Hazard Communications(HAZCOM)

What Your Business Needs to Know to be in Compliance

Overview of Topics

What is HAZCOM? Who & what does it

apply to? How is OSHA’s

HAZCOM Program different from EPA’s Worker Protection Standard (WPS)

Common citations within the Green Industry

Requirements of a HAZCOM Program Written program Chemical Inventory Material Safety Data

Sheet’s (MSDS’s) Chemical Labels Training

Upcoming changes to the standard

What do you do now?

Audio Information

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What is Hazard Communications???

Also known as “Right to Know”

Requires employers to provide information to employees about chemical hazards in the workplace Physical hazards Health hazards

Who does it apply to?

General Industry, Construction & Agriculture All companies where any hazardous

chemical is used by employees Any size of company – even if it is only 1

employee Includes all chemicals in the workplace

Not just pesticides!!!! Fuel, lubricants, paint, commercial cleaning

products, aerosols, etc.

What is not covered? Hazardous waste Tobacco and tobacco products Wood or wood products – with exceptions Food & Alcoholic beverages Drugs Cosmetics Household consumer products – with

exceptions Articles – as defined in the standard

What is not covered? Wood or Wood Products

Exception Must not be treated with a

chemical Must not be intended for

cutting/sawing

Household Consumer Products Exception Used as intended by the chemical manufacturer Duration & frequency is not greater than the range of

exposure that could be reasonably experienced by a typical household consumer

All Chemicals in the workplace

Training required before exposure

MSDS’s Certified applicator is

still required to go through training

Only pesticides Worker & handler

training Formal training before

the 6th day of exposure Fact sheet @ time of

hire Certified applicator

exempt from training requirement

Specific training required for both topics

HAZCOM VS. WPS

HAZCOM Citations

Constantly within OSHA’s top 10 most frequently cited standards in all industries

Federal OSHA’s #1 cited standard during the period of October, 2008 thru September, 2009 within the Agricultural Production Crops & Agricultural Services Industries

Common Citations Include

No program in place Unlabeled containers Employees are not trained Missing Material Safety

Data Sheet’s (MSDS’s) No written program Missing chemical inventory

What is the Manufacturer Responsible For?

Testing & determining hazards associated with their products

Creating labels & MSDS’s Providing distributors & employers with

MSDS’s

What must be included in your Written Program?

Procedures for:Developing & maintaining a list of

hazardous substances & their MSDS’sHow will the Written program & MSDS’s

be readily available Labeling system that is in place @ your

workplaceNon-routine work tasks (for example –

cleaning a boiler)

What must be included in your Written Program?

Employee TrainingMulti-employer workplace

(contractors/sub contractors)Multi-cultural workplaces must designate

someone to assist employees who are unable to read and/or understand English

Plan for periodic inspection of program (@ least annually)

Container Labeling All containers must be

labeled Except for when intended

for Immediate Use Used up within 1 work shift

(Still a good idea to label the container)

Original container must have manufacturer’s label contact manufacturer or

distributor for a replacement if removed or defaced.

Container Labeling

Secondary container Include name of chemical & manufacturer Any associated hazards to the productSignal words – Caution, Warning, Danger

HMIS NFPA Fire Diamond

NEVER use one of these as a

SECONDARY CONTAINER

Container Labeling

Labeling Pipes

Pipes are not required to be labeled by Federal OSHA’s HAZCOM Standard Some OSHA State Plans may require it NFPA Standard Must have an MSDS for materials in the pipes &

list them in your chemical inventory

Employees must be trained on hazards associated with chemicals in unlabeled pipes

Hazard Identification

Can be anything you want Words Pictures Symbols

Must provide @ least general hazard information & target organs

Must be Legible In English (other

languages if desired)

Prominently displayed

Employee Training Must be in a language that the

participants can understand Must be completed prior to use and/or

possible exposure Include where chemicals are used &

stored Must include the location of:

Your Company’s Written HAZCOM Program Location of MSDS’s Location of Chemical Inventory

Employee Training

What information is included in the MSDS How to read & understand an MSDS & label Your company’s in-house labeling system Who can an employee go to if they need

assistance with translation Signs & symptoms of overexposure First aid procedures PPE Requirements Must be DOCUMENTED!!!!

HMIS & NFPA LabelingHEALTH4 - Life threatening 3 - Major injury likely2 - Temporary/minor injury1 - Irritation/minor reversible injury0 - No significant risk

FLMMABILITY4 – Extremely flammable3 – Flammable under most conditions2 – Needs external heat to ignite1 – Must be preheated to ignite0 – Will not burn

REACTIVITY / PHISICAL HAZARD4 – Extremely explosive3 – Moderately explosive2 – Unstable, violent chemical change, will not detonate1 – Normally stable – can become unstable @ high temps. and pressures.0 – Normally stable, even in fire – will not react with water

1 3

4

WHITESpecial Hazard (NFPA Diamond) / PPE (HMIS Label)

Employee Training

Physical Hazards Flammability Reactivity Corrosive Explosive

Health Hazards Carcinogen Highly Toxic Toxic Irritant Sensitizer Immediately

Dangerous to Life & Health (IDLH

Target Organ Effects

Who Can Perform Training?

Anyone in the company can perform training.

OSHA does not require a trainer to have any type of certification.

They need to be: An effective trainer Have read and

understand OSHA’s HAZCOM standard

Know your company’s HAZCOM Program & Policies

How to train? Just showing a video is not enough Must include company specific

informationMSDS’s – LocationFirst aid proceduresEmergency proceduresEngineering control, work practices &

PPEOperations in work areas where

hazardous chemicals are present

Multi-Employer FacilityContractors & Sub-contractors

Must ensure that information regarding hazards and protective measures is made available to the other employers onsite, where appropriate.

MSDS’s Required for all hazardous chemicals

used in the workplace No standardized format Must be available at all times without

having to ask for a copy Can’t be located in a locked room or

file cabinet Required to be in ENGLISH.

MSDS – Web/Computer Based Collection

Required to have open access at all times to all employees

You need a backup plan for power outage or computer malfunction. Employees need to be trained on how to use the computer & the program

Just saying you have access to the internet is not enough – must be compiled

Recommended to have a back-up hard copy

MSDS’s

MSDS & Chemical inventory must be kept current

MSDS’s are required to be kept for 30 years after you stop using the chemical(s)Chemicals that are no longer used should

be removed from your active MSDS Binder & Inventory List

Store in a separate binder/file

MSDS’s

Is an MSDS required for the chemicals listed to the right? Yes No It depends

Glass cleaner

Steel

Wood

Where to go to find MSDS’s & Labels?

Many manufacturers provide these on their website.

Perform a Google search for the name of the product with MSDS following it.

Free Search Engineshttp://hazard.com/msds/ http://www.ehso.com/msds.php

State OSHA Plans

Must comply with State OSHA Plan

May be more stringent than Federal Regulations

State Plans The following states have

approved State Plans: Alaska Arizona California Connecticut Hawaii Illinois Indiana Iowa Kentucky Maryland Michigan Minnesota Nevada

New Jersey New Mexico New York North Carolina Oregon Puerto Rico South Carolina Tennessee Utah Vermont Virgin Islands Virginia Washington Wyoming

NOTE: The Connecticut, Illinois, New Jersey, New York and Virgin Islands plans cover public sector (State & local government)

employment only.

Possible Changes to come

OSHA is currently in the process of trying to make some changes to the HAZCOM Standard.

Trying to move to use the Globally Harmonized System GHS

MSDS’s will follow Safety Data Sheet (SDS) format

How Will This Effect Chemical Manufactures?

Required to change the format of: Chemical Labels MSDS’s will become

SDS’s Have a specific

format to follow.

This will make a uniform information system

Label Elements Product Name or Identifier Pictogram Signal Word Physical, Health,

Environmental Hazard Statements

Supplemental Information Precautionary Measures

(PPE) Fist Aid Statements Name, Address & Phone #

of Company

ToxiFlam (Contains: XYZ)   

Danger! Toxic If Swallowed, Flammable Liquid and Vapor

Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container

tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary measures

against static discharge. Use only non-sparking tools. Store in cool/well-ventilated

place. 

IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth.

In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam.

See Material Safety Data Sheet for further details regarding safe use of this product.

MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999

Sample GHS Label

How Will This Effect Chemical Employers?

Required to update MSDS’s with SDS’s

Required to provide employee training on new labeling & SDS systems

Unlabeled fertilizer containers

Unlabeled spray bottles. Even if it is

only water in the bottle they are still required to

be labeled as water.

Unlabeled container

What To Do Now?

Obtain a copy of the standard Read & understand the requirements Designate a responsible person to

implement, manage & monitor the program Develop & maintain a chemical inventory of

all hazardous substances Obtain MSDS’s for hazardous substances –

should match chemical inventory list

What To Do Now?

Create a labeling system Check all containers to ensure they are

properly labeled Develop a written program – Hortica has a

Sample Template Program on our website that you can tailor to your business

Make sure the program & MSDS’s are available at all times

Provide your employees with HAZCOM Training – Visit Hortica’s Website for materials

What To Do Now?

Develop procedures to make sure:New employees are trainedCurrent employees are retrained if new

hazards are introducedMSDS’s & Chemical Inventory remains

up to date with all current & new chemicals

Multi-employer issues are addressedProgram is effective (Annual Review)

To access Hortica’s Loss Control & Safety materials on-line:

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Materials may be viewed and downloaded – just another value-added benefit available only to Hortica clients!

Zachery BruceLoss Control Managerzbruce@hortica-insurance.com