Protecting Employees from Workplace Hazards

1. Protecting Employees from Workplace Hazards OSHA Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories

2. Introduction • Presenter - Colleen Cunanan, AKOSH Industrial Hygienist • Purpose – familiarize you with OSHA’s Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories Standards [CFR 1910.1200 & 1910.1450]

3. Overview • Hazard Communication Standard (HCS) • 2012 standard revision to incorporate the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) • Requirements of the standard • Occupational Exposure to Hazardous Chemicals in Laboratories Standard (Lab Standard) • Requirements of the standard • Comparison of the Lab Standard to HCS

4. OSHA’s Hazard Communication Standard 29 CFR 1910.1200

5. What is Hazard Communication? • OSHA Hazard Communication Standard 29 CFR 1910.1200 – “Right to Know” went into effect in November 1985 • The purpose of Hazcom is to communicate workplace chemical hazards and appropriate protective measures to employees • Employees have a Right to Know about the hazards in their work areas and the potential effects of these hazards upon their health and safety

6. What is Global Harmonization? • A common and coherent approach to defining and classifying hazards, and communicating information on labels and safety data sheets • Provides the underlying infrastructure for establishing a national, comprehensive chemical safety program

7. How will Global Harmonization help? • Improve comprehensiveness • Improve consistency • Improve understanding

8. Changes to HCS • Hazard Classification • Labels • Safety Data Sheets

9. Timeline for Compliance

10. Key Elements of the Hazard Communication Standard (HCS) • Written Program – must be developed and tie all the following elements together • Training - all employees must be trained to identify and work safely with hazardous materials • Labeling - containers of hazardous materials must have labels which identify the material and warn of its potential hazard to employees • Safety Data Sheets (SDSs) - detailed description of each hazardous material present in the workplace

11. HCS Written Program • Information and training the employee will receive regarding workplace hazards • Labeling and other forms of warning utilized in the workplace • Maintenance of SDSs for every chemical • Chemical inventory • Methods the employer uses to inform employees of hazards of non-routine tasks and hazards of chemicals in unlabeled pipes in work areas • Methods of communicating hazards to other employers (contractors)

12. Additional Alaska Requirements • Chemical inventory with locations • Physical Agent Data Sheets (PADs) • Table Z-1-A Example - Acetone • Fed PEL – TWA 1000 ppm • AK PEL – TWA 750 ppm, STEL 1000 ppm

13. HCS Training Requirements Employee training is an integral part of the hazard communication program and must be provided: • At the time of initial assignment • Whenever a new hazard is introduced into the workplace, and • When employees may be exposed to other employers’ workplace hazards Hazard Communication – Site specific training • Details of employer’s Hazcom program • Specific hazards in the workplace • Methods to detect presence or release of a hazardous chemical • Methods to reduce hazards - product substitution, engineering controls, administrative controls, and personal protective equipment

14. Training – Non-routine Tasks Prior to starting work on such projects, affected employees will be given information on hazards to which they may be exposed during such activity This information will cover: • Specific hazards • Measures the employer has taken to reduce the risk of these hazards • Required protective/safety measures

15. Labels • Warn of potential hazards • Not intended to be the only source of information • Serve as an immediate warning

16. What must be labeled? • The OSHA Hazard Communication Standard requires that ALL hazardous materials be labeled. Labels must appear either on the container itself, abatch ticket, placard, or process sheets • Hazardous chemicals in portable containers which are for the immediate use of the employee who performs the transfer is the exception to this rule

17. Manufacturer/Importer Label Requirements • Product identifier • Signal word • Hazard statement • Pictograms • Precautionary statements • Name, address, and phone number of responsible party

18. GHS Pictograms and Hazards

19. GHS Pictograms and Hazards

20. GHS Pictograms and Hazards

21. GHS Compliant Label

22. Workplace Labeling • Standard is “performance based” – allows flexibility in labeling system • Employers may use NFPA, HMIS, or duplicate the shipped label (GHS)

23. Workplace Labeling Must include: • Product identifier – must match SDS and chemical inventory • Words, pictures, symbols or combination of these that will provide employees with specific information regarding the physical and health hazards

24. Workplace Labeling Ensure labels are not removed, defaced, or unreadable For hard to label containers use: • Signs or placards • Process sheets or batch tickets

25. Safety Data Sheets (SDSs) • Formerly referred to as Material Safety Data Sheets (MSDSs) • SDSs provide detailed health and safety information and precautions for handling hazardous substances, including emergency and first aid procedures • Employer must have a SDS for each hazardous chemical in the workplace and ensure SDSs are accessible to all employees

26. SDS Requirements HCS requires a standardized 16 section format 9. Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12. Ecological information 13. Disposal considerations 14. Transport information 15. Regulatory information 16. Other information 1. Identification 2. Hazard(s) Identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls/personal protection

27. PADs – Alaska Requirement • Cold Stress • Hand-Arm Vibration • Heat Stress • Ionizing Radiation • Lasers • Noise • Radio Frequency/Microwave Radiation • Ultraviolet Radiation

28. OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories 29 CFR 1910.1450

29. Key Elements of the Lab Standard • Scope – laboratory use of chemicals; supersedes other subpart Z requirements except: • PEL limitations • Skin and eye contact prohibition • Monitoring/medical surveillance requirements • Written chemical hygiene plan – defines how employees will be protected and exposures will be kept below PELs • Training – all employees must be trained on chemical hazards • Medical consultation and examinations – provided free to employee by licensed physician under certain circumstances • Hazard identification – labels and SDSs

30. What is “laboratory use” of chemicals? • Chemical manipulations are carried out on a “laboratory scale”; • Multiple chemical procedures or chemicals are used; • Procedures involved are not part of a production process, nor in any way simulate a production process; and • “Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals.

31. Written Chemical Hygiene Plan (CHP) Must be: • Capable of protecting employees from health hazards associated with hazardous chemicals in laboratory • Capable of keeping exposures below PELs • Readily available to all employees

32. Required CHP Elements • SOPs for work involving use of hazardous chemicals • Criteria to determine and implement control measures to reduce employee exposure • Requirement that fume hoods and other protective equipment are functioning properly and measures taken to ensure adequate performance of such equipment

33. Required CHP Elements • Provisions for training and information • Procedures requiring prior approval • Provisions for medical consultation and examination • Responsible personnel – Chemical Hygiene Officer • Provisions for additional employee protection when working with particularly hazardous substances

34. Lab Standard Information and Training Requirements • Employees must be apprised of hazards of chemicals present in their work areas • Must be provided at time of initial assignment and prior to assignment involving new exposure situation

35. Lab Standard Information and Training Requirements Employees must be informed of: • Contents of 1910.1450 and appendices • Location of employer’s CHP • PELs • Signs and symptoms of exposure to chemicals in the laboratory • Location of reference materials such as SDSs

36. Lab Standard Information and Training Requirements Employee training must include: • Methods and observations that may be used to detect presence or release of hazardous chemical • Physical and health hazards of chemicals in the work area • Measures employees can take to protect themselves such as appropriate work practices, emergency procedures, and personal protective equipment (PPE)

37. Medical Consultation and Examinations • Opportunity shall be provided when: • Signs/symptoms shown • Monitoring indicates need • An “event” results in likelihood of exposure • Shall be followed by Dr’s written opinion • Requires the employer provide info to Dr • Shall be: • At no cost to employee • Provided by a licensed physician

38. Hazard Identification • Labels on incoming containers shall not be removed or defaced • SDSs received with incoming shipments of hazardous chemicals must be maintained and be made readily accessible

39. Hazard Identification Chemicals developed in lab: • If composition is known, employer must determine if it is hazardous and provide appropriate training • If composition is unknown (e.g. a byproduct) employer will assume it is hazardous • If produced for outside user, employer must comply with HCS – SDS and labeling requirements

40. Differences from HCS • SDS requirements • Chemical inventory requirement • Lab Standard supersedes other regs • Annual review of CHP • Medical evaluations • Chemical Hygiene Officer • Monitoring requirements

41. Similarities to HCS • Same objective • Same definitions • Written program • Training and information requirements

42. Questions?