HAZARD COMMUNICATION TRAININGFOR SMACNA MEMBER COMPANIES

Who Must Comply with the OSHA HAZCOM StandardThis section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

Does not apply to:Hazardous Waste – SWD Act.Substance Defined by CERCLATobacco, Food and Alcohol ProductsUntreated Wood ProductsConsumer Products used in such a way.Nuisance Particulates that are harmless.Ionizing and Non Ionizing RadiationBiological Hazards

Scope of Responsibilities

Chemical Manufacturers and Importers. Labeling MSDS

SMACNA Member Companies that have employees who use potentially hazardous materials… Main Parts of HAZCOM Program Written Program Chemical List (Inventory) MSDS for Each Chemical in the Inventory Labeled Containers Training (All Employees)

Definitions

Hazardous Chemical Any chemical which has a

physical or health hazard effect.Container

Any bag, barrel, box, can, cylinder, drum, vessel, storage tank or the likes that contain a hazardous chemical.Use

Package, handle, react, emit, extract or generate as a

byproduct or transfer.

STEP 2 LABELS ON

ALL CONTAINERS

STEP 3 MSDS: COMPLETE HAZARD ANALYSIS

STEP 4 INFORMATION AND TRAINING

STEP 5 WRITTEN

PROGRAM

STEP 1 WRITTEN

HAZCOM POLICY

Labeling Information

ManufacturersRequirementsChemical Name

Manufacturer NameManufacturer Address

Appropriate Hazard Warning

Employer’s ResponsibilityChemical Name

Appropriate Hazard Warning

(such as “flammable” or

“toxic”)

Employers’ Labeling Requirements

All containers of chemicals are labeled. The words ‘container’ and ‘label’ have broad meaning in 1910.1200

Exception: immediate use of employee

Do not remove or deface labels Change labels as hazard information changes

(within 3 months)

Information on an MSDS

• Identity• What’s in it?• Physical/Chemical

Properties• Health Hazards• Route of Entry• PEL – TLV - Limits• Listed Under NTP, IARC or

NIOSH• Safe Handling / Use• Controls – Work Practices –

PPE• Emergency and 1st Aid

Requirements

Form 174 - MSDS Non-Mandatory Form with Twelve

(12) Mandatory Spaces Blank spaces are not permitted.

Use NA Produced by chemical

manufacturers and distributors and accepted in good faith by employers

Blank 174s are available from www.osha.gov

Trade Secrets Manufacturer can withhold

information from MSDS Nurse or physician can request

proprietary information in writing OSHA makes final decision if

information is denied to nurse or physician

Employee Exposure & MSDS

Your employee

Your temporary employee

Visitors and other

contractors

Your supervisor

Employee Access to MSDS

The employer shall maintain in the workplace copies of the required material safety data sheets for each hazardous chemical, and shall ensure

that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and

other alternatives to maintaining paper copies of the MSDS are permitted as long as no barriers to immediate employee access in each workplace

are created by such options.)

Information and Training

Requirements of 1910.1200Operations where hazardous chemicals are usedInformation about labeling systems, the written program and MSDS

Physical and chemical hazardsMethods to detect the presence or release of the chemicalProtective measures

Review your Company’s Written Hazard Communication Program and MSDS for information specific to the chemicals you use!