HAZARD COMMUNICATION: EMPLOYEE RIGHTTOKNOW

1
HAZARD COMMUNICATIONEMPLOYEE RIGHT-TO-KNOW
Subpart Z 29CFR1910.1200
2
National Fire Prevention and Hazard Communication
Insignia
3
(No Transcript)
4
The Bhopal Disaster In the early morning of
December 3, 1984 a Union Carbide pesticide
producing plant leaked a highly toxic cloud of
methyl isocyanate onto the densely populated
region of Bhopal, central India. Of the 800,000
people living in Bhopal at the time, 2,000 died
immediately, 300,000 were injured and as many as
8,000 have died since. The leak was caused by a
series of mechanical and human errors. A portion
of the safety equipment at the plant had been
nonoperational for four months and the rest
failed. When the plant finally sounded an
alarm--an hour after the toxic cloud had
escaped--much of the harm had already been done.
5
Bhopal, India Dec. 3rd, 1984
6
(No Transcript)
7
(No Transcript)
8
Introduction

• Enacted in 1984
• 14 Years later, still one of the most often cited
  violations

9
Subpart Z
Toxic and Hazardous Substances (1910.1000 - 1500)
Number of Serious Violations
10
Steps to a successful hazard communication program

• Inventory
• Label
• MSDS
• Training
• Written Program
• Records Retention

11
1. Inventory

• List chemicals used in your workplace
• Identify chemicals which are hazardous
• Caution Warning Danger
• MSDS
• Consumer products not considered hazardous
• if used in normal manner
• duration and frequency same as consumer

12
Partial list of typically hazardous products

• Fungicides
• Industrial oils
• Herbicides
• Lacquers
• Paints
• Pesticides
• Process Chemicals
• Shellacs
• Varnishes
• Water treatments
• Wood preservatives

• Acids
• Adhesives
• Aerosols
• Battery Fluids
• Catalysts
• Caustics
• Cleaning Agents
• Degreasing Agents
• Detergents
• Flammables
• Foaming Resins
• Fuels

13
Other chemicals considered to be hazardous

• Having Permissible Exposure Limits (PEL) under
  the OSHAct
• Having a Threshold Limit Value (TLV) listed by
  the American Conference of Governmental
  Industrial Hygienists
• Any suspected or confirmed Carcinogen

14
If you arent sure...

• Assume the chemical is hazardous until you
  receive confirmation from the manufacturer or
  supplier

15
2. Label hazardous chemical containers

• All chemical containers need to be labeled,
  tagged, or marked with following information
• Appropriate hazard warnings
• Name and address of the chemical manufacturer,
  importer, or other responsible party
• Identity of the hazardous chemicals

16
Solid metal, wood, or plastic manufacturers

• May give the label to the customer/ distributor
  at time of shipment
• Does not need to include with subsequent
  shipments unless information changes

17
Secondary Containers

• Must be labeled, tagged or marked with the
  identity of the hazardous chemical and
  appropriate hazard warnings
• The identity may be any chemical or common name
  that is indicated on the MSDS and permits cross
  reference

18
The Hazard Warning

• Needs to be as specific as possible
• Example Warning Continuous inhalation may
  cause lung damage
• Caution, Danger, not enough, unless no
  specific target organ is known

19
Alternatives to In-house labeling

• Post signs that convey the hazard if stationary
  containers with similar contents in same work
  area
• Written standard operating procedures, process
  sheets, batch tickets, blend tickets, etc., may
  be substituted on stationery process equipment
• Dont have to label portable containers in which
  hazardous chemicals are transferred from labeled
  containers and which are intended only for
  immediate use by the employee who makes the
  transfer

20
Some substances have specific labeling
requirements

• Carcinogens
• Lead WAC
• Asbestos
• Hydrogen, Oxygen and Anhydrous Ammonia
• Cotton Dust
• Coke Oven Emissions
• Formaldehyde
• Benzene
• Methylenedianiline

21
3. Material Safety Data Sheets

• You are required to have an MSDS for each
  hazardous chemical product you package, handle or
  transfer.
• The MSDS file must be maintained at the work
  place
• When employees travel between workplaces, the
  MSDSs may be kept at a central location at the
  primary workplace facility but availability
  must be immediate!

22
Who is responsible for providing MSDS and Labels?

• Primarily the Manufacturer ( or importer, or
  wholesale distributor)
• Retail Distributors are only required to provide
  MSDS to commercial customers who make requests.

23
Check each new MSDS you receive

• Standard specifies minimum information
• There should be no blank sections if there are,
  contact manufacturer for complete form
• If info just not available, mark form

24
Can you prepare your own MSDS?

• Yes, but you become responsible for the
  completeness and accuracy
• OSHA form 174 is available for this

25
Is there a standard format?

• No
• Certain minimum information must be clearly
  presented
• Otherwise, you will see a variety of formats used
  on MSDS

26
What must be provided on an MSDS?

• Product or chemical identity used on the label
• Name address and phone number for hazard and
  emergency information
• Date of MSDS preparation

• Chemical and common names of hazardous
  ingredients (1 or more of mixture, or
  releasable above TLVs and PELs)
• State or Fed OSHA PEL
• ACGIH TLVs

27
What must be provided on an MSDS? (continued)

• Primary routes of entry into the body, such as
  inhalation, ingestion, absorption
• Acute and chronic health hazards, including signs
  and symptoms
• Medical conditions aggravated by exposure

• Physical and chemical characteristics, such as
  vapor pressure and flash point
• Physical hazards, including the potential for
  fire, explosion, or reactivity

28
What must be provided on an MSDS? (continued)

• Carcinogenic hazard, if applicable
• Emergency and first aid procedures
• Precautions for safe handling and use including
  hygiene, repair and maintenance, spill/leak
  cleanup

• Exposure control measures such as engineering
  controls, work practices and personal protective
  equipment

29
Must MSDS be translated into a foreign language?

• No, but one way or another, all employees must be
  informed of hazards
• Many State OSHA offices will translate into
  Cambodian, Chinese, Korean, Spanish, Vietnamese

30
4. Information and Training

• Inform ALL employees about your hazard
  communication program
• Identify and train you employees who could be
  exposed to hazardous chemicals

31
For ALL employees

• The Hazard Communication Standard requirements
• Any operations in their work areas that involve
  hazardous chemicals
• The location and availability of the written
  hazard communication program, including the
  list(s) of hazardous chemicals and data sheets.

32
Training for employees with exposure

• The requirements of the Hazard Communication
  Standard
• Working situations where hazards are present
• What the warning on the container means
• The location of written program inventory lists,
  and MSDS
• How to obtain and MSDS
• How to detect the presence or release of
  hazardous chemicals

33
Training for employees with exposure (continued)

• Physical and health hazards of hazardous
  chemicals
• How employees can protect themselves from
  overexposure, and what symptoms are
• Exposure control methods, including work
  practices, engineering controls, administrative
  controls, personal protective and emergency
  procedures
• When and how to report leaks and spills
• Where to get more information

34
Training short cuts

• Dont have to train employees separately for each
  brand of same chemical
• Generic training on groups of chemicals with
  similar hazards is acceptable

35
Training Documentation

• Not technically required, but....
• Have attendants sign a form to verify they
  attended and understood the training
• Follow up your training sessions. Ask a couple
  of questions in the field that your people should
  be able to answer, based on the training

36
5. Develop a written plan

• You must have an up-to-date written plan to be in
  compliance with the law.

Hazard-Communication Plan
37
What must be in the written plan?

• A list of hazardous chemicals known to be present
  in your workplace
• Who is responsible for identifying chemicals,
  their criteria, and how list is updated
• Labels and other forms of warning
• Describe labels used, who is responsible for
  labeling requirements, written alternative if
  any, procedure to review and update label warning

38
What must be in the written plan? (continued)

• Material Safety Data Sheets
• Indicate how and where maintained
• Who is responsible for them
• Procedure for employee access
• What you do if dont receive one
• How you update them with additional information

39
What must be in a written plan? (continued)

• Employee information and training procedures
• Describe training program and who is responsible
  for it
• Indicate how employees are informed about
  non-routine tasks

40
What must be in a written plan? (continued)

• How to inform employees of other employers
• at worksite about possible hazardous exposures
• what personal protective measures need to be
  taken during the workplaces normal operating
  conditions and in foreseeable emergencies
• An explanation of labeling system used in the
  workplace

41
Record Keeping Requirements

• Each MSDS received must be maintained for at
  least 30 YEARS
• Or other records showing
• identify (chemical name if known) of substance or
  agent
• Where it was used
• When it was used
• Employees or designated representatives can
  request and receive in reasonable time, place,
  and manner

42
Summary

• The purpose of the Hazard Communication
• Program is to inform all employees about the
• major components of the companys hazard
• communication program.
• Chemicals are an important part of the work we
• do, but they can be harmful. Get to know how
• to obtain information about the chemicals
• in your area and protect yourself. You might
• not be given a second chance!

43
(No Transcript)
44
(No Transcript)