Georgia Tech- Right To Know Training


Hello, and welcome to the Right to Know
Training, brought to you by the Georgia Tech Office of Environmental Health and
Safety. This training will give users a comprehensive overview of the rules and
regulations under the State of Georgia’s Right to Know Law To ensure that you
receive the proper credit for this training, please make sure that the
following actions are completed prior to taking the Right to Know Training Prior to taking the Right to Know Training, you must be enrolled in the Onsite Environmental
Health and Safety Assistant database or EHSA. Please note if you are using the
Shared User Management System, or SUMS, your are in our database unless you received
an error message about this video. Please follow the instructions to be added.
Please note that you must pass the test at the end of this training presentation
with a score of 80% or higher. Should you not get a score of 80% or higher, you
will have to wait 24 hours before attempting to take the training and test
again. You can use this video as a future reference after the training is complete
by viewing it at the Georgia Tech EHS YouTube channel. This channel can be
accessed at the extreme top right hand corner of the EHS Homepage found at ehs.gatech.edu. Please note that no credit for the training will be recorded unless
you are completing it through the SUMS system. The objectives for this course
are as follows- To understand the components and requirements under
Georgia’s Right to Know Law. Recognize key components of the updated Hazard Communication Standard, or HCS, under the Globally Harmonized System, or GHS. These components we further elaborated on later in the training presentation. Be
able to differentiate hazards using the new standardized pictograms. Be able to
identify elements of the new standardized hazard label. And finally,
learn where to locate information about hazardous chemicals under the
standardized 16 section safety data sheet, commonly referred to as an SDS. As an employee of the state of Georgia, you’re given the right to be informed
about hazardous chemicals you work with under the Georgia Public Employee
Hazardous Chemical Protection and Right to Know Act of 1988. This is often
referenced simply as a Right to Know, or RTK. Under this law, you cannot be fired,
disciplined, or discriminated against for exercising your rights under this act. A
grievance procedure may be filed if you are adversely affected for exercising
these rights. We will discuss these and all other rights given under this law to
State of Georgia employees later in the training session. What is Right to Know? Right to Know is
the State of Georgia equivalent to the Federal Hazard Communication Standard,
abbreviated as HCS. This is generally monitored and regulated by the
Occupational Safety and Health Administration, or OSHA. However OSHA is a federal statute unless there is a state OSHA program in existence. In Georgia,
there is no State OSHA, and since Georgia Tech is on state property,
the RTK law takes its place. OSHA regulations are still considered best
management practices in most cases. Other organizations that provide guidance on
chemical management include the National National Institute for Occupational Safety and
Health, abbreviated as NIOSH, the Resource Conservation and Recovery Act,
abbreviated as RCRA, the American Conference of Governmental Industrial
Hygienists, or ACGIH, the American National Standards Institute, or ANSI, and
the Asbestos Hazard Emergency Response Act, or AHERA. The Right to Know Law also
protects people’s rights regarding the information they are provided about
hazardous materials he or she may be working with. It also ensures you’re
provided with all the hazardous material safety data sheets and knowledge on how
to properly read them to obtain the information you may be looking for. To
recap, here are legal components of the law that this training will elaborate on-
1. The requirements of a law that the State of Georgia employer must adhere
to. 2. The rights of the employees to receive information regarding the
hazardous chemicals he or she may face while on the job. 3. The right of the
employee to have their physician receive information on chemicals to which he or
she may be exposed to. 4. The right of the employee to receive formal training
and education on the hazardous chemicals that he or she may face. This is the most
important component of the Right to Know Training, and by taking this training you’re
receiving a huge portion of the prudent information on this topic. 5. What an SDS
is, and how to read one to search for information you may be looking for. And 6,
where hazardous chemicals are used in your work area and how to protect
yourself from an accident. There are many benefits to the campus at
large, as well as the surrounding community, by having the Right to Know
law in place. It obviously protects the employee by presenting much more
disclosure about hazardous materials that he or she may encounter. In addition
to that, it makes sure that Georgia Tech and other state-run institutions are
held accountable for the materials we possess on our campus. This also provides
transparency to our community and emergency responders about the materials we have
so that any emergency or hazardous situation can be dealt with as
efficiently as possible. The other key component under this law is that it
upholds an employee’s right against wrongful discharge or other
discrimination due to exercising his or her rights. This means if you request
information on the materials you work with that are guaranteed under this law,
your employer must comply. Your employer cannot lawfully discriminate against you
in any way including disciplinary action or dismissal for requesting this
information as this is part of your rights under this law. This section of
the law OCGA – 45 – 22 – 11 protects the employee’s right for a formal
grievance filing if you feel you’ve been adversely affected for exercising your
rights. As with all other legal grievances, you must follow your
employer’s established grievance filing policy in the event this process must be
started. Please contact your HR representative should you need more
information. Beginning in 2010, and finishing implementation in 2015, there
have been some significant changes made to the Right to Know program, aligning it
with the updated HCS under the Globally Harmonized System. These include the
changes associated with SDS’. Prior to this change SDS’ is were referred to as
material safety data sheets or MSDS’. The SDS’ now have a specified 16 section
format which was not required before. The definitions of hazards have also been
changed to provide specific criteria for classification. The GHS now has 16
classifications of physical hazards, ten classifications of health hazards, and
two classifications of environmental hazards. Precautionary statements must
also be provided. These are numerous in totality, but can include general
statements such as “keep out of reach of children”. They can also include
prevention statements such as “handle under inert gas”, response statements such
as “evacuate area”, storage statements such as “store locked up” as well as disposal
statements such as “refer to manufacturer’s instructions for disposal
or recovery”. There are some products that are not
covered under the Right to Know program. The materials exempt under RTK include
materials already covered by the Department of Energy, or DOE
regulations, chemicals that are being transported in state as part of a
shipment or interstate commerce, chemicals covered by the Atomic Energy
Act or Federal RCRA, alcoholic beverages or other articles intended for
personal consumption, and consumer products that are being used in the
workplace in the same manner that would be classified as normal consumer use. The
classic example of this type of material would be liquid paper correction fluid. There are particular topics addressed under the Right to Know program, and many of these have been previously referenced. The remainder of this training
presentation will dive in in these topics more in depth. These include
training, labeling, access to hazard information, the right to file a
grievance, inventory requirements, and a few other odds and ends that will assist
you in complying with this law and promote working as safely as possible when
working with hazardous materials. As noted earlier, training is one of the key
components of the Right to Know program and may be its most essential element. Right to Know requires that training be provided at any of the following
intervals- at the time of initial assignment, usually marking the beginning
of employment at a minimum. Whenever a new hazard is introduced into the
workplace. This happens quite frequently in the university setting and we’ll talk
more about it in the odds-and-ends section. And finally, this training should
be renewed annually. For a comprehensive overview of all Georgia Tech specific
required training, as well as a link to the training tool, please visit ehs.gatech.edu/training for more details. The required courses to begin
working in a lab with any chemical or biological material Right to Know and
Lab Safety 101. If you have not completed Lab Safety 101, and need to work in a
laboratory, this training should be taken immediately. Lab Safety 101 is available
both online and in-person. Please visit the EHS training page for more
information, including upcoming in-person training sessions as well as the link to
the online tutorial. Other types of EHS training may be required if working with
biological or radiological materials such as General Biosafety Training, Bloodborne Pathogen Training, and Radioactive Material Safety Training. Again, please consult the EHS training page for more information and upcoming
sessions. This training presentation cannot dive into particular RTK issues
for a lab. As such there is an additional level of training that is referenced in
the RTK program which states that you must have lab specific hazard trainig from
your department. This usually comes from a PI or experienced lab member such as a
research group lab manager. This training must cover any operation in your
workspace where hazardous chemicals may be present. Because there is no central
database for all Georgia Tech training classes, EHS requests that paper
copies of all lab personnel training certificates be kept in a central spot,
usually near a lab entrance or exit so they may be easily accessible. Labeling,
and more importantly the information coming in on a GHS compliant label, has
changed relative to the previous system of labeling. You will now see a label
that has the following elements required to be on labels coming from a
manufacturer, importer, or distributor. These include a chemical name or product
name, a hazard pictogram or pictograms, if more than one is appropriate for the
material in question, a signal word such as “warning” or “danger”, a precautionary
statement such as “keep out of reach of children”, a hazard statement such as” may
cause liver or kidney damage”, the supplier information which specifies the
manufacturers physical location and contact information, and a product
identifier or identifiers may also be present. This may include the UN number,
proper shipping name, and CAS number. These are the pictograms associated with
the various hazards that they represent. You may see one of many of these on a
chemical depending on what the chemical is Proper accommodations should be made
for the storage and use of all materials containing one or more of these
pictograms. Beginning from left to right, top to bottom, the pictograms are the
“exploding bomb symbol”. This signals that the chemical may have explosive
properties. The “gas cylinder symbol”. This represents that the chemical is a compressed gas.
“The flame symbol”. This signifies that the material is flammable. “The damaged
material / damaged hand symbol” represents that the material is
corrosive, and may damage materials or be a dermal contact hazard. “The O with the
flame over the top” indicates that the material is an oxidizer. “The skull and crossbones symbol” indicates that the materials toxic or is
classified as a poison. “The silhouette with a star pattern on the chest” always
indicates a health hazard. An often made assumption based on the position of
where the star pattern is superimposed is that this indicates an inhalation
hazard. It should be noted that this does not solely indicate an inhalation hazard
although that may apply depending on the material in question. “The exclamation
mark symbol” also indicates a health hazard warning, but is considered a
denotation that the hazard is less than that of the silhouette label. The
analogous situation would be the signal word difference on the GHS compliant
label between “warning” and “danger” where the former is a less severe signal than
the latter. And finally, “the dead fish out of water
with a dead tree” is indicative that the material is an environmental pollutant
of some type making it hazardous to the environment in some way. Here are
side-by-side comparisons of the former ANSI pictogram format versus the new GHS
compliant pictogram format .The actual symbols have undergone very minor
changes, mostly in terms of size color and orientation. Only in the case of the
irritant or lesser health hazard was a wholesome change made from an X to an
exclamation point. You will also notice that pictograms now exist to denote a
compressed gas or respiratory hazard where one did not previously exist in
the old format. As mentioned earlier signal words are now part of the GHS
compliant label. “Danger” being a more serious word, and “warning” being
less serious as it pertains of the severity of the hazard associated with
the material in question. Physical hazard statements are now included on the label
and have an alphanumeric identifier assigned to each one. There are a total
of 91 possible physical hazard statements, 74 health hazard statements,
and 21 environmental hazard statements. Please view the slides to see an example
of each. They’ll always be denoted at the very least by the statement itself, but
may also be coupled by the alphanumeric identifier. Introduced earlier, certain
precautionary statements if warranted are required to be on the label per the
GHS. Precautionary statements may or may not have been on previous labeling
systems, and was completely up to the manufacturer as to whether or not these
statements were added to the label. Phrases or statements such as “read label
before use” and “obtain special instructions before use” give cues from
the manufacturer as to the recommendations regarding the things you
consider before using the product. The NFPA system of labeling is still the most widely used hazard rating system in North
America. The original intent was to advise firefighters and other emergency
responders of hazards when extinguishing a fire or responding to a chemical
release. It is also most commonly used with regard to labeling containers made
in-house at Georgia Tech. We will elaborate more on in-house labeling
requirements including immediate versus extended use labeling in the next
portion of this training. The NFPA system of labeling exists concurrently to that
of the GHS and other labeling systems so it is important to know what each
category represents, and what the numeric rating means. The blue portion on the
diamond represents the health hazard of the material, the red portion represents
the flammability, the yellow portion represents the reactivity of the
material, and finally, the white portion of the diamond represents any special
hazards associated with the material. For example, the letters O X would denote
that the material is an oxidizer, a W with a line through would denote that
the material is water reactive .The numeric rating runs on a scale from zero
to four. As discussed earlier when talking about the rating system relative
to the GHS and how they are opposite of one another, the higher the number means
the higher level of hazard. The focus will now shift to container labeling
requirements for those solutions or mixtures of chemicals made in-house. We
break these up into two different categories- immediate use and extended
use labeling. Immediate use labeling constitutes a mixture or solution that
is only going to last up to one day or one shift. This container is also not to
leave the direct control of the person who made it at any time. This type of
container needs only the name of the person who made it and the name of the
chemical. It can be as simple as marker writing directly on a piece of masking
tape and affixing that to the container. The extended use labeling requirements
are a bit different than those for immediate use containers.This again
would be for a container of a mixture or solution, but it will differ in the
length of time that the container is around for. The extended use label will
be used for any container that will be stored away at the end of the shift or day, and
used for future occurrences. Potentially this container will be out of your
control once the shift or day is over so the labeling requirements will be a
bit more descriptive and convey the hazard information of the material. The
extended use container must have not only the name of the chemical, but
some form of hazard information. This can be done in a variety of ways but the
most common in-house hazard information efficient is done through the NFPA
diamond. While not required on extended use containers, EHS strongly recommends that
an owner or group name also be put on the extended use container as well.
Regardless of the type of label used, it is imperative to remember that every
chemical container must have a label. The difference will be in the type and
detail of the information written on the label. The two pictures in this slide are
examples of both an immediate and extended use label. Any container not
having a label that you come across in your lab should be reported to your
supervisor, a lab manager, or an EHS Lab and Chemical Safety Professional
immediately. The Lab and Chemical Safety team can be contacted at the email address
below [email protected] Here are some acceptable examples of blank
labels that are commonly used at Georgia Tech, and would be consider compliant for
extended use labeling given that they are completed correctly. Beside label changes,
perhaps the changes to the safety data sheets are the most significant changes
to the HCS under the GHS. First the name has been changed from material safety
data sheets or MSDSs to safety data sheets or SDS.
Regardless of this name change, they are required by law to be kept on hand. They
may be kept in either a hardcopy or electronic format, but you must make sure
they can be accessed by everyone in the event of an emergency. It is important
that all employees or users have access to the SDSs for the chemicals he or
she may be working with. The other significant change, other than the name
change, is the format for which SDSs now must comply with. Prior to the GHS,
manufacturers could produce MSDSs is in a variety of formats, and sections could be
in any order. In comparing the old ANSI recommended MSDS format and the new GHS
required format, one can see that the overall structure of the sections are
now different. The GHS format for section order provides clarity so one can be
assured that no matter what the chemical material is the SDS will always have
identification information in Section 1, first aid measures at Section 4,
accidental release measures in Section 6, and so on. Here is a side-by-side comparison of
the rest of the sections of the MSDS versus the SDS comparing the ANSI
recommended MSDS format and the GHS required SDS format. Chemical inventory
must be kept and reconciled semi-annually per the State of Georgia
Board of Regents reporting requirements. The deadlines for individual lab
inventory reconciliation is approximately mid-June and mid-December
each year, although the inventory can be
technically reconciled at any point during the reconciliation period. The
web-based inventory system used at Georgia Tech is the Environmental Health
and Safety Assistant, or EHSA. If you are a new arrival to Georgia Tech, and are
bringing materials with you, this should be reflected in your inventory, in
addition to any chemicals that are purchased once you arrive and begin
working. If you need to be added as a user to EHSA, need training on how
the system works, or any other general inquiries, you may always contact [email protected] Here are a number of reminders that are important to remember
in order to comply with many of the Right to Know concepts. Create or follow any
existing written standard operating procedures or SOPs for every regular
task that is done in your work area, especially if this task involves a
hazardous material or chemical . Take ownership of your workspace. This
involves knowing where all of the safety equipment such as safety showers, eye
washes, fire extinguishers, first-aid kits, and spill kits are located. Make sure you
know how to properly and safely use shared equipment.
This would include using shared tools in a machine shop, a cleanroom, or any other
shared work setting on campus. Conduct monthly meetings amongst your group. Most
research groups and groups or units within departments already conduct
monthly safety meeting. If you can take at least three minutes of time to speak
about a safety topic of interest it will be beneficial to have the groups input
on the topic at hand. Chances are if it’s on one person’s mind,
it is likely on the minds of others. Have new employees sign a checklist once the
orientation is complete. This is documentation that the person training
hasn’t missed anything, but is also confirmation for the trainee that he or
she has received all of the safety information needed to work as safely as
possible. A blank template of such an orientation checklist can be found on
the EHS website under the documents tab of the Lab and Chemical Safety page,
under the forms column. And lastly, if ever you come across any situation where
you question your own or anyone else’s safety be sure to ask your supervisor.
Don’t be afraid to communicate about things like this with other
colleagues, and remember you can always feel free to reach out to anyone in EHS
directly. Please go to ehs.gatech.edu/contact to find contact information for
all EHS personnel. You can also access all available online upcoming in-person
training sessions at ehs.gatech.edu/training. The lab safety manual can
be found in both web and PDF format at ehs.gatech.edu/lsm. The Georgia
Tech Police Department number (404) 894-2500 should be programmed in your phone but you can also find the number on the back
of your BuzzCard, should you forget. A manager from EHS carries an emergency
phone 24 hours a day seven days a week This number is (404) 216-5237 and should only be used for emergency purposes. It is
important to remember that the police should be contacted first in any true
emergency. Dispatch will automatically contact the on-call manager at this
number when the police need EHS assistance. After watching this video in SUMS, you
will need to complete the comprehension test. You must pass this test with a
score of 80% or higher to receive credit for the training. Iif you do not pass this
test, you must wait 24 hours before attempting to retake it. You can access this training video at anytime through the SUMS system or on
the EHS YouTube channel. A link to this channel can be found on the EHS main
page at the top right hand corner. If you are taking this training through RosterTech, please close this window and click on “final test” .This will open up a new
browser window with the test. This concludes our presentation of the
Right to Know Training. Thank you for your completion of this training.