OSHA Chemical Safety Update West virginia SERC workshop august 24 , 2017

1. OSHA Chemical Safety UpdateWest virginia SERC workshopaugust 24, 2017 Adam Hamrick OSHA Region 3

2. Hazardous chemicals standards • Process Safety Management (PSM) • General Industry standard – 29 CFR 1910.119 • Construction standard – 29 CFR 1926.64 • Explosives (definition) – 29 CFR 1910.109 • Hazardous Waste Operations and Emergency Response (HAZWOPER) • General Industry standard – 29 CFR 1910.120 • Construction standard – 29 CFR 1926.65 • Hazard Communication • General Industry standard – 29 CFR 1910.1200 • Construction standard – 29 CFR 1926.59 (identical to 1200)

3. Process Safety Management Of highly hazardous chemicals (PSM) • Purpose is to prevent or minimize the consequences of catastrophic releases of toxic, flammable, highly reactive and explosive substances. • A comprehensive management program integrating technologies, procedures, and management practices. • Focused primarily on worker safety “inside the fence line”. • Performance based compliance. • No reporting requirements.

4. PSM Coverage • A process that contains a chemical at or above the threshold quantity listed in Appendix A of the standard. Examples are 10,000 pounds of anhydrous ammonia or 1,500 pounds of chlorine. • A process that contains a Category 1 flammable gas or liquid in one location in a quantity of 10,000 pounds or more. • Explosives and pyrotechnics manufacturers in accordance with Explosives and Blasting Agents Standard 29 CFR 1910.109(k)(2). • Exemptions and exceptions – Retail facilities, oil/gas drilling or servicing, unoccupied remote facilities, hydrocarbon fuels consumed as fuel and not part of a covered process, and flammable liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point without chilling or refrigeration.

5. PSM updates • Retail facilities exemption – facility must receive >50% of income from the direct sales of PSM covered chemicals to end users to qualify. • The 1% test – Rescinding the maximum commercial grade policy for chemicals listed in Appendix A where concentration is not specified will now use the total weight of the chemical in the process at a concentration of one percent or greater. (Enforcement will begin March 31, 2018 for newly covered processes) • Process involving a 2000-pound mixture of 50 percent chloropicrin by weight and an appropriate solvent, the following formula determines coverage: • Weight x [concentration] = amount of highly hazardous chemical2000 pounds x 50 percent = 1000 pounds chloropicrinexceeds the 500-pound threshold quantity in Appendix A.

6. HAZARDOUS WASTE AND EMERGENCY RESPONSE OPERATIONS (HAZWOPER) • Employers covered by PSM are required to develop and implement an emergency response plan in accordance with 1910.120(q) • Also applies for a clean-up of a chemical which requires an emergency response. • Emergency response means a response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. • Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses. • Responses to incidental releases are covered by the Hazard Communication standard.

7. HAZARD COMMUNICATION • HAZCOM 2012 aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Based on Rev. 3 (2009) • Hazardous Chemical is defined as any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. • Chemical manufacturers and importers must classify each chemical they produce or import: • Determine the appropriate hazard classes and associated hazard categories • Base this on an evaluation of the full range of available data/evidence on the chemical (no testing is required) • Use Appendix A for health hazard criteria and Appendix B for physical hazard criteria • Appendix C specifies required information for each hazard class and associated hazard category.

8. Labels on shipped containers • Each container of a classified hazardous chemical leaving the workplace is to be labeled, tagged, or marked with the following: • Product identifier (SDS & Label must match) • Pictogram(s) • Signal word • Hazard statement(s) • Precautionary statement(s) • Name, address, and telephone number of responsible party (Emergency Number must be a U.S. phone number) • FAQ – An importer becomes the responsible party

9. Workplace (in-house)labeling • Provide label identical to that of the shipped container OR Product identifier and words, pictures, symbols, or a combination thereof, providing general information on the hazards of the chemical, along with other HCS information available. Key - Information must achieve a level of employee awareness which equals or exceeds if employer had used a label with complete information.

10. SAFETY DATA SHEETS • 16-section safety data sheet (SDS) • Appendix D of HCS specifies what must be included in each section, such as: • Section 2 required to have hazard identification information. • Section 8 must include OSHA PEL, ACGIH TLV and Exposure Controls/Personal Protection • Section 10 must include reactivity, stability and incompatibilities • Sections 12-15 are not mandatory since they address information outside OSHA’s jurisdiction • If no relevant information is found for any sub-heading within a section on the safety data sheet, the chemical manufacturer, importer or employer preparing the safety data sheet shall mark it to indicate that no applicable information was found. • FAQ – There is no requirement that an employer replace all MSDSs with SDSs.

11. Guidance products • The Use of Metrics in PSM Facilities Fact Sheet • OSHA and EPA published Fact Sheet: The Importance of Root Cause Analysis During Incident Investigation. • OSHA and EPA published PSM and RMP Comparison Tool • OSHA and DOT PHMSA Memorandum on labeling of hazardous chemicals for bulk shipments.

12. OSHA Resources

13. QUESTIONS? Adam Hamrick OSHA Region III Office# (215)861-4930Mobile# (215)678-3135 Email: hamrick.adam@dol.gov Contact your nearest OSHA Office or call 1-800-321-6742 (OSHA)