HAZARD COMMUNICATION and MSDS

1. HAZARD COMMUNICATION and MSDS PUBH 3310 October 6, 2010

2. Supplemental Resources • The Basics of Occupational Safety (course text) • Pages 384-385 of Chapter 16 covers OSHA’s Hazard Communication Standard • Selected Internet websites, as noted in this presentation

3. Objectives • After this session, students should know: • Basic information about Material Safety Data Sheets • Background • MSDS sources • Format • How to use an MSDS • The importance of the OSHA Hazard Communication standard • The 5 major requirements of the standard • How OSHA officers determine compliance • Proposed OSHA changes (in progress)

4. Outline • Introduction • MSDS • History • Format • OSHA Hazard Communication Standard • 5 HAZCOM elements • OSHA enforcement • Future

5. Introduction • Chemical hazard information • In our culture, individuals have the “right to know” about hazards • This presentation will emphasize the process used to inform workers in the US • Material Safety Data Sheets • OSHA Hazard Communication Standard

6. Material Safety Data Sheets • The Material Safety Data Sheet (MSDS) is used in the US and Canada to document chemical hazards • Required by the OSHA Hazard Communication standard in the US • Provided by chemical suppliers • In Canada, required under Workplace Hazardous Materials Information System (WHMIS ) rules • “Chemical Information Cards” are used in Europe

7. Material Safety Data Sheets • MSDS History • MSDSs have been in use for 100 years • http://www.phys.ksu.edu/area/jrm/Safety/kaplan.html • “Modern” MSDS forms • Form No. LSB-OOS-4 issued in 1968 • Required for ship building, breaking and repairing • OSHA Form 20 in 1972 • OSHA Hazard Communication Standard accepts any format • OSHA-174 form recommended • http://www.osha.gov/dsg/hazcom/msds-osha174/msdsform.html • American National Standards Institute, ANSI Z400.1-2004 • An updated format with more information

8. OSHA MSDS Format • OSHA recommended MSDS, OSHA-174 (1989), 8 sections • Manufacturer information • Hazard Ingredients/Identity Information • Physical/chemical properties • Fire and Explosion Hazard Data • Reactivity Data • Health Hazard Data • Precautions for Safe Handling and Use • Control Measures

9. ANSI A400.1-2004 Product and Company Identification Hazard Identification Composition / Information On Ingredients First Aid Measures Fire Fighting Measures Accidental Release Measures Handling and Storage Exposure Control / Personal Protection Physical and Chemical Properties Stability and Reactivity Toxicological Information Ecological Information Disposal Considerations Transport Information Regulatory Information Other Information ANSI MSDS Format

10. Material Safety Data Sheets • Other formats • Canadian WHMIS (Workplace Hazardous Materials Information System) • http://www.ccohs.ca/oshanswers/legisl/intro_whmis.html • 9 mandatory MSDS sections • Includes information about the MSDS preparer • http://www.ccohs.ca/oshanswers/legisl/msds_prep.html • Expires after 3 years • European Community • International Chemical Safety Cards (ICSCs) • Standard format • http://www.cdc.gov/niosh/ipcs/icstart.html

11. Sample MSDS • MSDS Example • WD-40 • A common product that everyone may know • http://www.wd40.com/ • ANSI Z-400 format

12. OSHA Hazard Communication Standard • Hazard Communication Standard promulgated in 1983 • Applies to general industry and agriculture • Duplicate standards apply to other industries • 1910.1200, for general industry • 1915.1200, for shipyards • 1917.28, for marine terminals • 1918.90, for longshoring • 1926.59, for construction • 1910.1450 applies to laboratories instead of 1910.1200 • This has been the most frequently cited OSHA standard! • Third most common violation in recent years

13. OSHA Hazard Communication Standard • The Hazard Communication Standard (HCS) is based on a simple concept: • 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. • The HCS is designed to provide employees with the information they need.

14. OSHA Hazard Communication Standard • Employers benefit • Knowledge acquired under the HCS will help employers provide safer workplaces • Employers can take steps to reduce exposures, substitute less hazardous materials, and establish proper work practices. • These efforts will help prevent the occurrence of work-related illnesses and injuries caused by chemicals.

15. OSHA Hazard Communication Standard • Information on all hazardous chemicals must be prepared and transmitted • Physical hazards and health hazards • Employers have flexibility in applying this performance-oriented standard • Chemical manufacturers and importersmust evaluate the hazards • Labels for containers • Material safety data sheets (MSDS) with more information • OSHA guidance documents • http://www.osha.gov/dsg/hazcom/oshacomplianceassistance.html

16. OSHA Hazard Communication Standard • For laboratories and where chemicals are only handled in sealed containers: • Keep labels on containers as they are received • Maintain material safety data sheets that are received, and give employees access to them • Provide information and training for employees • There is no need for a written hazard communication programs or lists of chemicals 

17. OSHA Hazard Communication Standard • Under the hazard communication standard, employers are responsible for 5 items: • Preparing an inventory of hazardous chemicals • Preparing and implementing a written program • Ensuring that all in-plant containers are properly labeled • Ensuring that MSDSs are obtained for all hazardous chemical • Training employees

18. 1. Identifying hazardous chemicals • A list (inventory) of hazardous chemicals in the workplace is required • Everything listed needs an MSDS • Survey the workplace, check purchasing records • Establish procedures to ensure that MSDSs are received • Includes chemicals in all physical forms if there is potential exposure • Exceptions for consumer items, cosmetics, drugs, food

19. 2. (Written) Hazard Communication Program • All workplaces where employees are exposed to hazardous chemicals must have a written plan which describes how the standard will be implemented.  • Sample plans are available from trade groups, OSHA, Internet, etc. • Written plan must include requirements for: • Labels and other forms of warning • Material safety data sheets • Employee information and training

20. 3. Labels • In-plant containers of hazardous chemicals must be labeled, tagged, or marked:  • Identity for the material • Appropriate hazard warnings • Labels are required when materials are transferred into other containers, • Exemption for portable containers • Filled from labeled container by employee • Used within one shift by that employee

21. Distributors must provide MSDSs to customers Employers must have MSDS for each hazardous chemical MSDS must be readily accessible to employees in their work areas during their workshifts Often MSDS binder in a central location (e.g., in the pick-up truck on a construction site).  Computerized information with access through terminals is acceptable Employees must have access to the MSDSs themselves 4. Material Safety Data Sheets (MSDS)

22. 5. Employee information and training • Each employee who may be "exposed" to hazardous chemicals must be provided information and training • Prior to initial assignment to work with a hazardous chemical • Whenever the hazard changes • "Exposure" means "an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.) and includes potential (e.g., accidental or possible) exposure." 

23. 5. Employee information and training • Written HCS programs should include: • Designation of person(s) responsible for conducting training • Format of the program to be used (audiovisuals, classroom instruction, etc.) • Elements of the training program (should be consistent with the elements in paragraph (h) of the HCS) • Procedure to train new employees at the time of their initial assignment to work with a hazardous chemical, and to train employees when a new hazard is introduced into the workplace.

24. OSHA enforcement • OSHA compliance officers enforce the HSC standard • Review written HSC program • Responsible persons • Required elements • Look at labels, MSDSs, etc. • Interview employees • Training • Hazards • MSDS

25. HCS Criticism • Difficult for employers to comply • Detailed, lots of work • The many available third-party computer programs and MSDS providers exemplify the trouble employers have with this standard • Easy for OSHA to find violations • HCS could be more effective • Confusing, hard to read, inaccurate MSDSs • Inconsistent labeling • Etc.

26. OSHA changes in hazard communication http://www.osha.gov/SLTC/hazardcommunications/index.html Advanced Notice of Proposed Rulemaking, ANPR, 09/12/2006 OSHA adopting voluntary international system Globally Harmonized System of Classification and Labeling of Chemicals (GHS) International goal to implement the GHS by 2008 Every country would use the GHS GHS applies throughout product life cycle Future of OSHA HCS

27. OSHA changes in hazard communication (cont) GHS features ANSI Z-400 compatible MSDS Labels with pictograms Future of OSHA HCS

28. Future of OSHA HCS • OSHA changes in hazard communication (cont.) • OSHA compliance directive emphasizes MSDS accuracy (1998) • CSHOs will screen MSDSs during inspections • Employers will not be responsible for inaccurate MSDSs the accepted in good faith • Manufacturers required to correct deficiencies • http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1551