Hazard Communication

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Hazard Communication

• MODULE 11

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Purpose of OSHAs 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.

Hazard Communication Program
Container Labeling
Material Safety Data Sheet
Label
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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 employers 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