Hazard CommunicationMODULE 11

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Purpose of OSHA’s Hazard Communication Standard

“…ensure that employers and employees know about work hazards and how to protect themselves so that the incidence of illnesses and injuries due to hazardous chemicals is reduced.”

LabelProgram MSDS

Hazard Communication

Program

Container Labeling

Material SafetyData Sheet

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Why should chemical hazards be communicated?

Exposure Risk: About 32 million workers potentially exposed to chemical hazards

Profusion of Chemicals: About 650,000 chemical products exist; hundreds of new ones introduced annually

Health Effects: May include heart ailments, central nervous system damage, kidney and lung damage, sterility, cancer, burns, and rashes

Safety Hazards: Potential to cause fires, explosions, or other serious accidents

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Concept of regulation:

Employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working.

They also need to know what protective measures are available to prevent adverse effects from occurring.

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Who is covered?

General industry, shipyard, marine terminals, longshoring, and construction employers

Chemical manufacturers, importers, employers, and employees exposed to chemical hazards

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Employer Responsibilities

A significant portion of the standard pertains only to chemical manufactures, importers, and distributors

Employers who do not produce chemicals only have to focus on establishing a workplace program and communicating information to their

workers. Appendix E provides guidelines

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Employer Responsibilities

Inventory: Identify and list hazardous chemicals in workplaces

MSDS & Labeling: Obtain Material Safety Data Sheets and labels for each hazardous chemical, if not provided by the manufacturer, importer, or distributor

Written Program: Implement a written HazCom program, including labels, MSDS, and employee training

Communication & Training: Communicate hazard information to employees through labels, MSDSs, and formal training programs

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Labeling Exemptions

Other federal agencies control labeling requirements for the following substances: Pesticides Chemicals covered under the Toxic Substance

Control Act Foods or food additives Distilled spirits, tobacco Consumer products, lumber, cosmetics Hazardous wastes

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How can workplace hazards be minimized?

Hazard Assessment: The first step in minimizing workplace hazards is to perform a thorough hazard assessment

Manufacturer Evaluations: Employers can rely on the manufacturers’ or importers’ evaluations of the hazards of the chemicals they use (from MSDS)

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Why is a written program required?

Employer: Program ensures that all employers receive the information they need to inform and train their employees

Employee: Program provides necessary hazard information to employees

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Employer Requirements-Written Program

Must cover at least: Labels and other forms of warnings Material Safety Data Sheets Employee Information and Training List of chemicals present and MSDS for

each Methods used to inform employees of

hazards of non-routine tasks Hazards of chemicals in unlabeled pipes

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Multi-Employer Workplaces

When other employers have employees onsite that may be exposed, program must include: Methods to provide contractor employees

with on-site access to MSDS Methods used to inform other employers of

precautionary measures for normal and emergency situations

The employer’s chemical labeling system

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Consumer Products Exemption

Any consumer product as defined in the Consumer Product Safety Act where: Used in the workplace for the purpose

intended Exposure within the range that could

reasonably be experienced by consumers when used for intended purpose

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Written Program Availability

Written program available on request: To employees and their representatives Program may be kept at main location

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How must chemicals be labeled?

Containers of hazardous chemicals entering workplace must be labeled with Identity of chemical Appropriate hazard warnings

Message, picture or symbol Hazards of chemical Target organs affected Legible in English, may have other languages

Name and address of responsible party

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Container Labeling Exemptions

No new labels necessary if existing labels convey required information

Labeling not required for portable containers if: Transferred from labeled containers and Intended for immediate use by employee

performing transfer

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Material Safety Data Sheets

Prepared by chemical manufacturer or importer, describing Physical hazards, such as fire and

explosion Health hazards, such as signs of exposure Routes of exposure Precautions for safe handling and use Emergency and first-aid procedures Control measures

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Material Safety Data Sheets

Must be in English and include specific chemical identity and common names

Must provide information about: Physical and chemical characteristics Health effects Exposure limits Carcinogenicity (cancer-causing) Identification (name, address, and telephone

number) of the organization responsible for preparing the sheet

Must be readily accessible to employees in their work area

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Material Safety Data Sheets

No prescribed format If no MSDS received for a chemical:

Contact supplier, manufacturer or importer Maintain record of the contact

May be kept in any form including operating procedures

Addressing hazards of process may make more sense than individual chemicals

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Employee Information and Training

Employees must be provided information and training on hazardous chemicals in their work area: At the time of their initial assignment Whenever a new physical or health hazard

is introduced into their work area May cover categories of hazards or

individual chemicals

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Employee Information

Employers must inform employees of: Training requirements of this section Operations in their work area where

hazardous chemicals are present; Location and availability of the written

hazard communication program

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What must employee training contain?

Program: Explanation of the HazCom program, including information on labels, MSDSs, and how to obtain and use available hazard information

Physical and health hazards of chemicals Protection: Protective measures such as

engineering controls, work practices, and the use of PPE

Detection: How to detect the presence or release of a hazardous chemical (using monitoring devices, observation, or smell)

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Health Hazard Definitions

Acute: rapid effects, as a result of short-term exposures, of short duration

Chronic: effects as a result of long-term exposure, of long duration

Corrosive: Visible destruction or irreversible damage to body tissue, including acids and caustics (bases)

Definitions in 1910.1200 Appendix A

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Target Organ Effects

Hepatotoxins: liver damage Nephrotoxins: kidney damage Neurotoxins: nervous system effects Agents which act on the blood or

hematopoietic system: deprive body tissues of oxygen

Agents which damage the lungs

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Target Organ Effects

Reproductive toxins, including teratogens (damage fetuses) and mutagens (damage DNA)

Cutaneous hazards: skin damage Eye hazards

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Setting up a program

The Hazard Communication Standard covers both: Physical hazards (such as flammability),

and Health hazards (such as irritation, lung

damage, and cancer) Most chemicals used in the workplace

have some hazard potential, and thus will be covered by the rule

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Setting up a program

This rule is more performance-oriented than many other OSHA regulations.

You have flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific, rigid requirements

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Setting up a program

Make a list of all chemicals in the workplace that are potentially hazardous Survey the workplace to make a

comprehensive list Identify chemicals in containers, including

pipes Establish purchasing procedures so that

MSDSs are received before a material is used in the workplace

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Identify hazardous chemicals in the workplace

Compile a complete list of the potentially hazardous chemicals in the workplace

Determine if you have received material safety data sheets for all of them

If any are missing, contact your supplier and request one

Do not allow employees to use any chemicals for which you have not received an MSDS

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Preparing and implementing a hazard communication program

All workplaces where employees are exposed to hazardous chemicals must have a written plan

The plan does not have to be lengthy or complicated

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Employee Training

You may want to discuss each chemical individually if there are only a few chemicals in the workplace

You may want to train generally: Based on the hazard categories (e.g.,

flammable liquids, corrosive materials, carcinogens)

Where there are large numbers of chemicals or

Where the chemicals change frequently

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Training Documentation

The rule does not require employers to maintain records of employee training, but many employers choose to do so

This may help you monitor your own program to ensure that all employees are appropriately trained