thresholds
use different end points than those in
NFPA 704. This causes some materials evaluated using GHS to yield a less
hazardous health category than that
obtained for the same material using
the NFPA 704 criteria.
To address these issues and others,
OSHA and NFPA have been working
together to develop strategies for communication, outreach, and training.
During development of the current
edition of NFPA 704, the Committee on
Classification and Properties of Hazardous Chemical Data considered the
implications of the pending HCS regulation and the inclusion of the GHS
requirements. Without a clear picture
of what the final rule might look like,
though, the committee elected not to
take any action as part of that revision.
When OSHA announced that the new
GHS requirements had become part of
its HazCom document, the committee established task groups to consider
what impact the new HazCom could
have on NFPA 704. The hazard category numerical values and the health
hazard criteria thresholds were identified as the issues most likely to require
immediate attention and guidance.
Working with members of the NFPA
committee, NFPA staff developed a
standard response, available through
its advisory service, that addresses
questions on the status of NFPA 704
and the impact of HCS and GHS. At
the same time, OSHA, NFPA, and
members of the technical committee
have collaborated on a communication tool to guide users of 704, HCS,
and GHS during this implementation
period. An outreach task group has
prepared a reference card that shows
HazCom 2012 with the GHS elements
side-by-side with those of NFPA 704.
The reference card will be distributed
to users by NFPA and OSHA on their
respective websites.
One result of this collaboration is
that OSHA does not see any reason
for NFPA 704 to be revised in order
to correspond with the GHS category
numbering. NFPA 704 ratings are
still permitted for inclusion in the
safety data sheet, and employers may
continue to use NFPA 704 as part of
a hazard communication program,
provided that the aspects required by
HCS that are not covered by NFPA 704
are addressed separately. Because the
committee includes OSHA staff representation, future revisions of NFPA
704 could benefit from the continued
collaboration established during this
initial HCS implementation period.
Compliance with HazCom 2012 will
be phased in over the next few years,
with full compliance scheduled for
2016. An early compliance date is set
for worker training, which must be
met by December 2013. The OSHA
and NFPA collaboration considered
this initial compliance date in its response to create information resources
and training tools, such as the reference card. Once in place, NFPA plans
to monitor the effectiveness of this
approach through feedback obtained
from emergency responders, through
advisory service inquiries on NFPA
704, and through public input submitted during the next NFPA 704 revision
cycle. As part of that cycle, the technical committee will further evaluate the
health hazard criteria and rating level
thresholds compared to those in the
GHS. Since industry will have at least a
bit of experience with the GHS provisions by then, it is anticipated that the
technical committee will be able to
revisit the NFPA 704 health hazard criteria to validate the basis for continued
use or to make any necessary changes.
For now, NFPA and OSHA are
working to ensure that the two systems
can effectively work together without
significant change. Going forward,
experience from full implementation of
the GHS system may demonstrate a
need for slight changes to NFPA’s
system, but without the expectation
that it would ever be eliminated.
Guy R. Colonna, P.E., is division manager,
Industrial & Chemical Engineering at NFPA.
MAY/JUNE 2013 NFPA JOURNAL
73
http://www.unece.org
Table of Contents for the Digital Edition of NFPA Journal - May/June 2013
NFPA Journal - May/June 2013
Contents
First Word
In a Flash
Perspectives
Firewatch
Research
Heads Up
Structural Ops
In Compliance
Buzzwords
Outreach
Electrical Safety
Wildfire Watch
Treasurer's Report
Work in Progress
Amping It Up
Drill Team
Working Together
Code Process 2.0
Routine Maintenance
Here, There, Everywhere
Section Spotlight
Expo Preview: Exhibitors' Showcase
Looking Back
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