Hazard Communications (HAZCOM)

1. Hazard Communications(HAZCOM) What Your Business Needs to Know to be in Compliance

2. What is HAZCOM? Who & what does it apply to? How is OSHA’s HAZCOM Program different from EPA’s Worker Protection Standard (WPS) Common citations within the Green Industry Requirements of a HAZCOM Program Written program Chemical Inventory Material Safety Data Sheet’s (MSDS’s) Chemical Labels Training Upcoming changes to the standard What do you do now? Overview of Topics

3. Audio Information • Some of the slides in this presentation contain a sound clip with an explanation of the information on the slide. To play the sound click or double click the speaker located in the upper left corner of the presentation.

4. What is Hazard Communications??? • Also known as “Right to Know” • Requires employers to provide information to employees about chemical hazards in the workplace • Physical hazards • Health hazards

5. Who does it apply to? • General Industry, Construction & Agriculture • All companies where any hazardous chemical is used by employees • Any size of company – even if it is only 1 employee • Includes all chemicals in the workplace • Not just pesticides!!!! • Fuel, lubricants, paint, commercial cleaning products, aerosols, etc.

6. What is not covered? • Hazardous waste • Tobacco and tobacco products • Wood or wood products – with exceptions • Food & Alcoholic beverages • Drugs • Cosmetics • Household consumer products – with exceptions • Articles – as defined in the standard

7. What is not covered? • Wood or Wood Products Exception • Must not be treated with a chemical • Must not be intended for cutting/sawing • Household Consumer Products Exception • Used as intended by the chemical manufacturer • Duration & frequency is not greater than the range of exposure that could be reasonably experienced by a typical household consumer

8. All Chemicals in the workplace Training required before exposure MSDS’s Certified applicator is still required to go through training Only pesticides Worker & handler training Formal training before the 6th day of exposure Fact sheet @ time of hire Certified applicator exempt from training requirement HAZCOM VS. WPS Specific training required for both topics

9. HAZCOM Citations • Constantly within OSHA’s top 10 most frequently cited standards in all industries • Federal OSHA’s #1 cited standard during the period of October, 2008 thru September, 2009 within the Agricultural Production Crops & Agricultural Services Industries

10. Common Citations Include • No program in place • Unlabeled containers • Employees are not trained • Missing Material Safety Data Sheet’s (MSDS’s) • No written program • Missing chemical inventory

11. What is the Manufacturer Responsible For? • Testing & determining hazards associated with their products • Creating labels & MSDS’s • Providing distributors & employers with MSDS’s

12. What must be included in your Written Program? • Procedures for: • Developing & maintaining a list of hazardous substances & their MSDS’s • How will the Written program & MSDS’s be readily available • Labeling system that is in place @ your workplace • Non-routine work tasks (for example – cleaning a boiler)

13. What must be included in your Written Program? • Employee Training • Multi-employer workplace (contractors/sub contractors) • Multi-cultural workplaces must designate someone to assist employees who are unable to read and/or understand English • Plan for periodic inspection of program (@ least annually)

14. Container Labeling • All containers must be labeled • Except for when intended for Immediate Use • Used up within 1 work shift (Still a good idea to label the container) • Original container must have manufacturer’s label • contact manufacturer or distributor for a replacement if removed or defaced.

15. Container Labeling • Secondary container • Include name of chemical & manufacturer • Any associated hazards to the product • Signal words – Caution, Warning, Danger HMIS NFPA Fire Diamond

16. Container Labeling NEVER use one of these as a SECONDARY CONTAINER

17. Labeling Pipes • Pipes are not required to be labeled by Federal OSHA’s HAZCOM Standard • Some OSHA State Plans may require it • NFPA Standard • Must have an MSDS for materials in the pipes & list them in your chemical inventory • Employees must be trained on hazards associated with chemicals in unlabeled pipes

18. Can be anything you want Words Pictures Symbols Must provide @ least general hazard information & target organs Must be Legible In English (other languages if desired) Prominently displayed Hazard Identification

19. Employee Training • Must be in a language that the participants can understand • Must be completed prior to use and/or possible exposure • Include where chemicals are used & stored • Must include the location of: • Your Company’s Written HAZCOM Program • Location of MSDS’s • Location of Chemical Inventory

20. Employee Training • What information is included in the MSDS • How to read & understand an MSDS & label • Your company’s in-house labeling system • Who can an employee go to if they need assistance with translation • Signs & symptoms of overexposure • First aid procedures • PPE Requirements • Must be DOCUMENTED!!!!

21. HMIS & NFPA Labeling FLMMABILITY 4 – Extremely flammable 3 – Flammable under most conditions 2 – Needs external heat to ignite 1 – Must be preheated to ignite 0 – Will not burn HEALTH 4 - Life threatening 3 - Major injury likely 2 - Temporary/minor injury 1 - Irritation/minor reversible injury 0 - No significant risk 4 1 3 REACTIVITY / PHISICAL HAZARD 4 – Extremely explosive 3 – Moderately explosive 2 – Unstable, violent chemical change, will not detonate 1 – Normally stable – can become unstable @ high temps. and pressures. 0 – Normally stable, even in fire – will not react with water WHITE Special Hazard (NFPA Diamond) / PPE (HMIS Label)

22. Physical Hazards Flammability Reactivity Corrosive Explosive Health Hazards Carcinogen Highly Toxic Toxic Irritant Sensitizer Immediately Dangerous to Life & Health (IDLH Target Organ Effects Employee Training

23. Anyone in the company can perform training. OSHA does not require a trainer to have any type of certification. They need to be: An effective trainer Have read and understand OSHA’s HAZCOM standard Know your company’s HAZCOM Program & Policies Who Can Perform Training?

24. How to train? • Just showing a video is not enough • Must include company specific information • MSDS’s – Location • First aid procedures • Emergency procedures • Engineering control, work practices & PPE • Operations in work areas where hazardous chemicals are present

25. Multi-Employer FacilityContractors & Sub-contractors Must ensure that information regarding hazards and protective measures is made available to the other employers onsite, where appropriate.

26. MSDS’s • Required for all hazardous chemicals used in the workplace • No standardized format • Must be available at all times without having to ask for a copy • Can’t be located in a locked room or file cabinet • Required to be in ENGLISH.

27. MSDS – Web/Computer Based Collection • Required to have open access at all times to all employees • You need a backup plan for power outage or computer malfunction. Employees need to be trained on how to use the computer & the program • Just saying you have access to the internet is not enough – must be compiled • Recommended to have a back-up hard copy

28. MSDS’s • MSDS & Chemical inventory must be kept current • MSDS’s are required to be kept for 30 years after you stop using the chemical(s) • Chemicals that are no longer used should be removed from your active MSDS Binder & Inventory List • Store in a separate binder/file

29. Is an MSDS required for the chemicals listed to the right? Yes No It depends Glass cleaner Steel Wood MSDS’s

30. Where to go to find MSDS’s & Labels? • Many manufacturers provide these on their website. • Perform a Google search for the name of the product with MSDS following it. • Free Search Engines • http://hazard.com/msds/ • http://www.ehso.com/msds.php

31. State OSHA Plans • Must comply with State OSHA Plan • May be more stringent than Federal Regulations

32. The following states have approved State Plans: Alaska Arizona California Connecticut Hawaii Illinois Indiana Iowa Kentucky Maryland Michigan Minnesota Nevada New Jersey New Mexico New York North Carolina Oregon Puerto Rico South Carolina Tennessee Utah Vermont Virgin Islands Virginia Washington Wyoming State Plans NOTE: The Connecticut, Illinois, New Jersey, New York and Virgin Islands plans cover public sector (State & local government) employment only.

33. Possible Changes to come • OSHA is currently in the process of trying to make some changes to the HAZCOM Standard. • Trying to move to use the Globally Harmonized System GHS • MSDS’s will follow Safety Data Sheet (SDS) format

34. Required to change the format of: Chemical Labels MSDS’s will become SDS’s Have a specific format to follow. This will make a uniform information system Label Elements Product Name or Identifier Pictogram Signal Word Physical, Health, Environmental Hazard Statements Supplemental Information Precautionary Measures (PPE) Fist Aid Statements Name, Address & Phone # of Company How Will This Effect Chemical Manufactures?

35. ToxiFlam (Contains: XYZ)    Danger! Toxic If Swallowed, Flammable Liquid and VaporDo not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place. IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth.In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam. See Material Safety Data Sheet for further details regarding safe use of this product.MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999 Sample GHS Label

36. How Will This Effect Chemical Employers? • Required to update MSDS’s with SDS’s • Required to provide employee training on new labeling & SDS systems

43. Unlabeled fertilizer containers

44. Unlabeled spray bottles. Even if it is only water in the bottle they are still required to be labeled as water.

45. Unlabeled container

46. What To Do Now? • Obtain a copy of the standard • Read & understand the requirements • Designate a responsible person to implement, manage & monitor the program • Develop & maintain a chemical inventory of all hazardous substances • Obtain MSDS’s for hazardous substances – should match chemical inventory list

47. What To Do Now? • Create a labeling system • Check all containers to ensure they are properly labeled • Develop a written program – Hortica has a Sample Template Program on our website that you can tailor to your business • Make sure the program & MSDS’s are available at all times • Provide your employees with HAZCOM Training – Visit Hortica’s Website for materials

48. What To Do Now? • Develop procedures to make sure: • New employees are trained • Current employees are retrained if new hazards are introduced • MSDS’s & Chemical Inventory remains up to date with all current & new chemicals • Multi-employer issues are addressed • Program is effective (Annual Review)

49. To access Hortica’s Loss Control & Safety materials on-line: • Visit www.hortica-insurance.com • Select “RESOURCES” tab • Click on “Loss Control & Safety” (drop down menu) • Click on “Register here” • Complete the required information (Account number and billing zip code are required) • Click on “Register My Account” • You will then receive an activation e-mail. Open the e-mail and click on the link to activate the account. • Materials may be viewed and downloaded – just another value-added benefit available only to Hortica clients!

50. Any ???'s Zachery Bruce Loss Control Manager zbruce@hortica-insurance.com