Hazard Communication & Temp Workers

1. Hazard Communication & Temp Workers OSHA Compliance for Temp Agencies and Host Employers

2. Background 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 at work

3. Background • 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

4. Hazard Communication Standard Written Program • Purpose • Scope • Definitions • Hazard Classification • Written Program • Labels • Safety Data Sheets • Employee Training • Trade Secrets • Effective Dates

5. Four Major Changes 4 • Hazard Classification (changed from hazard determination) • Labels • Safety Data Sheets (changed from (M)SDS) • Information and Training Will affect nearly 40 million workers and 5 million workplaces.

6. Haz Com Revisions Benefits: • Improved worker comprehension = appropriate handling and use of chemicals • Improved access to information • Harmonized classification of health and physical hazards • Specific elements for labeling and SDS • Reduced burden on overseas exports/imports

8. Chemical Manufacturers • A significant portion of the standard pertains only to chemical manufacturers, importers, and distributors • Employers who do not produce chemicals only have to focus on establishing a workplace program and communicating information to their workers

9. Employers • Employers are required to provide information to their employees about the hazardous chemicals to which they are exposed using: • A hazard communication program • labels and other forms of warnings • (material) safety data sheets ((M)SDS) • information and training

10. Employer Requirements – Written Program • Employers must develop a written program that covers at least: • Labels and other forms of warnings • (Material) Safety Data Sheets • Employee Information and Training

11. Written Program • Employers must develop a written program that covers at least: • A list of the hazardous chemicals known to be present at the facility along with (M)SDS’s for each chemical • The methods the employer will use to inform employees of the hazards non-routine tasks • The hazards of chemicals in unlabeled pipes

12. Labels on shipped containers Required Elements on shipped containers Product identifier Signal words Hazard statements Pictograms Precautionary statements Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party A new Appendix C, Allocation of Label Elements, has been provided to indicate the label requirements by hazard class and category Labels are to be updated within 6 months of getting new and significant information about the hazards, or ways to protect those exposed

13. Workplace Labeling • The employer must ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: • The label information on the shipped container, or • Product identifier and words, pictures, symbols, or combination providing general information on the hazards of chemicals • Labels must be legible, in English, and prominently displayed on the container or readily available in the work area

14. Labels, Tags, and Markings

15. Container Labeling Exemption for Portable Containers The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use by the employee who performs the transfer

16. Example of Simple Label

17. Example of Complex Label

18. Labels OSHA is maintaining the current approach to allowing alternatives to labels on each stationary process container The exception for portable containers under the control of the person who filled them with the chemical remains the same. Labels on incoming containers are not to be removed or defaced unless immediately replaced by another label Workplace labels are to be prominently displayed and in English, although other languages are permitted as well

19. Pictograms

20. Labels Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, drums, and for training their employees on the hazards listed on the labels in the workplace. Labels must continue to be: legible contain the pertinent information (such as the hazards and directions for use) not able to be defaced, (i.e., fade, get washed off,) or removed in any way

21. Safety Data Sheets (SDS) (Material) Safety Data Sheets ((M)SDS) are one of the most important tools available to employers for providing information, and protection to workers from hazardous chemicals which are used in the workplace.

22. Safety Data Sheets (SDS) • Identifies chemicals by name • Tells potential harm and how chemicals will enter the body (Inhalation, ingestion, and/or skin absorption) • Explains signs and symptoms of exposures • Explains emergency procedures

23. Safety Data Sheets (SDS) The GHS uses a specified order of information, as well as title descriptions, on the 16-section safety data sheet. Health, physical and environmental hazard criteria for substances and for classification of mixtures. Consistent with voluntary industry consensus standards, such as ANSI. Should improve comprehensibility and issues regarding accuracy of information.

24. Identification of the substance or mixture and of the supplier 2. Hazards identification Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures Accidental release measures 7. Handling and storage Exposure controls/personal protection Physical and chemical properties 10. Stability and reactivity 11. Toxicological information Ecological information Disposal considerations Transport information Regulatory information Other information, including date of preparation or last revision Safety Data Sheet Format

25. Safety Data Sheets (SDS) • SDS in the workplace for each hazardous chemical • Readily accessible during each work shift to employees when they are in their work area(s)

26. Employee Information and Training • Employers must provide employees information and training on hazardous chemicals in their work area: • At the time of their initial assignment • Whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area • Training may cover categories of hazards

27. OSHA standard covered Operations in their work area where chemical is used Pictograms Location of program, list of chemical, and SDS Detection of chemical Hazards of chemical Protection measures Emergency procedures Labeling system used Employee Training

28. Employee Training Although this paragraph remains essentially the same, updates include Training to include label elements and new safety data sheet format - by December 1, 2013 Training to reflect any new hazards identified in the workplace - by June 1, 2016 Training – prescribed label elements and order of information on data sheets facilitate training/comprehensibility.

29. Temporary Employees • Worksite Specific HazCom Training • Chemicals in use • Methods of detection and prevention • Emergency procedures • Written HazCom Program • Generic HazCom Training • How to read SDS • Labeling requirements • Pictograms • Elements of HazCom Standard • SDS maintenance • Workplace labeling