Protecting Employees from Workplace HazardsOSHA Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories

Introduction Presenter - Colleen Cunanan, AKOSH

Industrial Hygienist

Purpose – familiarize you with OSHA’s Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories Standards [CFR 1910.1200 & 1910.1450]

Overview Hazard Communication Standard (HCS)

2012 standard revision to incorporate the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

Requirements of the standard

Occupational Exposure to Hazardous Chemicals in Laboratories Standard (Lab Standard) Requirements of the standard

Comparison of the Lab Standard to HCS

OSHA’s Hazard Communication Standard29 CFR 1910.1200

What is Hazard Communication? OSHA Hazard Communication Standard 29

CFR 1910.1200 – “Right to Know” went into effect in November 1985

The purpose of Hazcom is to communicate workplace chemical hazards and appropriate protective measures to employees

Employees have a Right to Know about the hazards in their work areas and the potential effects of these hazards upon their health and safety

What is Global Harmonization? A common and coherent approach to

defining and classifying hazards, and communicating information on labels and safety data sheets

Provides the underlying infrastructure for establishing a national, comprehensive chemical safety program

How will Global Harmonization help? Improve comprehensiveness

Improve consistency

Improve understanding

Changes to HCS Hazard Classification

Labels

Safety Data Sheets

Timeline for ComplianceEffective Completion Date Requirement(s) Who

December 1, 2013 Train employees on the new label elements and safety data sheet

(SDS) format.

Employers

June 1, 2015*

December 1, 2015

Compliance with all modified provisions of this final rule,

except:The Distributor shall not ship

containers labeled by the chemical manufacturer or

importer unless it is a GHS label

Chemical manufacturers, importers, distributors and

employers

June 1, 2016 Update alternative workplace labeling and hazard

communication program as necessary, and provide additional

employee training for newly identified physical or health

hazards.

Employers

Transition Period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard), or

the current standard, or both

Chemical manufacturers, importers, distributors, and

employers

Key Elements of the Hazard Communication Standard (HCS) Written Program – must be developed and tie

all the following elements together

Training - all employees must be trained to identify and work safely with hazardous materials

Labeling - containers of hazardous materials must have labels which identify the material and warn of its potential hazard to employees

Safety Data Sheets (SDSs) - detailed description of each hazardous material present in the workplace

HCS Written Program Information and training the employee will

receive regarding workplace hazards Labeling and other forms of warning utilized in

the workplace Maintenance of SDSs for every chemical Chemical inventory Methods the employer uses to inform employees

of hazards of non-routine tasks and hazards of chemicals in unlabeled pipes in work areas

Methods of communicating hazards to other employers (contractors)

Additional Alaska Requirements Chemical inventory with locations

Physical Agent Data Sheets (PADs)

Table Z-1-AExample - Acetone

Fed PEL – TWA 1000 ppm AK PEL – TWA 750 ppm, STEL 1000 ppm

HCS Training RequirementsEmployee training is an integral part of the hazard communication program and must be provided:

At the time of initial assignment Whenever a new hazard is introduced into the workplace, and When employees may be exposed to other employers’

workplace hazards

Hazard Communication – Site specific training Details of employer’s Hazcom program Specific hazards in the workplace Methods to detect presence or release of a hazardous

chemical Methods to reduce hazards - product substitution, engineering

controls, administrative controls, and personal protective equipment

Training – Non-routine TasksPrior to starting work on such projects, affected employees will be given information on hazards to which they may be exposed during such activity

This information will cover:Specific hazardsMeasures the employer has taken to reduce the risk of these hazardsRequired protective/safety measures

Labels Warn of potential hazards

Not intended to be the only source of information

Serve as an immediate warning

What must be labeled? The OSHA Hazard Communication

Standard requires that ALL hazardous materials be labeled. Labels must appear either on the container itself, a batch ticket, placard, or process sheets

Hazardous chemicals in portable containers which are for the immediate use of the employee who performs the transfer is the exception to this rule

Manufacturer/Importer Label Requirements Product identifier Signal word Hazard statement Pictograms Precautionary statements Name, address, and phone number of

responsible party

GHS Pictograms and HazardsHealth Hazard Flame Exclamation

Mark

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

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

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

GHS Pictograms and HazardsGas Cylinder Corrosion Exploding Bomb

• Gases under Pressure

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

• Explosives• Self-Reactives• Organic Peroxides

GHS Pictograms and HazardsFlame Over

CircleSkull &

CrossbonesEnvironment

(Non-mandatory)

• Oxidizers • Acute Toxicity (fatal or toxic)

• Aquatic Toxicity

GHS Compliant Label

Workplace Labeling Standard is “performance based” –

allows flexibility in labeling system Employers may use NFPA, HMIS, or

duplicate the shipped label (GHS)

Workplace LabelingMust include:

Product identifier – must match SDS and chemical inventory

Words, pictures, symbols or combination of these that will provide employees with specific information regarding the physical and health hazards

Workplace LabelingEnsure labels are not removed, defaced, or unreadable

For hard to label containers use:

Signs or placards Process sheets or

batch tickets

Safety Data Sheets (SDSs) Formerly referred to as Material Safety Data Sheets

(MSDSs)

SDSs provide detailed health and safety information and precautions for handling hazardous substances, including emergency and first aid procedures

Employer must have a SDS for each hazardous chemical in the workplace and ensure SDSs are accessible to all employees

SDS Requirements

HCS requires a standardized 16 section format1. Identification2. Hazard(s) Identification3. Composition/information on ingredients4. First-aid measures5. Fire-fighting measures6. Accidental release measures7. Handling and storage8. Exposure controls/personal protection

9. Physical and chemical properties10. Stability and reactivity 11. Toxicological information12. Ecological information13. Disposal considerations14. Transport information15. Regulatory information16. Other information

PADs – Alaska Requirement Cold Stress Hand-Arm Vibration Heat Stress Ionizing Radiation Lasers Noise Radio Frequency/Microwave Radiation Ultraviolet Radiation

OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories29 CFR 1910.1450

Key Elements of the Lab Standard Scope – laboratory use of chemicals; supersedes other

subpart Z requirements except: PEL limitations Skin and eye contact prohibition Monitoring/medical surveillance requirements

Written chemical hygiene plan – defines how employees will be protected and exposures will be kept below PELs

Training – all employees must be trained on chemical hazards

Medical consultation and examinations – provided free to employee by licensed physician under certain circumstances

Hazard identification – labels and SDSs

What is “laboratory use” of chemicals?1) Chemical manipulations are carried out on a

“laboratory scale”;2) Multiple chemical procedures or chemicals are

used;3) Procedures involved are not part of a

production process, nor in any way simulate a production process; and

4) “Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals.

Written Chemical Hygiene Plan (CHP)

Must be:Capable of protecting employees from health hazards associated with hazardous chemicals in laboratoryCapable of keeping exposures below PELsReadily available to all employees

Required CHP Elements SOPs for work involving use of hazardous

chemicals Criteria to determine and implement

control measures to reduce employee exposure

Requirement that fume hoods and other protective equipment are functioning properly and measures taken to ensure adequate performance of such equipment

Required CHP Elements Provisions for training and information Procedures requiring prior approval Provisions for medical consultation and

examination Responsible personnel – Chemical

Hygiene Officer Provisions for additional employee

protection when working with particularly hazardous substances

Lab Standard Information and Training Requirements Employees must be apprised of hazards

of chemicals present in their work areas

Must be provided at time of initial assignment and prior to assignment involving new exposure situation

Lab Standard Information and Training RequirementsEmployees must be informed of:

Contents of 1910.1450 and appendices Location of employer’s CHP PELs Signs and symptoms of exposure to

chemicals in the laboratory Location of reference materials such as

SDSs

Lab Standard Information and Training RequirementsEmployee training must include:

Methods and observations that may be used to detect presence or release of hazardous chemical

Physical and health hazards of chemicals in the work area

Measures employees can take to protect themselves such as appropriate work practices, emergency procedures, and personal protective equipment (PPE)

Medical Consultation and Examinations Opportunity shall be provided when:

Signs/symptoms shown Monitoring indicates need An “event” results in likelihood of exposure

Shall be followed by Dr’s written opinion Requires the employer provide info to Dr Shall be:

At no cost to employee Provided by a licensed physician

Hazard Identification Labels on incoming containers shall not

be removed or defaced

SDSs received with incoming shipments of hazardous chemicals must be maintained and be made readily accessible

Hazard IdentificationChemicals developed in lab:If composition is known, employer must determine if it is hazardous and provide appropriate trainingIf composition is unknown (e.g. a byproduct) employer will assume it is hazardous If produced for outside user, employer must comply with HCS – SDS and labeling requirements

Differences from HCS SDS requirements Chemical inventory requirement Lab Standard supersedes other regs Annual review of CHP Medical evaluations Chemical Hygiene Officer Monitoring requirements

Similarities to HCS Same objective

Same definitions

Written program

Training and information requirements

Questions?