Hazard Communication

1

Four ComponentsWritten Program

Contains information on how the employer will meet the requirements of the standard

LabelingLabels must include information such as the name of the material, manufacturer’s

name and address, and hazard warnings

(SDS) Safety Data SheetsContain all important information on a material and must be accessible to

employees at any time

Employee TrainingEmployees learn the characteristics of the materials

2

Written Plan

• A Written Plan must address the following issues;• Procedures• Related Safety & Health Issues• Training• Chemical Inventory• Labeling Procedures

3

Written Plan

• What are the chemicals on the job or in the shop?• Who will be exposed to specific chemicals?• Are the employees trained prior to work?

• What is the procedure for clean-up?• What is the procedure for first-aid and emergency

contact?

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Labeling – The NFPA Placard

Fire Hazard4 – Below 73°F3 – Below 100°F2 – Above 100°F1 – Above 200°F0 – Will Not Burn

Health Hazard4 – Deadly3 – Extremely Dangerous2 – Hazardous1 – Slightly Hazardous0 – Normal Material

Reactivity4 – Detonate3 – Shock and Heat may

Detonate2 – Violent Chemical Change1 – Unstable if Heated0 - Stable

Specific HazardACID – AcidCOR – CorrosiveOXY - Oxidizer

The placard is used on all storage tanks and transfer containers (gas cans, storage vessels).

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O5

GHS - Globally Harmonized System1910.1200

All existing training and right-to-know requirements remainMSDS are now SDS (Safety Data Sheets)Revision to hazard classification

• Hazard Category System• Classification based on defined chemical data

Sheet structure is now uniformNew pictures enhance communication for non-englishspeaking employees 6

GHS Hazard CommunicationAdditions to GHS standard include:

• Combustible dust • Pyrophoric Gases• Simple Asphyxiants

Hazards Not Otherwise Classified (HNOC) – any substance that is known to be hazardous but does not conform to the hazard categories• Classification allows additions to be made at a later date

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Labeling• Product Identifier - Must match the identifier on the SDS and include the

chemical identity of the substance /mixture ingredients that create hazard.• Pictograms - Image conveys chemical hazards. (black symbol, white field, all

inside red diamond)• Signal Word - indicates the severity of the product’s hazard.

– “Danger” = severe hazards – “Warning” = less sever hazards.

• Hazard Statements - based on the nature of the product’s hazardous contents.

• Supplier Identification – must include the name, address and telephone number used to locate or communicate with the manufacturer or supplier.

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Labeling• Precautionary Statements - informs the reader about how to prevent the hazards of

storing or handling the product . Four categories:– Prevention– Response– Storage– Disposal

• Other Elements – A competent person may add content to the label as long as it does not interfere with the label structure or confuse the user

– Transport pictograms – Precautionary pictograms – First-aid recommendations – Universal product codes– General usage information

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LabelingIdentifier 1

Pictograms 2

Signal words 3

Hazard Statement 4

Precautions 5

Supplier Identification 610

Labeling• It is the employer’s responsibility to ensure that all

containers of hazardous substances in the workplace are labeled

• Never remove a label• Container size is irrelevant, all containers must be

labeled• The only labeling exception is “Immediate Use”,

employee has 100% control of material.

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(SDS) Safety Data Sheets

The SDS give vital information on the behavior of a material:

• Physical Data• Reactivity with other

chemicals• Emergency First-Aid Procedures

• Hazard Information• Prolonged and Acute Health Effects

12

SDS StructureThe format should include the following sections:

1. Identification2. Hazard(s) identification3. Composition/information on ingredients4. First-Aid measures5. Fire-fighting measures6. Accidental release measures7. Handling and storage8. Exposure controls/personal protection

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SDS StructureFormat cont…

9. Physical and chemical properties10. Stability and reactivity11. Toxicological information12. Ecological information13. Disposal considerations14. Transport information15. Regulatory information16. Other information, including date of preparation or last revision

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Definition of Physical States

• Gas - a substance or mixture which at 50°C (122°F)has a vapor pressure greater than 300 kPa; or is completely gaseous at 20°C (68°F) and a standard pressure of 101.3 kPa.

• Liquid - a substance or mixture that is not a gas and which has a melting point or initial melting point of 20°C (68°F) or less at standard pressure of 101.3 kPa.

• Solid - a substance or mixture that does not meet the definitions of a liquid or a gas.

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SDS Pictograms• Provides a visual representation of the hazard

Hazard CategoriesHealth Hazard Explosion

Corrosives Toxicity

Flammable Environmental

Irritants Compressed Gas

Oxidizer16

Health Hazard

Carcinogen

Mutagenicity

Reproductive Toxicity

Respiratory Sensitizer

Target Organ Toxicity

Aspiration Toxicity 17

Corrosives

Skin Corrosion/ burns

Eye Damage

Corrosive to Metals

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Flammable

Flammables

Pyrophorics

Self-Heating

Emits Flammable Gas

Self-Reactives

Organic Peroxides19

Irritant

Irritant (skin and eye)

Skin Sensitizer

Acute Toxicity (harmful)

Narcotic Effects

Respiratory Tract Irritant

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Explosion

Explosives

Self-Reactives

Organic Peroxides

21

Toxicity

Acute Toxicity (fatal or toxic)

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Environmental

Hazardous to Ozone LayerAquatic Toxicity

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Compressed Gas

Gases under Pressure

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Oxidizer

Could yield oxygen and contribute to combustion.

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(SDS) Safety Data Sheets

• Small quantities of (household use) products purchased from retail stores do not require an SDS, unless exposure is increased and constant.

• If a supplier will not provide an SDS, they are required to tell you how to get it.

• It is good practice to carry an SDS manual in a field vehicle, but not necessary. SDS’s must be accessible to an OSHA inspector during the shift.

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(SDS) Safety Data SheetsMaterials and Chemicals that require an SDS:

Paint & Stains Brick & Block

Fuels & Lubricants Sheetrock

Solvents Compressed Gas

Pesticides, Insecticides Welding Rods

Adhesives Insulation

Cleaning Agents Treated Lumber

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Subpart Contents

• This presentation will cover the following information:– Toxic and Hazardous Substances Overview– Asbestos– Hexavalent Chromium– Lead– Mold and Mildew– Soil Contamination Management

Employee Training• Employees must be trained on every new chemical in which

they come in contact• Acute and chronic health effects• Proper handling and use• Proper storage• Clean-Up procedures• Proper disposal• Accessing information (SDS Manual)

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Job-Site Compliance• All contractors are responsible for providing SDS for the

chemicals/materials they bring to the site.• Other contractors must be made aware of potential

hazards created by chemicals/materials brought on-site.

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Common Job-Site Exposures• Sheetrock work – sanding and cutting• Lawn Maintenance and Landscaping – fertilizers and fuels• Masonry - cutting and mixing• Insulation - blown and batting, cutting or spraying installation• Fabrication or repair - compressed gas welding rods• Pest control - mixing and spraying• Carpentry – cutting, sanding, installation

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Additional OSHA Requirements

• Employers must present information in a manner and language that their employees can understand.

• Employers must communicate the training in the employee’s language.

• If the employee has a limited vocabulary or is illiterate the training must account for that.

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Hazard Communication Checklist

Inventory of Chemicals Used Match Chemicals With Exposures

Obtain all SDS Safe Work Practices for Each Chemical

Identify SDS Storage Location Employees Educated on Potential Exposures

Employees Know Location of SDS Employees Trained on Use of Material

All Containers Labeled Notify Other Contractors When Necessary

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Toxic and Hazardous Substances

• Toxic and Hazardous substances are defined as:– Chemicals present in

the workplace which are capable of causing harm.

• Includes dusts, mixtures, paints, fuels, and solvents

Compliance• Engineering Controls when

feasible• Personal Protective Equipment• Training• Hygiene Practices

– Change Rooms– Washing Facilities– Eating/Drinking Areas– Prohibited Activities

• Housekeeping• Medical Surveillance• Hazard Communication• Recordkeeping

Asbestos

• Operations where asbestos may be present– Demolition or salvage of

structures– Construction, alteration,

repair, maintenance, structural renovation

– Transportation, disposal, containment of housekeeping activities involving ACM’s

Health Effects

• Heaviest exposures are in the construction industry

• Causes two types of cancer:– Cancer of the lung tissue – Mesothelioma, a cancer of the thin membrane

that surrounds the lung • These diseases do not develop

immediately following exposure to asbestos, but appear only after a number of years.

DefinitionsAsbestos Work

– Class I• Activities involving the removal of TSI and surfacing ACM

and PACM– Class II

• Activities involving the removal of non-thermal non-surfacing ACM’s

– Example: Wallboard, floor tile and sheeting, roofing materials, mastics

– Class III• Repair and maintenance operations where ACM and/or

PACM are likely to be disturbed– Class IV

• Maintenance and custodial activities during which employees contact but do not disturb ACM or PACM, includes dust, waste and debris cleanup from Class I-III activities

Permissible Exposure Limits• Time Weighted Average (TWA)

– The employer shall ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an 8 hour time-weighted average

• Excursion Limit– The employer shall ensure that no employee is

exposed to an airborne concentration of asbestos in excess of 1.0 fiber/cc as averaged over a sampling period of 30 minutes

• Appendix A specifies collection media and procedures

Multi-Employer Worksites• Notification to all trades not associated with

abatement• Materials will be abated by controlling or

creating contractor• Employers of employees exposed to abatement

process are responsible for outfitting and educating workers

• Employers of employees adjacent to abatement operations are responsible for monitoring the worksite

Table 1 – Respiratory Protection for Asbestos Fibers

Airborne Concentrations of Asbestos

Required Respirator

≤1 fiber/cc (10 x PEL) Half-mask respo. w/ high efficiency filters

≤5 fiber/cc (50 x PEL) Full face respo. w/ high efficiency filters

≤10 fiber/cc (100 x PEL) Powered air purifying respo. w/ high eff. filters, continuous flow

≤100 fiber/cc (1,000 x PEL) Full face piece, supplied air, pressure demand mode

>100 fiber/cc (1,000 x PEL) Full face piece, supplied air, pressure demand mode + aux positive pressure

SCBA

Hexavalent Chromium• Construction standard still under

proposal• Most common exposure, stainless

steel welding operations• Permissible Exposure Limit (PEL)

< 5µg/M³ (micrograms/cubic meter)• Covers HexChrom in all forms and

compounds• Some exceptions

– Pesticides regulated by EPA– Exposures to Portland cement– Monitored data that shows

insufficient concentrations

Health Effects• Chronic exposure can lead to lung cancer• Breathing high levels of HexChrom can irritate or

damage:– nose– throat – lungs

• Irritation or damage to the eyes and skin can occur if hexavalent chromium contacts these organs in high concentrations or for a prolonged period of time.

Application• Standards do not apply to

– Workers exposed to > PEL while performing the following tasks

• Addition of Chemicals• Prep and Mixing activities• Tank Cleaning• Painting

– Employees that request a respirator– Employees required to wear respirators– Employees with exposures under PEL (1910.1000)

and those covered under a respirator program in effect 05/30/2006

Exposure Determination

• If concentrations exceed the PEL– Employer must notify affected employees in

writing– Employer must provide written description of

action to be taken to reduce exposure– Regulated areas must be marked and

restricted

Compliance

• Engineering• Work Procedures• Combination of engineering

and work procedures for large parts spraying

• Respiratory protection must comply with 1910.134

Lead• Lead overexposure is one of the most common

overexposures found in industry, a leading cause of workplace illness.

• Operations that generate lead dust and fumes include;– Flame-torch cutting– Welding– The use of heat guns– Sanding, scraping, and grinding of lead painted surfaces

• OSHA has established the reduction of lead exposure as a high strategic priority.

• Lead poisoning is the leading environmentally induced illness in children.

Health Risks• Children under six are at highest risk

– Nervous system & kidney damage– Decreased intelligence, learning disabilities, a.d.d.– Speech, language, and behavioral problems

• Pregnancy is adversely affected by lead exposure• Health effects in adults may include:

– High Blood Pressure– Fertility Problems– Digestive tract, nervous system issues– Memory and concentration problems– Sexual disorders– Muscle or joint pain

Health Effects• Adversely affects numerous body systems, causes

health impairment and disease after exposure• Periods can be as short as days (acute exposure) or as

long as several years (chronic exposure)• Frequency and severity of medical symptoms increases

with concentration of lead in the blood. • Acute poisoning symptoms include:

– Loss of appetite– Nausea, Vomiting, Stomach Pain– Insomnia– Fatigue and headaches– Death

• Long term poisoning can cause damage to:– Blood-forming systems– Nervous, urinary, and reproductive systems

Mold and Mildew

• Mold and Mildew can grow on any surface

• Paints, stains, and water repellants are susceptible

• Material generates via airborne spores

Health Effects

• Severe allergic reaction• Skin irritation• Flu-like symptoms

The Four Requirements for Mold and Mildew

AirTemperatures

between 34°-104°FMoisture with a

relative humidity of +/- 70%

Food source (organic material)

Prevention Methods

• Properly install insulation without gaps, folds, voids, or compression.

• Use materials like Tyvek to create tighter walls.

• Use polyethylene to control moisture in dark, tight, and cool areas.

• Insure that all areas containing warm moist air are properly ventilated.

• Control water intrusion.

Soil Contamination Management

Regulatory Legislation• Federal

– EPA• Environmental Protection Agency, the federal regulatory agency for

environmental standards– RCRA

• Resources Conservation and Recovery Act, covers hazardous waste generation, transportation, treatment, storage and disposal

– CERCLA• Comprehensive Environmental Response, Compensation and Liability Act;

aka the “Superfund”– SARA

• Superfund Amendments Reauthorization Act, requires reporting of hazardous material releases, emergency planning, community right-to-know

• State– ADEM

• Alabama Department of Environmental Management• Most closely follow EPA’s standards, exceed them on some components of

HazMat

Hazardous Waste• Characteristics

– Ignitability• Has flashpoint less than 140°F

– Corrosivity• Possesses corrosion properties in natural state

– Reactivity• Susceptible to heat, shock, decomposition, other

materials– Toxicity

• Presents specific biological harm in certain quantities

Four key factors of Abatement

•Containment•Reporting•Clean-up•Disposal

Containment

• Napkins• Berms• Pads• Pans• Pillows• Diking for fixed

locations

Reporting• Any spill on land in excess of 25 gallons is

reportable• Any release of petroleum into water is

reportable• Emergency Management Association

(State) 334-263-7594

• National Response Center 800-424-8802

Clean-Up• No quantity is too small for

clean-up• Soil must be excavated

completely• Transferred to suitable

containers for transport• Stockpiling avoided if possible• Proper personal protective

equipment if needed for abatement procedures

• Regular monitoring of soil depending on contaminant

Disposal

• Material must be disposed of in accordance with the rules and regulations of federal and state agencies

• ADEM– Office of General Council; (334)-271-7977– (http://www.adem.state.al.us/)

Potential Spill Exposures

• Fuel dispensing areas• Maintenance areas• Equipment Failure• Improper Storage vessels

– Drums– Buckets– Unapproved containers

Lead Safe Work Practices

Renovation - Repair - Painting

OSHA 10 Hour Supplemental

Toxic and Hazardous Substances

Definition

• Lead based paint is defined as:– Any paint or surface coatings that contain

lead equal to or in excess of 1.0 mg/cm(milligrams per square centimeter) or more than 0.5 % by weight.

• State and local health departments must have a standard that meets or exceeds federal guidelines.

• Lead-based paint was banned in 1978.

Regulations - EPA• EPA – Environmental Protection Agency• Establishes training requirements for people involved in

lead abatement• Abatement includes:

– Removal of paint and dust– Permanent enclosure or encapsulation – Replacement of painted surfaces or fixtures– Removal or permanent covering of soil– Cleanup, Disposal, Post abatement testing

• Abatement does not include:– Renovation– Remodeling– Landscaping

Regulations - HUD

• HUD – Housing and Urban Development• Specifies what actions are required to

address lead hazards• Employs state and local grant programs to

fund lead hazard reduction activities

Regulations - OSHA

• OSHA – Occupational Safety & Health Administration

• Code of Federal Regulations 1926.62 specifies worker protection requirements– Personal protective equipment– Safe work procedures– Recordkeeping

The RRP Rule• RRP – Renovation, Repair, and Painting• Addresses activities that disturb lead-based

paint for:– Target Housing– Child Occupied Facilities

• On or after April 22, 2010 firms working in pre-1978 homes and child occupied facilities must be certified and use lead-safe work practices during renovations.

• Deadline has been extended to Oct 1.

Definitions• Target Housing - A home or residential unit built

on or before December 31, 1977– Housing designated for the elderly or persons with

disabilities is an exception– Any zero bedroom dwellings are an exception

• Child Occupied Facility - A pre 1978 building that meets all three of the following criteria– Visited regularly by the same child under 6 years of

age– The visits are on at least two different days within any

week provided that each days visit lasts at least three hours

– Combined weekly visits last at least 6 hours and the combined annual visits last at least 60 hours

RRP Exclusions

• Renovation activities where affected components do not contain lead-based paint

• Emergency renovations– Elevated blood lead levels in residents– Natural disaster - tree fall, flood, etc.

• Renovations performed by homeowners in there own homes

• Minor repair and maintenance activities

Minor Repair and Maintenance Activities

• This exclusion does not apply to window replacement, demolition, or activities involving prohibited practices.

• Interior work disturbing less than 6 ft² per room of painted surface

• Exterior work disturbing less than 20 ft² per side of painted surface.

• Cleanup and cleaning verification are not required after minor repair and maintenance activities unless they involve window replacement, demolition, or prohibited practices.

RRP Certification• As of 04/22/2010 all covered renovations must

be performed by certified firms.• Must use certified renovators and other trained

workers.• Certification requires:

– Application submittal– $300 fee paid to EPA

• Certifications are valid for 5 years• Certification allows the firm to perform

renovations in any non-authorized state.

RRP Firm Responsibilities

• Ensure compliance with RRP Rule• Ensure all renovation personnel are

Certified Renovators or have been trained on-the-job by Certified Renovators

• Assign a Certified Renovator to all jobs• Meet pre-renovation education

requirements• Meet recordkeeping requirements

Certified Renovator Requirements

• An individual must complete a EPA approved 8 hour training course from an EPA accredited trainer

• Participants are given a course completion certificate

• Refresher training is required every 5 years• Workers do not need certification as long as on-

the-job training is handled by a Certified Renovator and the work is not regulated by HUD

Certified Renovator Responsibilities

• Perform work and direct lead-safe work practices.• Provide on-the-job training to non-certified workers. • If non-certified workers are trained and documented,

certified renovator does not have to be on site.• Keep a copy of the initial and/or refresher training

certificates onsite.• Use EPA-recognized test kits to identify lead-based paint• Must be present while posting signs, containing work

areas, and cleaning work area.

Certified Renovator Responsibilities

• Must be available via telephone while off-site.

• Maintain the containment to keep dust and debris within the work area.

• Implement the cleaning verification procedure.

• Prepare and maintain required records.

RRP Enforcement

• EPA may suspend, revoke, or modify a firm’s certification if the Certified Renovator is found to be in non-compliance.

• Civil penalties can be as high as $32,500 for each violation.

• Firms who knowingly or willfully violate can be penalized as much as $32,500 per violation plus imprisonment.

HUD Lead Safe Housing Rule

• Covers federally owned or assisted Target Housing and federally owned target housing sales.

• Renovator must determine if occupant is federally assisted.

• HUD has evaluation and control requirements based on type of assistance.

HUD Lead Safe Housing Rule

• Requires lead safe work practices for the following procedures:– Paint stabilization– Interim control of lead-based paint hazards– Renovation– Standard treatments– Ongoing lead-based paint maintenance

HUD Lead Safe Housing Rule• Training requirements mirror those of the EPA Certified

Renovator• Only a certified inspector can determine whether lead-

based paint is present.• HUD prohibits the same practices as EPA RRP plus

three more:– Heat guns that char paint– Dry scraping or sanding except within 1 ft of electrical outlets– Use of volatile strippers in areas of poor ventilation

• HUD has a smaller interior repair and maintenance activity threshold than EPA– From 6 ft² per room of painted surface to 2 ft² per room of

painted surface

HUD Lead Safe Housing Rule• Clearance testing must be completed by a party

independent of the renovator• Clearance test must be conducted by:

– Lead Inspector– Lead Risk Assessor– Duct Sampling Technician

• Notices must be distributed to occupants within 15 days after lead based paint hazards have been identified.

• And 15 days after completion of hazard completion work.

Testing for Lead-Based Paint

• Lead-based paint can only be identified by testing

• The results of the test must be covered in a lead test report

• Property owner can provide a report from a Certified Lead Inspector that proves no lead-based paint is present in lieu of surface testing

Testing for Lead-Based Paint• Testing Options

– Paint Chip Collection for Laboratory• Intrusive collection method, requires sample of all layers• Sent to EPA recognized lab for analysis• Must be collected by Certified Lead Inspector

– X-Ray Fluorescence Testing• Non intrusive method, provides instant result• Instrument analyzes surface with radiation• Must be analyzed by Certified Lead Inspector

– EPA Recognized Test Kits• Non intrusive method, provides instant result• Chemicals are applied to surface• Material changes color if lead is present• For info on recognized test kits go to www.epa.gov/lead