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Transition Guide to the
HMIS® III For In-Plant End Users
1.0
Introduction
This document is intended to assist those businesses which
are currently using an older version of the HMIS® (First or Second Edition) in implementing the new HMIS® Third Edition (HMIS® III). While there
is no one “right” way to accomplish this transition, the procedures in this
Guide were developed by industry participants who have actually made the transition
and learned from it. Following this transitional blueprint can help make your
transition error and confusion free.
2.0
Why Use HMIS®?
Every employer is responsible for
providing their employees with a safe and healthy workplace. Hazard communication
is an important part of this responsibility. Employers must be trained to recognize
the potential hazards of diverse chemicals and properly deal with these hazards
through work practice procedures and the use of personal protective equipment
(PPE). Additionally, hazard communication is the law. The Occupational Safety
and Health Administration’s (OSHA) standard titled “Hazard Communication” found
in Title 29 (Labor) of the Code of Federal Regulations (CFR) part 1910, section
1200, requires chemical manufacturers, importers, distributors, and employers
to provide hazard information to employees and customers.
HMIS®
serves as a primary means of complying with the OSHA Hazard Communication Standard
(known as “the standard” or “HCS”). The HMIS® Implementation Manual, Third Edition, may be used as
the basis of a written hazard communication plan. The rating, labeling, and
training portions of the implementation process satisfy many of OSHA’s requirements for hazard evaluations, workplace labeling
of hazardous materials, and employee instruction, respectively.
OSHA
stated in the Preamble to the 1983 HCS that “Labels prepared in accordance with
NPCA’s Hazardous Materials Identification System would
generally be in compliance with this standard.” OSHA re-confirmed the acceptability
of HMIS® as an in-plant hazard communication tool by stating in the
Preamble to the 1994 Revised Final Hazard Communication Standard, that this
type of system continues to be an acceptable means of complying with the standard,
providing adequate attention is given to target organ hazards during employee
training.
3.0
In What Way Has HMIS® Changed?
The HMIS® Implementation Manual,
Third Edition, is designed to be a BETTER and more COMPREHENSIVE compliance
tool for employers’ use in meeting requirements of the Occupational Safety and
Health Administration (OSHA) HCS. Significant changes in the third edition
include the following:
A.
Changes in definitions better matches language found in the HCS. The third
edition HMIS® adopts OSHA’s
criteria for “Flammability” rating, and adds a “Physical Hazards” category with
seven subcategories:
- Water Reactive
- Organic Peroxides
- Explosives
- Compressed Gasses
- Pyrophorics
- Oxidizers
- Unstable Reactives
B.
The HMIS®
label was revised to better utilize the physical hazard ratings. On the new
labels a field entitled “Physical Hazard” replaces “Reactivity.” The new Physical
Hazard field is orange, to distinguish it from the yellow Reactivity field.
A yellow border makes the label more visually distinctive, and the colors used
on the label comply with the most recent American National Standard Safety Color
Code (ANSI Z535.1-1998).
C.
New ICONS are available to identify specific health and physical hazards. The
ICONS support “at-a-glance” hazard recognition and aid employers with internal
product labeling, informing employees of the specific nature of the chemical
hazard as emphasized by OSHA. ICON stickers are now available for Target Organs,
Physical Hazards, and Personal Protective Equipment (PPE).
D.
Chapter 12 (Hazard Communication
Training) of the Hazardous Materials Identification System Implementation Manual
has been expanded to include the most current information and guidance that
OSHA offers on the subject. There is increased training emphasis on understanding
Target Organ hazards. This chapter also explains how to effectively incorporate
HMIS® into your site-specific Hazard Communication Training
Program using new training aids covered in Chapter 13, Employee Training Materials.
Training aids also reflect the changes in label and ICON options.
4.0 Should I Replace All the Existing HMIS® Labels With HMIS® III Labels?
5.0
How do I Manage the Transition from the Current Version of HMIS® to the HMIS® III?
The most important modifications of the HMIS®
are the new Physical Hazard rating criteria and the introduction of icons to
convey the specific physical hazards and the Target Organ hazards posed by the
chemical or chemical mixture. These changes will most significantly affect
training and labeling of materials within the facility.
5.1
What Are the Steps in an In-Plant Program Transition?
5.1(A).
Step 1
The HMIS® implementation manager (IM) obtains
the HMIS® III Implementation Manual and becomes
familiar with all of the new aspects of the system. The IM should concentrate
on revised portions of the program, such as the Physical Hazard rating criteria,
the Icons and the new Posters and Labels.
5.1(B).
Step 2
The IM determines the length of the transition period,
i.e., the time frame during which the company will fully convert from the prior
edition of HMIS® to the HMIS® III. We recommend a full year for this purpose.
5.1(C). Step 3
The IM should incorporate all the new HMIS®
III and support/communications materials into the company’s existing Hazard
Communication Training Program. Since there will be a period of time when both
the old and the new HMIS® information and ratings will be used throughout the facility, employees
must be aware of the transition and knowledgeable on both systems.
When developing the new training program the IM should
use all of the HMIS® III training aids available.
These include:
The HMIS® Label
The HMIS® Wall Poster
The HMIS® Wallet Card
The Employee Guide to HMIS®
The Employee Quiz
The HMIS® Wall Poster Rating Chart Set
The HMIS® PPE Index
Physical Hazard Icons
Target Organ Icons
HMIS® Right-To-Know Poster
HMIS® Haz
Com Target Organ Poster
HMIS® Target Organ Labels
The transition should not be initiated until ALL employees
have received this training.
If MSDSs for the materials used
reflect HMIS® ratings developed under an earlier
version, replace the existing MSDS with a new MSDS with the HMIS®
III ratings. This should be done in a controlled fashion over the transition
period rather than all at one time.
5.1(D).
Step 4
The IM begins using the various HMIS® III communication tools throughout the facility as soon as possible after
the initial training is completed.
5.1(D)(i) Classic HMIS® III Labels – New Material Containers
The first objects to receive the new HMIS®
III labels should be those containers which are short-lived in the facility.
Begin placing the new HMIS® III labels on raw materials and products which arrive at the loading docks
as soon as the transition training has been completed.
5.1(D)(ii) Classic HMIS® III Labels – Static Containers
Once a process to label short shelf life containers and
material is established, begin to re-label static containers, tanks, totes,
etc., gradually, replacing old labels over a predetermined time frame.
The IM should plan to have
ALL of the old labels replaced with the new labels in the early stages of transitioning.
Depending on the number of labels involved, we recommend that this be accomplished
in the first quarter of the transition period, if possible.
5.1(D)(iii) HMIS® III Wall Posters
The new HMIS® III Wall poster
should be posted next to the old version during the first part of the transition
period. This helps serve as reinforcement to the transition and lessens the
possibility of errors in interpreting the new system information. The new HMIS® III posters should be posted
at other locations to reinforce the new system and the new information.
5.1(D)(iv) HMIS® Wallet Cards
The wallet cards have not changed in the new HMIS® III system. They are still excellent information prompters for the ratings
and codes listed on the HMIS® Labels. They contain
much the same information as the original HMIS® Wall Poster, e.g. explanation
of the HMIS® ratings and the PPE code equipment
and combinations.
5.1(D)(v) HMIS® PPE Index
The PPE Index has not changed in the new HMIS®
III system. However, it is still a good idea to reinforce the PPE information
during the training session and provide the Index in either label or Poster
format throughout the facility for employees to refer to.
5.1(D)(vi) Other Forms of HMIS® III Communications Tools
All of the other HMIS® III
support/communications materials should also be used at the early stages of
transition. This will ensure the employees become familiar with them and have
time to ask questions and resolve conflicts, should they arise, early in the
transition.
5.1(E) Step 5
“Refresher” or Reinforcement
Training, is not required by the OSHA standard, but should be scheduled periodically
during the transition period or as often as needed. The objective of these
training sessions is to address any potential employee questions about HMIS® III and the transition process,
and ensure employees clearly understand the key aspects of the new HMIS®
III system. We recommend emphasizing and using only HMIS®
III materials during the training sessions. This will aid in an orderly and
complete transition. We also recommend using the HMIS® III Posters as the major instructional
props for the training sessions and to augment the training with actual HMIS®
III labels for materials commonly used in the work place. It may be helpful
to use several sample labels to demonstrate all of the different Icons for Physical
Hazards and Target Organs.
6.0 HMIS® Chemical Ratings Guide
New for the HMIS®
III system is the publication of a companion document entitled “HMIS®
Chemical Ratings Guide.” One feature lacking in older versions was a reference
containing HMIS® ratings for commonly used chemicals.
Employers were expected to develop their own ratings or obtain recommended ratings
from suppliers. As a result, ratings of common chemicals often varied from user
to user depending on how the person developing the rating interpreted the HMIS®
ratings guidance. To address this problem and make the system more uniform,
HMIS® now features an “HMIS®
Chemical Ratings Guide.” While users will have to develop ratings for chemicals
or chemical mixtures that are not addressed in the new Guide, HMIS®
users will now be able to rely on the guide for well-documented ratings for
a large number of commodity chemicals.
The guide contains an explanation of
how to develop HMIS® ratings, a table of chemicals with
their HMIS® ratings, and finally an Appendix with
an HMIS® Rating Classification Data Sheet for
each chemical listed in the table.
7.0 Where can I get the HMIS®
III Implementation Manual and all of the Support Materials?
The exclusive licensee for ALL HMIS®
materials is J. J. Keller and Associates, Inc. They may be reached at:
JJ Keller & Associates, Inc.
3003 W. Breezewood
Lane
P. O. Box 368
Neenah, WI
54957-0368
Toll Free: 800-327-6868
FAX: 800-727-7516
www.jjkeller.com
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