Specific Program Requirements applicable on every Validus Energy worksite are:

All chemicals used by Validus Energy will have a safety data sheet (SDS) available. 

A SDS database will be kept on Validus.Energy under the safety data sheet tab.

Validus energy employes will receive annual training on this program, chemicals they may work with, labeling and the precautions to take when using chemicals.  They will also be retrained if new chemical hazards are introduced.

All chemicals on a Validus Energy worksite will be labeled. 

Validus energy will regularly assess contractor activity to ensure that chemical containers brought onto a Validus Energy worksite are labeled and the SDS are included in the chemical inventory list.

 
The SDS library located on Validus.Energy under the Safety Data Sheets tab (https://validus.energy/safety-data-sheets-1) will serve as the chemical inventory list of chemicals known to be present and used by Validus Energy employees.

EHS will review the Hazardous Chemical Inventory annually and update the SDS Library as necessary.

The Globally Harmonized System of Classification and Labeling of Chemicals or GHS is an internationally agreed-upon system, created by the United Nations.

It is designed to replace the various classification and labeling standards used in different countries by using consistent criteria for classification and labeling on a global scale.

The GHS is a set of criteria and provisions that can be incorporated into existing systems, or used to develop new systems.

It is important to know that:

The GHS itself is not a regulation or a standard
It establishes agreed upon hazard classification and communication provisions with explanatory information on how to apply the system

GHS is a system for:

• Standardizing and harmonizing the classification and labeling of chemicals 
• Defines health, physical and environmental hazards of chemicals
• Communicates hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).

Having differences in systems within different countries and within different regulatory agencies within the same government leads to inconsistent protection for those potentially exposed to the chemicals as well as creating extensive regulatory burdens on companies producing the chemicals.

In the United States, there are requirements for classification and labeling of chemicals for the Consumer Product Safety Commission, the Department of Transportation, the Environmental Protection Agency, and the Occupational Safety and Health Administration.

To provide sound management of chemicals that includes a system through which chemical hazards are identified and communicated to all who are potentially exposed.

The widespread use of chemicals has resulted in the development of sector-specific regulations (transport, production, workplace, agriculture, trade, and consumer products).

International Mandate

The United Nations Conference on Environment and Development (UNCED) issued a mandate calling for the development of the GHS.

It was:

• Adopted in the 1992 United Nations Conference on Environment and Development (UNCED), and was often called the "Earth Summit".
   
• It was recognized that an internationally harmonized approach to classification and labeling would provide the foundation for all countries to develop comprehensive national programs to ensure the safe use of chemicals.

• To ensure that employers, employees, and the public are provided with adequate, practical, reliable and comprehensible information on the hazards of chemicals so they can take effective, preventive, and protective measures for their health and safety.
• Improved safety for workers and others through consistent and simplified communications on chemical hazards and practices to follow for safe handling and use.
• Greater awareness of hazards, resulting in safer use of chemicals in the workplace and in the home.

Chemicals are classified based on the type, the degree and the severity of the hazard it poses.  Manufacturers are required to evaluate chemicals to make sure they are properly classified.  Physical hazards are generally consistent with current DOT requirements. Classification is the starting point for hazard communication:

• Chemicals are classified based on the type, the degree and the severity of the hazard it poses.
• Classification involves the identification of the hazard(s) of a chemical or mixture by assigning a category of hazard/danger using defined criteria.

Hazard classes are subdivided into categories of a hazard:

• 16 classes of physical hazards
• 10 classes of health hazards
• 3 classes of environmental hazards

• Explosives
• Flammable Gases
• Flammable Aerosols
• Oxidizing Gases
• Gases Under Pressure
• Flammable Liquids
• Flammable Solids
• Self-Reactive Substances
• Pyrophoric Liquids
• Pyrophoric Solids
• Self-Heating Substances
• Substances which, in contact with water emit flammable gases
• Oxidizing Liquids
• Oxidizing Solids
• Organic Peroxides
• Corrosive to Metals

• Acute Toxicity
• Skin Corrosion/Irritation
• Serious Eye Damage/Eye Irritation
• Respiratory or Skin Sensitization
• Germ Cell Mutagenicity
• Carcinogenicity
• Reproductive Toxicology
• Target Organ Systemic Toxicity - Single Exposure
• Target Organ Systemic Toxicity - Repeated Exposure
• Aspiration Toxicity

• Hazardous to the Aquatic Environment
• Acute aquatic toxicity
• Chronic aquatic toxicity
  
  • Bioaccumulation potential
  • Rapid degradability

Once a chemical has been classified, the hazard(s) must be communicated to target audiences.

Labels and Safety Data Sheets are the main tools for chemical hazard communication.

The following UN markings are required on the for outer package:

• Product Identifier
• Signal Word (Danger, Warning)
• Hazard Statement (for each hazard class and category)
• Pictogram(s)
• Precautionary Statement (for each hazard class and category)
• Name, Address, and Phone Number of the chemical manufacturer

"Danger" or "Warning" are used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category.

• "Danger"  for the more severe hazards
• "Warning" for the less severe hazards.

Hazard statements are standardized and assigned phrases that describe the hazard(s) as determined by hazard classification.

Hazard Statements are standard phrases assigned to a hazard class and category that concisely describe the nature of the hazard. The following are examples of Hazard Statements:

• “Causes eye irritation”
• “Toxic if inhaled”
• “Flammable aerosol”
• “May cause cancer”
• “May cause respiratory irritation”
• “Harmful to aquatic life”
• “Contains gas under pressure; may explode if heated”

Pictograms serve to attract attention to the hazard warnings.  One pictogram may be used to represent several hazards within a class, and:

• Convey health, physical and environmental hazard information, assigned to a GHS hazard class and category.
• The GHS symbols have been incorporated into pictograms for use on the GHS label
• Pictograms will have a black symbol on a white background with a red diamond frame

• Carcinogen
• Mutagenicity
• Reproductive Toxicity
• Respiratory Sensitizer
• Target Organ Toxicity
• Aspiration Toxicity

• Aquatic toxicity

• Irritant (skin and eye)
• Skin Sensitizer
• Acute Toxicity
• Narcotic Effects
• Respiratory Tract Irritant
• Hazardous to Ozone Layer (Non-Mandatory)

Some of the pictograms included in the final rule are already widely recognized by a general audience.

• Acute toxicity (fatal or toxic)

• Gases Under Pressure

• Skin Corrosion/Burns
• Eye Damage
• Corrosive to Metals

• Explosives
• Self-Reactives
• Organic Peroxides

• Oxidizers

• Flammables
• Pyrophorics
• Self-Heating
• Emits Flammable Gas
• Self-Reactives
• Organic Peroxides

Precautionary Statements are standardized explanations of the measures to be taken to minimize or prevent adverse effects:

• Prevention
• Response
• Storage
• Disposal

Prevention- 

“Wear protective gloves”

Response- 

“If inhaled remove person to fresh air”

Storage- 

“Store in well-ventilated place”

Disposal- 

“Waste must be disposed of in accordance with   federal, state and local environmental control regulations”

Employers must ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked with either the information specified under (i) through (v) for labels on shipped containers:

•(i) Product identifier;
•(ii) Signal word;
•(iii) Hazard statement(s);
•(iv) Pictogram(s);
•(v) Precautionary statement(s);

OR

Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

Material Safety Data Sheets (MSDSs) have been changed to Safety Data Sheets (SDS).

Items of primary interest to exposed employees and emergency responders are presented at the beginning of the SDS; more technical information is presented in the later sections.

Sections of an SDS

1. Identification of the substance or mixture and of the supplier
2. Hazards identification
3. Composition/information on ingredients
4. First aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information including information on preparation and revision of the SDS 

Identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier:

• Product identifier used on the label and any other common names or synonyms by which the substance is known.
• Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.

Identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards:

• The hazard classification of the chemical  
• Signal word.
• Hazard statement(s).
• Pictograms
• Precautionary statement(s)
• Description of any hazards not otherwise classified 

Identifies the ingredient(s) contained in the product. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed:

• Chemical name
• Common name and synonyms
• For mixtures, the chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards 
• Chemical Abstracts Service (CAS) number and other unique identifiers.

Describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical:

• Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion).
• Description of the most important symptoms or effects, and any symptoms that are acute or delayed.
• Recommendations for immediate medical care and special treatment needed, when necessary.

Provides recommendations for fighting a fire caused by the chemical:

• Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation.
• Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns.
• Recommendations on special protective equipment or precautions for firefighters.

Provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment:

• Use of personal precautions and protective equipment
• Emergency procedures, and appropriate protective clothing
• Methods and materials used for containment
• Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning or vacuuming; adsorbent materials; and/or equipment required for containment/clean up)

Provides guidance on the safe handling practices and conditions for safe storage of chemicals:

• Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited)
• Recommendations on the conditions for safe storage, including any incompatibilities

Indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure:

• OSHA Permissible Exposure Limits (PELs), American Conference of
• Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer
• Appropriate engineering controls
• Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals
• Any special requirements for PPE, protective clothing or respirators

Identifies physical and chemical properties associated with the substance or mixture including but not limited to the following:

• Appearance (physical state, color, etc.)
• Upper/lower flammability or explosive limits
• Odor
• Vapor pressure
• Vapor density
• pH
• Flash point

Describes the reactivity hazards of the chemical and the chemical stability information:

• Description of the specific test data for the chemical(s)
• Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled
• List of all conditions that should be avoided and all classes of incompatible materials with which the chemical could react to produce a hazardous situation.

Identifies toxicological and health effects information or indicates that such data are not available:

• Information on the likely routes of exposure
• Description of the delayed, immediate, or chronic effects from short- and long-term exposure
• The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median lethal dose))
• Description of the symptoms
• Indication of whether the chemical is listed in the National Toxicology Program (NTP), International Agency for Research on Cancer (IARC) Monographs or found to be a potential carcinogen by OSHA

Provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment:

• Data from toxicity tests performed on aquatic organisms
• Whether there is a potential for the chemical to persist and degrade in the environment
• Results of tests of bioaccumulation potential
• The potential for a substance to move from the soil to the groundwater
• Other adverse effects

Provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices:

• Description of appropriate disposal containers to use.
• Recommendations of appropriate disposal methods to employ.
• Description of the physical and chemical properties that may affect disposal activities.
• Language discouraging sewage disposal.
• Any special precautions for landfills or incineration activities

Provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea:

• UN number
• UN proper shipping name
• Transport hazard class(es)
• Packing group number
• Any special precautions which an employee should be aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises

Identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS

Any national and/or regional regulatory information of the chemical or mixtures (including any OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product Safety Commission regulations)

Indicates when the SDS was prepared or when the last known revision was made. Other useful information also may be included here