Hazard Communication Emergency Response

1. Hazard CommunicationEmergency Response WSHSC July 31, 2009

2. Employer Chemical Hazard Communication WAC 296-800-170 �HazCom� Four Major Parts: MSDS Labeling Training Written Program

3. Hazard Communication Employees have the right to know about hazardous chemicals at their worksite: What the chemicals are, What are the hazards, How to protect themselves. Now we�ll focus on the hazard communication rule in the Core Rules. The purpose of the rule is to make sure that employees understand the hazards of the chemicals they are working with, so they can protect themselves and prevent injuries or illness. Hazard Communication is often called �Hazcom� and I will use that term today.Now we�ll focus on the hazard communication rule in the Core Rules. The purpose of the rule is to make sure that employees understand the hazards of the chemicals they are working with, so they can protect themselves and prevent injuries or illness. Hazard Communication is often called �Hazcom� and I will use that term today.

4. This training will cover What are hazardous chemicals Exemptions MSDSs Labeling Training Written Program

5. What are hazardous chemicals? "Hazardous Chemical" is a term that is broadly used in the hazard communication rule. A hazardous chemical includes: solvents glues paints products that may release a hazardous chemical.

6. What are hazardous chemicals? Flammables cause thermal burns or death Corrosives cause chemical burns to skin, eyes or lungs Toxics cause reversible or permanent effects to internal organs or whole body So what is a hazardous chemical? Flammables include many solvents. Corrosives include strong acids and bases or caustics. Toxic chemicals cause a variety of adverse health effects. Nearly all chemicals are toxic at some level and because of that nearly all chemicals used at work are considered hazardous. So what is a hazardous chemical? Flammables include many solvents. Corrosives include strong acids and bases or caustics. Toxic chemicals cause a variety of adverse health effects. Nearly all chemicals are toxic at some level and because of that nearly all chemicals used at work are considered hazardous.

7. What are hazardous chemicals? Sensitizers cause allergic response from repeated doses. Irritants cause reversible effects. Carcinogens cause cancer usually over a long time. Sensitizers cause an allergic type reaction, some common sensitizers include isocyanates in automotive paints and truck bed liners which cause asthma attacks in susceptible people. Irritants cause reversible effects, like reddening or a burning sensation of the skin or eyes, or coughing. � Weak acids, some solvents etc. can be irritants. Some products are so irritating, they may affect work or distract the worker so much he or she have an accident, even though no permanent damage from the chemical occurs. Example: low levels of ammonia. Carcinogens are not usually found in most workplaces � employers tend not to use products labeled �carcinogens� even though they may smoke cigarettes. An example of carcinogen include the solvent benzene which is known to cause leukemia in humans and asbestos which causes lung cancer and cancer of the lining of the lung. Sensitizers cause an allergic type reaction, some common sensitizers include isocyanates in automotive paints and truck bed liners which cause asthma attacks in susceptible people. Irritants cause reversible effects, like reddening or a burning sensation of the skin or eyes, or coughing. � Weak acids, some solvents etc. can be irritants. Some products are so irritating, they may affect work or distract the worker so much he or she have an accident, even though no permanent damage from the chemical occurs. Example: low levels of ammonia. Carcinogens are not usually found in most workplaces � employers tend not to use products labeled �carcinogens� even though they may smoke cigarettes. An example of carcinogen include the solvent benzene which is known to cause leukemia in humans and asbestos which causes lung cancer and cancer of the lining of the lung.

8. What are hazardous chemicals? Generally if an item is regulated by another federal rule it is not covered by hazard communication. The following slides present items that may be exempted from the rule; please see WAC 296-800-17055 for the specific exemptions.

9. Exempted items � not covered Hazardous waste Articles (solid objects) Most drugs Food and alcoholic beverages Main purpose for exemptions is to avoid duplicate coverage with other federal rules or agencies Consumer products used as you would use them at home are exempt, other uses are not. The consumer product exemption is based largely on how the compound is being used. Are the workers using the same amount for about the same time as a consumer? For example a worker who cleans a computer screen every once in a while wouldn�t be covered, but if that worker�s job was to clean everyone�s computer screen he would be covered. Main purpose for exemptions is to avoid duplicate coverage with other federal rules or agencies Consumer products used as you would use them at home are exempt, other uses are not. The consumer product exemption is based largely on how the compound is being used. Are the workers using the same amount for about the same time as a consumer? For example a worker who cleans a computer screen every once in a while wouldn�t be covered, but if that worker�s job was to clean everyone�s computer screen he would be covered.

10. Exempted items � not covered Consumer products used as you would use them at home are exempt, other uses are not. The consumer product exemption is based largely on how the compound is being used. Are the workers using the same amount for about the same time as a consumer? For example a worker who cleans a computer screen every once in a while wouldn�t be covered, but if that worker�s job was to clean everyone�s computer screen he would be covered. Consumer products used as you would use them at home are exempt, other uses are not. The consumer product exemption is based largely on how the compound is being used. Are the workers using the same amount for about the same time as a consumer? For example a worker who cleans a computer screen every once in a while wouldn�t be covered, but if that worker�s job was to clean everyone�s computer screen he would be covered.

11. Articles � when they are & are not covered When an item is used in a way that releases a hazardous chemical, it is covered by the rule.When an item is used in a way that releases a hazardous chemical, it is covered by the rule.

12. HazCom Breakdown

13. [see following slides which outline information found on this MSDS.][see following slides which outline information found on this MSDS.]

14. Names of hazardous chemicals in a product, Physical and chemical properties of the product, Physical hazards of working with the product, Short and long term health hazards of working with the product (including signs and symptoms of overexposures), [optional slide � you can print out the previous slide or use your own MSDS sheets, and go over it section by section with your employees. The information in red on the right is from the previous MSDS slide.][optional slide � you can print out the previous slide or use your own MSDS sheets, and go over it section by section with your employees. The information in red on the right is from the previous MSDS slide.]

15. Material Safety Data Sheet [optional slide][optional slide]

16. Material Safety Data Sheet [optional slide][optional slide]

17. Trade Secrets Manufacturer can withhold name of specific chemicals in a product Hazard information must still be disclosed in MSDS In emergencies name of chemical must be disclosed for medical treatment Disclosure also required if written request made for certain purposes

18. Labels Chemicals Labeled with the Following: Identity of hazardous chemical Hazard warnings including health effects

19. Labels Labels NOT required if the product: Will be used in same work shift Is used by person who did the transfer Is under the control of the person who did the transfer There is one case where a container does not need to be labeled. When a worker puts the compound into a container, he is the only one using the container and he never loses sight or control of the container it doesn�t have to be labeled. This is a fairly rare situation, but can happen in places where chemicals are routinely handled.There is one case where a container does not need to be labeled. When a worker puts the compound into a container, he is the only one using the container and he never loses sight or control of the container it doesn�t have to be labeled. This is a fairly rare situation, but can happen in places where chemicals are routinely handled.

20. Training What hazardous chemicals are used in the work area How to work safely with these chemicals How the employee can tell if he or she is being overexposed What information is available in a material safety data sheet (MSDS) Where to find MSDSs in the work area Information on the requirements of the Employer Chemical Hazard Communication Rule

21. Training and Information Engineering controls, such as exhaust ventilation. Work practices Emergency Procedures Personal Protective equipment, such as splash resistant goggles, gloves or chemical resistant clothing. The labeling system you use to quickly tell workers about the chemical, physical and health hazards of the compound. How to find information on the hazards in the material safety data sheet or label. Engineering controls, such as exhaust ventilation. Work practices Emergency Procedures Personal Protective equipment, such as splash resistant goggles, gloves or chemical resistant clothing. The labeling system you use to quickly tell workers about the chemical, physical and health hazards of the compound. How to find information on the hazards in the material safety data sheet or label.

22. Employees must be trained on the methods used to detect the presence or release of hazardous chemicals in the work area. Air monitoring Continuous monitoring devices The visual appearance or odor of the chemical The physical and health hazards of the hazardous chemical Air monitoring such as personal exposure monitoring conducted by your company. Continuous monitoring devices, these monitors may be connected to alarms. The visual appearance or odor of the hazardous chemical The physical and health hazards of the hazardous chemical; including the likely symptoms from an over-exposure. Air monitoring such as personal exposure monitoring conducted by your company. Continuous monitoring devices, these monitors may be connected to alarms. The visual appearance or odor of the hazardous chemical The physical and health hazards of the hazardous chemical; including the likely symptoms from an over-exposure.

23. Hazard Communication Program Identify hazardous chemicals and make a list Obtain MSDSs for each product Make MSDSs easily accessible Ensure containers are labeled Develop a written program Ensure effective training Almost every employer needs to develop a complete hazard communication program that includes the following elements: A written program that is specific to their work site. They need to identify all the hazardous chemicals and create a list or inventory They need to get MSDSs for each of the hazardous chemical/product identified. Every container needs to be labeled, including secondary containers. All employees need to be trained on the hazardous chemicals in their work are and on the company�s hazard communication program.Almost every employer needs to develop a complete hazard communication program that includes the following elements: A written program that is specific to their work site. They need to identify all the hazardous chemicals and create a list or inventory They need to get MSDSs for each of the hazardous chemical/product identified. Every container needs to be labeled, including secondary containers. All employees need to be trained on the hazardous chemicals in their work are and on the company�s hazard communication program.

24. Hazard Communication - Special Situation If only sealed containers are handled: No written program required Keep MSDSs if received Existing labels must be intact Spill or leak response training required There is a special situation under hazard communication where the employer only needs a minimal program, the handling of sealed containers such as in a warehouse, distribution center or retail store like garden or hardware stores. In these cases, no written program is needed, they only need to keep MSDSs if they come with the shipment or if an employee asks for one. They have to make sure that existing labels remain intact. The employees must be trained on how to respond to spills or leaks.There is a special situation under hazard communication where the employer only needs a minimal program, the handling of sealed containers such as in a warehouse, distribution center or retail store like garden or hardware stores. In these cases, no written program is needed, they only need to keep MSDSs if they come with the shipment or if an employee asks for one. They have to make sure that existing labels remain intact. The employees must be trained on how to respond to spills or leaks.

25. Hazard Communication - Written program Tailored to the worksite List of hazardous chemicals Labeling MSDSs Training Non-routine tasks Multi-employer worksites (if needed) The written program must be specific to the worksite, it has to cover routine and non-routine tasks, and multi-employer worksites if needed.The written program must be specific to the worksite, it has to cover routine and non-routine tasks, and multi-employer worksites if needed.

26. HazCom � Multi-employer Worksites Several employers at one site More than one employers� employees are visiting/working Mutual responsibility to share information Not just construction sites (janitorial, pest control, maintenance contractors) When there are several employers at a single work site, they need to share information on their haz-com programs including MSDSs, labeling systems. While the most common multi employer work site is a construction job it isn�t limited to this. Other examples include janitorial services � would have to share MSDSs on the cleaning products, and get MSDSs from their clients. Other examples could be pest control companies, or maintenance contractors.When there are several employers at a single work site, they need to share information on their haz-com programs including MSDSs, labeling systems. While the most common multi employer work site is a construction job it isn�t limited to this. Other examples include janitorial services � would have to share MSDSs on the cleaning products, and get MSDSs from their clients. Other examples could be pest control companies, or maintenance contractors.

27. Emergency Response (WAC 296-824) Again, this is a vertical standard, that has a specific �entry point� for coverage. Basically, if a facility processes, uses, or stores hazardous substances (see 824-800) and employees don�t evacuate during a uncontrolled release, or a certain number evacuate and other stay back to stop or control the release, then chances are this code requirement kicks in. Again, this is a vertical standard, that has a specific �entry point� for coverage. Basically, if a facility processes, uses, or stores hazardous substances (see 824-800) and employees don�t evacuate during a uncontrolled release, or a certain number evacuate and other stay back to stop or control the release, then chances are this code requirement kicks in.

28. The code contains a useful table at the beginning to assist you in determining coverage for a particular employer. Note the reference to the emergency action plan requirements of 24-567.The code contains a useful table at the beginning to assist you in determining coverage for a particular employer. Note the reference to the emergency action plan requirements of 24-567.

29. Emergency Response A response to an anticipated release of a hazardous substance that is, or could become, an uncontrolled release OK. This puts us a little closer, but we need to define �hazardous substance� and �uncontrolled release�.OK. This puts us a little closer, but we need to define �hazardous substance� and �uncontrolled release�.

30. Hazardous Substance Any biological, radiological, or chemical substance that can have adverse effects on humans (see WAC 296-824-800 for a more specific definition). As you can see this is a broad definition that potentially covers a lot of substances. TIP: Take a look at the definition in WAC 296-824-800 and you�ll see that it�s very broad and potentially covers a wide range of substances.As you can see this is a broad definition that potentially covers a lot of substances. TIP: Take a look at the definition in WAC 296-824-800 and you�ll see that it�s very broad and potentially covers a wide range of substances.

31. Uncontrolled Release A release where significant safety and health risks could be created. Releases of hazardous substances that are either incidental or couldn't create a safety or health hazard (i.e., fire, explosion, or chemical exposure) aren't considered to be uncontrolled releases. The person making this assessment needs to consider a variety of potential factors when making this determination. There�s a whole range of �spill� type scenarios. It�s relatively easy to make this determination if you have a large inventory of chemicals such as chlorine or ammonia, and then becomes progressively more difficult to make a case as you move down the scale. The person making this assessment needs to consider a variety of potential factors when making this determination. There�s a whole range of �spill� type scenarios. It�s relatively easy to make this determination if you have a large inventory of chemicals such as chlorine or ammonia, and then becomes progressively more difficult to make a case as you move down the scale.

32. Incidental Release A release that can be safely controlled at the time of the release and does not have the potential to become an uncontrolled release. The line between what would be considered �incidental� and that which could be characterized as �uncontrolled� is not well defined and requires careful evaluation on a case by case basis. This covers a lot of territory and potential situations. A reasonable assessment needs to be made. The line between what would be considered �incidental� and that which could be characterized as �uncontrolled� is not well defined and requires careful evaluation on a case by case basis. This covers a lot of territory and potential situations. A reasonable assessment needs to be made.

33. Danger Area Areas where conditions pose a serious danger to employees, such as areas where: Immediately dangerous to life or health (IDLH) conditions could exist High levels of exposure to toxic substances could exist There is a potential for exceeding the lower explosive limit (LEL), also known as the lower flammability limit (LFL), of a substance. A reasonable assessment of potential danger areas can be made by reviewing chemical data and assessing the configuration of the work area. Try and establish where employees may need to go to conduct some task or operation during an uncontrolled release. For instance, to control an ammonia release, does the operator need to go into the engine room and close critical valves?A reasonable assessment of potential danger areas can be made by reviewing chemical data and assessing the configuration of the work area. Try and establish where employees may need to go to conduct some task or operation during an uncontrolled release. For instance, to control an ammonia release, does the operator need to go into the engine room and close critical valves?

34. IDLH Any atmospheric condition that would: Cause an immediate threat to life Cause permanent or delayed adverse health effects Interfere with an employee's ability to escape Look for chemicals in the facility that are used, and try to make an assessment as to which ones could pose the greatest health hazard. Remember, a liter of a highly volatile and flammable liquid may not necessarily be characterized as potentially IDLH outside, however, the same quantity spilled inside of a storage room may. The NIOSH Pocket guide publishes IDLH values. Our directive requires us to use the 1990 version for compliance activities.Look for chemicals in the facility that are used, and try to make an assessment as to which ones could pose the greatest health hazard. Remember, a liter of a highly volatile and flammable liquid may not necessarily be characterized as potentially IDLH outside, however, the same quantity spilled inside of a storage room may. The NIOSH Pocket guide publishes IDLH values. Our directive requires us to use the 1990 version for compliance activities.

35. Limited Action Action necessary to: Secure an operation during emergency responsesor Prevent an incident from increasing in severity. Examples include shutting down processes and closing emergency valves. It may not be readily apparent what if any �limited actions� employees might take. Ask employees that operate the system(s) or work in the facility. Look at operating instructions and see if they define certain tasks or operations that must be carried out by some individual prior to evacuation. Have they had any prior events? Who evacuated? Who didn�t? Why? Ok, so these are the definitions that help us define whether employers are obligated to comply with the Emergency Response standard.It may not be readily apparent what if any �limited actions� employees might take. Ask employees that operate the system(s) or work in the facility. Look at operating instructions and see if they define certain tasks or operations that must be carried out by some individual prior to evacuation. Have they had any prior events? Who evacuated? Who didn�t? Why? Ok, so these are the definitions that help us define whether employers are obligated to comply with the Emergency Response standard.

37. The code contains a useful table at the beginning to assist you in determining coverage for a particular employer. Note the reference to the emergency action plan requirements of 24-567.The code contains a useful table at the beginning to assist you in determining coverage for a particular employer. Note the reference to the emergency action plan requirements of 24-567.

38. NIOSH Pocket Guide to Chemical Hazards IDLH of Formaldehyde is 20 ppm Formaldehyde has a low vapor pressure Dependant on size of room, ventilation rate, and surface area of the spill

39. Basic Requirements Written Emergency Response Plan Training Responders Medical Surveillance Recordkeeping Management of Emergency Operations Incident Command Personnel Briefing Here�s a listing of the basic requirements or elements of the Emergency Response code. As with most of the WISHA standards there�s a written program requirement. In this case a written Emergency Response Plan that describes in detail the standard operating procedures necessary to safety respond to uncontrolled release. The written plan provides information and resources as well as procedural information. There are approximately (8) required elements for a written Emergency Response Plan which basically describe in detail these code elements. Here�s a listing of the basic requirements or elements of the Emergency Response code. As with most of the WISHA standards there�s a written program requirement. In this case a written Emergency Response Plan that describes in detail the standard operating procedures necessary to safety respond to uncontrolled release. The written plan provides information and resources as well as procedural information. There are approximately (8) required elements for a written Emergency Response Plan which basically describe in detail these code elements.

40. Basic Requirements, Cont.. Buddy System = 2 In and 2 Out Rescue and Medical Assistance Personal Protective Equipment Post Emergency Response Operations

41. Common Findings No plans There doesn�t appear to be any clear roles or assigned duties. Responders have not received adequate training No procedures for limited actions Personal Protective Equipment No Command Structure These are some of the common problems you will likely encounter in the field: You determine that the employer is covered by the standard, but they have nothing (better sharpen your pencil). These actually provide you an opportunity to assist the employer in developing a good plan. These are the �every man for himself� type response actions. A bit chaotic to say the least. The standard is quite specific once you (or they) have established what role or duties employees have during emergency response actions. Once that�s established, there�s an obligation to train to that level (and document it). Employees that do not evacuate because they need to perform some �shut down� or securing type activity need to have some procedural guidelines to follow. For instance, if specific equipment needs to be isolated, shut down, or some other activity performed, these activities need to be clearly and concisely spelled out. Key pieces of equipment should be clearly marked and identifiable. These range from employees with no PPE, to employees getting it partially right, but maybe responding in the wrong type of respiratory protection, or possibly wearing the wrong chemical cartridge. Another common PPE finding is where one responder is totally decked out in appropriate gear, but his partner standing directly next to him is in street clothes. Definitely a problem. These are usually included with the �every man for himself� type response activities mentioned previously. Nobody seems to be in charge, calling the shots, and making key (many times safety critical) decisions. These are some of the common problems you will likely encounter in the field: You determine that the employer is covered by the standard, but they have nothing (better sharpen your pencil). These actually provide you an opportunity to assist the employer in developing a good plan. These are the �every man for himself� type response actions. A bit chaotic to say the least. The standard is quite specific once you (or they) have established what role or duties employees have during emergency response actions. Once that�s established, there�s an obligation to train to that level (and document it). Employees that do not evacuate because they need to perform some �shut down� or securing type activity need to have some procedural guidelines to follow. For instance, if specific equipment needs to be isolated, shut down, or some other activity performed, these activities need to be clearly and concisely spelled out. Key pieces of equipment should be clearly marked and identifiable. These range from employees with no PPE, to employees getting it partially right, but maybe responding in the wrong type of respiratory protection, or possibly wearing the wrong chemical cartridge. Another common PPE finding is where one responder is totally decked out in appropriate gear, but his partner standing directly next to him is in street clothes. Definitely a problem. These are usually included with the �every man for himself� type response activities mentioned previously. Nobody seems to be in charge, calling the shots, and making key (many times safety critical) decisions.

42. Key Questions Are employees expected to participate in an emergency response? Is the facility covered by community emergency response plan?

43. Key Points Emergency response is not defined by the quantity of hazardous substance or the level of PPE. It depends on the danger and the safety and health risk the release may pose to employees.

44. Key Points The level of training depends on the role employees will be expected to play in the event of an emergency response.

45. Key Points All emergency response personnel must receive annual refresher training.

46. Key Points The emergency response planning and procedures is to be based on the worst case scenarios.

47. Key Points Selection of PPE is to be based on the worst case scenarios.

48. Key Points The emergency response plan and procedures is to be site specific.

49. Compliance Issues/Recommendations Use Small Containers of Formaldehyde Prefilled containers for Specimens Proper Amount of Absorbent MSDS for concentration used Clearly Define Roles for a Spill Who responds, who evacuates

50. Compliance Issues/Recommendations Badge Sampling Methanol Mixed with Formaldehyde Methanol Interferes with Sample 35% Below Actual Exposure

51. Directives and Other Assistance WRD 12.75 � Emergency Response to Hazardous Substance Releases WRD 10.6 � 1994 NIOSH Pocket Guide IDLH Values WRD 32.99 � Post Emergency Oil Spill Response Operations The United States Department of Transportation's Emergency Response Guidebook (search at: http://www.dot.gov). There�s a multitude of reference type materials available. The WISHA WRD�s are all relatively old, and lack the new number designations, nonetheless, should be reviewed for policy type issues and inspection guidance. When attempting to make initial assessments it will be useful to refer to the NIOSH IDLH values. This WRD (10.6) basically directs inspectors to use the 1990 IDLH Values published by NIOSH rather than 1994 due to some technical disagreements regarding their development and validity. Note: IDLH values can help you define and document �danger areas� and �Uncontrolled release� . The DOT emergency response guidebook is an excellent resource for first responders, and is available from the DOT web site. This book is particularly useful in planning for response actions on a known chemical agent.There�s a multitude of reference type materials available. The WISHA WRD�s are all relatively old, and lack the new number designations, nonetheless, should be reviewed for policy type issues and inspection guidance. When attempting to make initial assessments it will be useful to refer to the NIOSH IDLH values. This WRD (10.6) basically directs inspectors to use the 1990 IDLH Values published by NIOSH rather than 1994 due to some technical disagreements regarding their development and validity. Note: IDLH values can help you define and document �danger areas� and �Uncontrolled release� . The DOT emergency response guidebook is an excellent resource for first responders, and is available from the DOT web site. This book is particularly useful in planning for response actions on a known chemical agent.

52. Directives and Other Assistance, Cont. WISHA Helpful Tools � Developing Emergency Response Plans National Fire Protection Association (NFPA) � A variety of standards and guides for emergency response activities. The helpful tools section at the end of the emergency response code has a useful checklist style assessment form designed to capture information in order to develop a plan. This is a good starting point for plan development, and can be used as a tool when and if you�re evaluating written plans as part of a compliance activity. The consensus documents and guidelines published by the National Fire Protection Association provide a wealth of detailed information on all aspects of emergency response activities all the way from plan development to qualifications to incident command structures. The helpful tools section at the end of the emergency response code has a useful checklist style assessment form designed to capture information in order to develop a plan. This is a good starting point for plan development, and can be used as a tool when and if you�re evaluating written plans as part of a compliance activity. The consensus documents and guidelines published by the National Fire Protection Association provide a wealth of detailed information on all aspects of emergency response activities all the way from plan development to qualifications to incident command structures.