HAZARD COMMUNICATION
by Bill Grieb
The Hazard Communication Standard is a law (Title 29 Code of Federal Regulations 1910.1200) enforced by OSHA of the U.S. Department of Labor. This standard gives employees the right to know the hazards and identities of chemicals in their workplaces.
Every employer in the United States is required to comply with the Hazard Communication Standard. Many common products such as housekeeping and cleaning materials are covered by this standard, so hazard communication applies to virtually all employers.
A basic hazard communication program will:
1. List all hazardous materials in the workplace
2. Establish files for information on hazardous materials
3. Obtain an MSDS for each hazardous chemical in use
4. Develop and implement a labeling program
5. Review each MSDS for completeness
6. Make each MSDS readily available to affected and potentially affected employees
7. Develop and implement a written hazard communication program
8. Develop and implement methods to communicate hazards to employees and others
9. Inform employees of protective measures for hazardous materials
10. Train and alert employees to ALL forms of warning that may be used
In many cases, response practices and emergency action drills are appropriate.
If you need a written Hazard Communication Program, you might consider SIC's Individualized Workplace Safety and Hazard Communication Manual. This is a comprehensive written program with all needed forms individualized for your organization. The cost is $198. Call SIC at (310) 454-2100 for additional information.
HAZARD COMMUNICATION PROGRAM COMPONENTS
Employers are required to know the provisions of the Hazard Communication Standard and inform employees of the law and their rights under the law. Effective hazard communication programs are carefully documented and supported by management, supervisors, and employees.
They should emphasize:
1. Identification of potential problems
2. Engineering and production controls to eliminate or minimize risk (This may entail use of alternate materials that are less hazardous than those in current use.)
3. Training of employees and supervisor with provisions for feedback
4. Monitoring, evaluation, and regular program improvements
The Hazardous Material Exposure and Handling checklist is a useful resource in assessing your hazard communication program. If you need a copy, call us at (310) 454-2100 and we'll fax it to you.
TRAINING PROGRAMS
Employees to be trained should be identified based on actual and potential exposure. Training should include emergency response. Training should be provided:
1. When the program is established
2. When new hazardous materials are introduced
3. When new hazards are identified
4. When new employees are hired
5. Regularly to ensure safety consciousness
Instruction should include:
- The provisions of the Hazard Communication Standard
- Any operations where hazardous chemicals are present
- Location and availability of the written program and MSDSs
- How to use and interpret MSDSs
- Methods to detect presence of hazardous materials
- Physical hazards
- Health hazards
- Protective measures, including:
- Work practices
- Emergency procedures
- Protective equipment
- Identifying hazardous chemicals in the workplace
UNDERSTANDING AN MSDS (Material Safety Data Sheet)
When you look at an MSDS, you will see that it has eight basic sections. It is important to understand each one. These sections are:
1. Chemical Identity-This section defines the manufacturer and how they can be reached. It usually states when the MSDS was prepared.
2. Hazards Ingredients/Identity-This section defines the chemicals by common names. Any safe exposure limits that have been defined are given. These include permissible exposure limit and threshold limit value.
3. Physical Chemical Characteristics-this may include boiling point, melting point, vapor pressure, vapor density, evaporation rate, solubility in water, and specific gravity.
4. Fire and Explosion Hazards-This includes flash point, flammable limits, and lower and upper explosive limits. It also defines what type of fire-fighting procedures are appropriate.
5. Reactivity-This includes information on stable vs. unstable, incompatibilities, hazardous decomposition, and polymerization by-products.
6. Health Hazard-This includes hazards from inhaling, ingestion, contact through the skin, etc. It explains whether the effects are acute, chronic, or both. Signs, symptoms, and first-aid procedures are defined.
7. Precautions for Safe Handling and Use-This includes handling of spills, leaks, and other accidental releases. It defines disposal precautions and other handling precautions.
8. Control Measures-This includes things such as types of respirators, ventilation, protective gloves, eye protection, protective clothing, etc. Work hygiene practices such as washing after handling and decontamination are included.
LABELING
All containers must be labeled. Containers used to transfer hazardous materials-for instance, small bottles, cans, etc.-must be labeled, too.
A label should include the material or product name, manufacturer, hazardous ingredients, physical and chemical characteristics, fire and explosion hazards and route of entry (if on OSHA, NTP, or IARC carcinogen list), precautions for use, first-aid measures, and control measures. Standard graphics such as skull and crossbones can be used, as well as warning signs, sounds, etc.
A good source of information for labels is the EMERGENCY RESPONSE HANDBOOK offered by System Interface Consultants, Inc. It provides an index to more than 2,000 materials and 65 on-page emergency response guides. Each guide identifies the hazards and appropriate response to spills, leaks, and fires as well as first-aid measures. There are also 10 first-aid guides. Emergency Response Handbooks are $29.80 each. You can order one by calling (310) 454-2100.
Chemical Labeling
The words DANGER, POISON, SKULL & CROSSBONES are required on labels of highly toxic compounds. The word WARNING is required on moderately toxic compounds. The word CAUTION is required on slightly toxic materials.
The label should define the chemical makeup and hazards involved, such as inhalation, ingestion, or skin absorption. It should advise of necessary precautions to take, such as personnel protective equipment required during handling.
Types of potentially hazardous chemicals that may be present in the workplace include: acids, adhesives, aerosols, asbestos, battery fluids, benzene, catalysts, caustics, cleaning agents, detergents, dusts, etching agents, Fiberglas, flammables, foaming resins, fuels, fungicides, gasoline, glues, greases, industrial oils, inks, insecticides, herbicides, janitorial supplies, kerosene, lacquers, lead, lye, oxalic acid, paints, pesticides, plastics, process chemicals, resins, sealers, shellacs, solders, solvents, strippers, surfactants, thinners, varnishes, water treatments, and wood preservatives.
CHEMICAL SAFETY RULES: C-H-E-M-S
C -Check it out
1. Do not handle or use hazardous materials you are not familiar with.
2. Always read, understand, and follow instructions on the label.
3. Know where to find Material Safety Data Sheets (MSDSs) on all hazardous materials.
4. Understand standard operating procedures that have been established for handling and cleaning up of chemical spills.
H - Handle it with care
1. Do not eat, drink, or smoke in areas where hazardous chemicals are present.
2. Wash thoroughly after handling hazardous materials and follow all special instructions. Change to clean clothes after spraying or dusting.
3. Wear protective clothing. Take all appropriate safety measures when handling potentially hazardous materials.
4. Never mix chemicals without specific instructions. Pour liquids, powders, and dusts slowly to avoid splash or spill.
5. When mixing chemicals, pour the chemical into water, not the reverse. Pour more concentrated or reactive material into solvent or less concentrated or reactive material. Never add weaker materials to stronger or concentrated chemicals.
E - Expect Emergencies
1. Know what to do in any emergency.
2. Know the location and operation of eye-wash fountains and safety showers in areas where corrosive chemicals are handled.
3. Avoid inhaling or contact with sprays or dust. Use appropriate respirators, goggles, shields, gloves, and other protective equipment as needed. When using solvents, don't breathe the vapors.
4. Do not use hazardous materials where respirators are needed for emergency use until you have been trained in and are familiar with their use, limitations, and location.
M - Mark it carefully
1. Keep chemicals in original labeled containers.
2. Label each container for a hazardous substance (vats, bottles, storage tanks) with product identity.
3. Label with a hazard warning (communication of the specific health hazards and physical hazards).
4. Promptly dispose of empty containers in a proper manner.
S - Store it safely
1. Do not leave toxic chemicals unattended. Store chemicals away from the reach of children and pets, preferably in locked storage.
2. Store compressed gas cylinders upright and chained.
3. Store all materials that give off toxic, asphyxiating, suffocating, or anesthetic fumes, in remote or isolated locations when not in use.
4. Store flammable materials away from heat source.
Printed with permission from Safety Information Currents, vol. IV, issue 8.