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OSHA HAZARD COMMUNICATION (HAZCOM) STANDARD 29 CFR 1910.1200. FOR TULANE LABORATORY OR FACILITY EMPLOYEES WHO WORK WITH OR AROUND CHEMICALS January, 2005. OBJECTIVES. Employees shall learn about Tulane’s written Hazard Communication Plan
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OSHA HAZARD COMMUNICATION (HAZCOM) STANDARD29 CFR 1910.1200 FOR TULANE LABORATORY OR FACILITY EMPLOYEES WHO WORK WITH OR AROUND CHEMICALS January, 2005 Tulane University - Office of Environmental Health & Safety (OEHS)
OBJECTIVES • Employees shall learn about Tulane’s written Hazard Communication Plan • Employees shall learn how to report and the reasons for reporting their chemical inventory • Employees shall learn about proper container labeling • Employees shall learn about Material Safety Data Sheets (MSDSs) and how to obtain them • Employees shall learn how to find information on chemicals they may encounter on the job and how to protect themselves Tulane University - Office of Environmental Health & Safety (OEHS)
OSHA HAZARD COMMUNICATION STANDARD • States You Have a “Right to Know” about Chemical Hazards in the Workplace and How to Protect Yourself • Tulane has a Written Hazard Communication Plan located in the OEHS Policies and Procedures Manual (see the OEHS website www.som.tulane.edu/oehs) • A Supervisor’s Guide to the OSHA Hazard Communication (HAZCOM) Standard is available on the OEHS Website under the Chemical Safety Link Tulane University - Office of Environmental Health & Safety (OEHS)
OSHA HAZARD COMMUNICATION STANDARD • Under the OSHA HAZCOM standard, manufacturers of chemicals are required to evaluate the hazards of the chemicals they produce and transmit that information to customers on labels and Material Safety Data Sheets (MSDSs) Tulane University - Office of Environmental Health & Safety (OEHS)
RADIATION BIOHAZARDS HAZARDOUS WASTE OVER-THE-COUNTER DRUGS DRUGS IN SOLID FORM FIRST AID SUPPLIES COSMETICS FOOD AND BEVERAGES WOOD PRODUCTS CONSUMER PRODUCTS (Depending on quantity or frequency of use – such as cleansers) ARTICLES (such as clothing) EXEMPTIONS FROM HAZCOMOSHA HAZCOM deals with chemical hazards. Other agencies such as the EPA or the FDA cover some of these other products. Tulane University - Office of Environmental Health & Safety (OEHS)
SUBMITTING ANNUAL CHEMICAL INVENTORIES Electronic submission (Excel, Paradox, Access or other delimited format) of your annual chemical inventory database/spreadsheet to OEHS is preferred, although OEHS does accept paper copies. A sample chemical inventory form is available on the OEHS website www.som.tulane.edu/oehs under the Chemical Safety link. Submit your database or spreadsheet annually to: pfatlan@tulane.edu or jfolse@tulane.edu. Tulane University - Office of Environmental Health & Safety (OEHS)
SUBMITTING ANNUAL CHEMICAL INVENTORIES The Operations Committee is looking into alternative methods of reporting Chemical Inventory (such as BarCoding, Radio-Frequency Tagging, etc.) OEHS will keep you informed of any changes. Tulane University - Office of Environmental Health & Safety (OEHS)
Supervisor/PI Department Campus/Bldg/Rm # Date of Inventory Product/Chemical Name Manufacturer Have MSDS? (Y/N) CAS (Chemical Abstract Service) Number Product or Catalog Number Number of Containers Total amount of material & units (ml, g, lb) Container Type/Size (glass, plastic/ml, g, lb) CHEMICAL INVENTORY FORM(Form available at www.som.tulane.edu/oehs under Chemical Safety link)Required Information Tulane University - Office of Environmental Health & Safety (OEHS)
All information is important for regulatory reporting and must be submitted. If amounts vary on any given day, simply indicate the amount of each material that is available on the day the inventory is taken. Each chemical has a unique CAS number. Mixtures will have a CAS number for each chemical in the mixture. Some materials are trade secrets and will not list the CAS numbers. Submit as much information as you can. Previously submitted inventories can be obtained from OEHS for updating. Contact Pam Fatland. CHEMICAL INVENTORY FORM(Form available at www.som.tulane.edu/oehs under the Chemical Safety link) Tulane University - Office of Environmental Health & Safety (OEHS)
PURPOSE OF UPDATING CHEMICAL INVENTORY • To verify that you have the Material Safety Data Sheets (MSDSs) you need in the work area and so the OEHS library of MSDSs is complete • Emergency Responders need inventory for emergencies, such as fires and spills, and for planning purposes • To perform a hazard evaluation of the area, obtain appropriate PPE, verify proper storage and that containers are in good condition and not expired Tulane University - Office of Environmental Health & Safety (OEHS)
PURPOSE OF UPDATING CHEMICAL INVENTORY • Tulane is required to report inventory to local, state, and federal agencies such as the EPA, the State Police, and the Fire Department • Fees based on the inventory must be paid to regulatory agencies (Example: City of New Orleans Hazardous Materials Tax which helps to support the Fire Dept’s HAZMAT unit) Tulane University - Office of Environmental Health & Safety (OEHS)
CHEMICAL LABELS – Required Information • Full Chemical Name • Physical and Health Hazards (Flammable, Corrosive, Toxic) • Manufacturer Name/Address/Phone Number (on incoming containers) Tulane University - Office of Environmental Health & Safety (OEHS)
CHEMICAL LABELS – Required Information • Labels are required on all incoming containers, all transfer containers that will be left for a period of time, and on all containers that will be used by more than one person • You can label an entire shelf instead of each individual container if all containers on the shelf contain the same thing (Ex. specimen containers of ethanol) • Labels must be legible, in English, and have the full name of the chemical spelled out (no symbols or abbreviations) Tulane University - Office of Environmental Health & Safety (OEHS)
CHEMICAL LABELS – Required Information • The purpose of labeling is to identify the material and to become aware of the hazards and the methods of protection • Sometimes OSHA requires special wording to appear on the label of certain chemicals or at the entrance to a regulated area (Ex. Formaldehyde containers must say “Irritant and Potential Cancer Hazard”) Tulane University - Office of Environmental Health & Safety (OEHS)
More Chemical Label InformationSometimes labels contain other information that serve to enhance the hazard warnings and identify means of protection, such as: • Signal Word (e.g., Danger, Warning, Caution) • First Aid Procedures • Handling & Storage (e.g., Avoid contact with Acids) • Special Instructions (e.g., Keep out of reach of children, Use with adequate ventilation) Tulane University - Office of Environmental Health & Safety (OEHS)
Chemical Labeling SystemsOptional information which may be found on a container label: • The National Fire Protection Association (NFPA) uses a color-coded diamond with a numerical rating system to identify the degree of health (blue), fire (red), or reactivity (yellow) hazards associated with a chemical in a fire situation. A zero means minimal hazards whereas a four indicates severe hazards. Tulane University - Office of Environmental Health & Safety (OEHS)
Chemical Labeling SystemsOptional information which may be found on a container label: • The National Paint and Coatings Association uses the Hazardous Materials Identification System (HMIS), a similar system of labeling which rates chemicals from zero to four on their health (blue), flammability (red), reactivity (yellow), and also gives personal protective equipment designations. Tulane University - Office of Environmental Health & Safety (OEHS)
Chemical Labels • OEHS has labels available for portable containers where you can write in the full name of the chemical and check off the physical and health hazards, as well as personal protective equipment. Use of these is optional. Contact Jay Folse of OEHS to request these labels: jfolse@tulane.edu. Tulane University - Office of Environmental Health & Safety (OEHS)
LABORATORY DOOR SIGNSSignage for laboratory doors stating the hazards found in the lab and emergency contact information are available from OEHS • Door sign request forms available on OEHS website www.som.tulane.edu/oehs under the Chemical Safety link – form can also be used for updates of current signs • Signs contain stickers relating to hazards found in that laboratory (Example: Flammable, Corrosive, Water Reactive) • Signs also contain authorized admittance/emergency contact information which should be used before entering a lab or during an emergency to contact appropriate personnel • Copies of signage forms are kept in OEHS for emergency response purposes Tulane University - Office of Environmental Health & Safety (OEHS)
DEFINITIONSFamiliarize yourself with terms found on chemical labels/MSDSs Under MSDS link of OEHS Website www.som.tulane.edu/oehs see MSDS HyperGlossary - http://www.ilpi.com/msds/ref/ Tulane University - Office of Environmental Health & Safety (OEHS)
DEFINITIONS CARCINOGEN - Can cause cancer CORROSIVE - Can cause destruction of living tissue (e.g., acids, caustics) EXPLOSIVE - Can cause release of pressure, gas, and heat FLAMMABLE - Can burn when ignition source and air are present Tulane University - Office of Environmental Health & Safety (OEHS)
DEFINITIONS IRRITANT - Can cause reversible inflammatory effect (e.g., eyes water, itching) OXIDIZER - Promotes combustion = oxygen SENSITIZER - Can cause an allergic reaction in some people TOXIC - Can cause health effect Tulane University - Office of Environmental Health & Safety (OEHS)
ROUTES OF ENTRYChemicals can enter the body in a number of ways. Depending on the chemical’s route of entry, you may need respiratory protection, skin protection such as gloves or aprons, or face and eye protection such as face shields and goggles. • INHALATION = Nose • INGESTION = Mouth • SKIN CONTACT = Skin, Eyes • INJECTION = Skin (subcutaneous vs. dermal) Tulane University - Office of Environmental Health & Safety (OEHS)
MSDSs are documents that inform you of the hazards associated with a chemical and how to protect yourself from those hazards MSDSs must be readily accessible to employees in the work area where the chemicals are used Each company publishes its own MSDSs with their address and emergency contact information. Thus if you have a chemical such as acetone from two different manufacturers, you will need an MSDS from both of those manufacturers MATERIAL SAFETY DATA SHEETS (MSDSs) Tulane University - Office of Environmental Health & Safety (OEHS)
Identity Ingredients Physical Properties Hazards * Physical * Health Precautions Storage Control Measures Disposal Spills Personal Protective Equipment (PPE) MATERIAL SAFETY DATA SHEETS (MSDSs)(The following are types of information that can be found on an MSDS) Tulane University - Office of Environmental Health & Safety (OEHS)
MATERIAL SAFETY DATA SHEETS - ACQUISITION • Manufacturers are required to ship MSDSs to Tulane with the first shipment of a chemical • OEHS maintains a hard-copy library of all MSDSs received from the manufacturers and all chemicals listed on the inventories that are submitted. The OEHS library of MSDSs is kept at the OEHS office downtown, the OEHS office Uptown, and at the Primate Center • MSDSs are also available on the OEHS website www.som.tulane.edu/oehs under the MSDS link • The OEHS website/MSDS link also contains FAX numbers for common chemical manufacturers • Contact OEHS if you have trouble finding an MSDS that you need Tulane University - Office of Environmental Health & Safety (OEHS)
MATERIAL SAFETY DATA SHEETS – ACQUISITIONWays to Obtain MSDSs at Tulane: • OEHS Website www.som.tulane.edu/oehs then click on the MSDS link • Online MSDS collections • Online Manufacturer Links • Manufacturer FAX numbers • Other University Websites • OEHS Library of hard copies of MSDSs Tulane University - Office of Environmental Health & Safety (OEHS)
ELECTRONIC MATERIAL SAFETY DATA SHEETSOSHA now recognizes that MSDSs can be kept electronically in the work area, if all of these criteria are met: • All employees are trained on how to obtain MSDSs • MSDSs are able to be printed • An alternative to obtaining MSDSs in the event of power loss or other emergency must exist (Contact OEHS – Library of MSDSs) Tulane University - Office of Environmental Health & Safety (OEHS)
TRADE SECRETS • The OSHA HAZCOM standard provides for protection of trade secrets. • The identity of a trade secret chemical must be given to health professionals, employees, or designated representatives in a medical emergency. The chemical manufacturer may require a written statement of need and confidentiality agreement as soon as circumstances permit. • In a non-emergency, the health professional, employee, or designated representative may provide a written request for disclosure of a chemical’s identity. This written request may be denied but the manufacturer must explain how alternate information will satisfy the specific occupational or medical need. OSHA may be contacted to review the request and denial. Tulane University - Office of Environmental Health & Safety (OEHS)
TRAININGAll who work with or around chemicals must be trained. • All training must be documented. • Training forms can be found at www2.som.tulane.edu/oehs/safety/04F-oehss03.pdf. • Online quizzes for this training Powerpoint presentation will go directly to OEHS and will serve as your training documentation for the OSHA Hazard Communication Standard Powerpoint presentation. • Supervisors must provide training on specific chemical hazards in the work area, PPE and/or work practices to use while doing your job, etc. Tulane University - Office of Environmental Health & Safety (OEHS)
TRAININGAll who work with or around chemicals must be trained. You must be able to show you understood the training. * Quiz * Random Interviews (Be able to answer questions) * Demonstrations (actually obtain an MSDS) Tulane University - Office of Environmental Health & Safety (OEHS)
OSHA REQUIRED TRAINING INFORMATIONEmployees must be familiar with the following: • The requirements of the OSHA HAZCOM standard • Any operations in their work area where hazardous chemicals are present • The location and availability of Tulane’s written HAZCOM plan and how to obtain MSDSs Tulane University - Office of Environmental Health & Safety (OEHS)
OSHA REQUIRED TRAINING INFORMATIONEmployees must be familiar with the following: • How to detect the presence or release of a hazardous chemical in the work area • Physical and health hazards of chemicals present in the work area • How to protect oneself from hazards • Details of Tulane’s HAZCOM program including labeling and MSDSs Tulane University - Office of Environmental Health & Safety (OEHS)
OSHA REQUIRED TRAINING INFORMATIONEmployees must be familiar with the following: • For hazards of non-routine tasks, check with your supervisor • For specific emergency procedures for your area, check with your supervisor • For hazards associated with unlabeled pipes in the work area, contact Facilities Services Tulane University - Office of Environmental Health & Safety (OEHS)
CONTRACTOR INFORMATION • Contractors who could be exposed to chemicals at Tulane must be given the opportunity to review Tulane’s written HAZCOM Plan and must be told about particular hazards in the work areas in which they will be working • Tulane and OEHS will provide MSDSs to contractors upon request Tulane University - Office of Environmental Health & Safety (OEHS)
CONTRACTOR INFORMATION • Contractors who bring chemicals on Tulane property to be used in the course of their work must supply Tulane with a list of these chemicals, and must supply MSDSs and information to Tulane upon request • See OEHS Policies and Procedures Manual at www.som.tulane.edu/oehs for more information on contractors and HAZCOM Tulane University - Office of Environmental Health & Safety (OEHS)
SUMMARY - HAZCOM COMPLIANCE CHECKLISTAre you in compliance with HAZCOM? • Annual chemical inventory submitted to OEHS • Access to MSDSs available in the work area • Training documentation forms/quizzes on HAZCOM topic sent to OEHS • Proper container labeling for all containers in work area • Up-to-date door labels for laboratories • Familiarity with Tulane’s written Hazard Communication Plan available in OEHS Policies & Procedures Manual on OEHS website www.som.tulane.edu/oehs Tulane University - Office of Environmental Health & Safety (OEHS)
Tulane UniversityOffice of Environmental Health & Safety (OEHS)www.som.tulane.edu/oehsPam Fatland, Chemical Safety Manager(504) 988-2800 / pfatlan@tulane.eduIf unable to proceed to quiz, type the link below into your browserhttp://aurora.tcs.tulane.edu/ehs/enterssn.cfm?testnum=12 Proceed to Quiz