Hazard Communication

1. Hazard Communication MODULE 11

2. Purpose of OSHA’s Hazard Communication Standard MSDS Program “…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

3. 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

4. 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.

5. Who is covered? • General industry, shipyard, marine terminals, longshoring, and construction employers • Chemical manufacturers, importers, employers, and employees exposed to chemical hazards

6. 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

7. 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

8. 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

9. 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)

10. 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

11. 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

12. 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 employer’s chemical labeling system

13. 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

14. Written Program Availability • Written program available on request: • To employees and their representatives • Program may be kept at main location

15. 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

16. 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

17. 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

18. 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

19. 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

20. 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

21. 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

22. 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)

23. 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

24. 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

25. Target Organ Effects • Reproductive toxins, including teratogens (damage fetuses) and mutagens (damage DNA) • Cutaneous hazards: skin damage • Eye hazards

26. 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

27. 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

28. 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

29. 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

30. 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

31. 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

32. 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