safety tidbit... osha has estimated that more than 32 million workers are exposed to 650,000...

Safety Tidbit . . .

OSHA has estimated that more than 32 million workers are exposed to 650,000 hazardous chemical products in more than 3 million American workplaces.*

Does this pose a serious problem for exposed workers and their employers …

What do you think?

* OSHA.gov

Top 10 . . .

* OSHA.gov

OSHA’s 2011Top 10 Most Frequently Cited Standards

(Oct. 1, 2010 to Sept. 30, 2011)

1. Scaffolding (C)

2. Fall Protection (C)

3. Hazard Communication

4. Respiratory protection

5. Lockout/tagout

C = Construction Standard

6. Electrical: wiring

7. Powered industrial trucks

8. Ladders (C)

9. Electrical systems design

10. Machine guarding

Developing An

Employee “Right-To-Know”

Program

HAZARD COMMUNICATION

ChemicalAny substance, or mixture of substances

Exposure or exposedMeans that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential exposure (accidental or possible)

Hazardous ChemicalAny chemical which is classified as a physical or health hazard, simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

LabelWritten, printed or graphic information concerning the chemical that is on the container or outside packaging.

DEFINITIONS

MSDS (Material Safety Data Sheets)Written or printed material concerning a hazardous chemical that is prepared by the manufacturer or importer.

Work AreaMeans a room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present.

WorkplaceAn establishment, job site, or project, at one geographical location containing one or more work areas.

w3hWhat, When, Why, How

DEFINITIONS

INTRODUCTION

WHAT OSHA standard 1910.1200 It’s a way to inform workers about potentially hazardous chemicals in use at

the workplace It’s a way to train employees on safe handling & use of those chemicals

WHY OSHA mandated Reduce work comp injuries Reduce $’s associated with WC and fines

HOW

HAZARD COMMUNICATION PLAN

Policy

Training MSDS

LabelsPLAN ELEMENTS

WRITTEN POLICY

Required if EE’s are exposed to hazardous chemicals

Must be available

Ties all the essential parts together

Essential parts include: Administrative or General

Hazardous Chemical List

Labels & other forms of warning

MSDS

Non-routine tasks

Contractors/Multiemployers

Training

ADMINISTRATIVE / GENERAL

WHAT

Purpose

Responsibilities

Review / Updating

1

The purpose of the Hazard Communication Program is to ensure that the hazards of products used in Company operations are evaluated and that information concerning physical and health hazards is transmitted to potentially exposed employees. This transmittal of information is to be accomplished by a written hazard communication program, to include container labeling or other forms of warning, Material Safety Data Sheets (MSDS), and employee training.

Annually, the Hazard Communication Program will be audited to determine its effectiveness.

The following people have specific responsibilities for implementing an effective HAZCOM program.

It is Executive Management's responsibility to:• Require a HAZCOM program to be implemented.• Hold the Manager accountable for implementing the HAZCOM program.• Require an annual audit of the program.

HAZARDOUS CHEMICAL LIST

WHAT Identifies the hazardous chemical used at workplace

Include all forms: liquids, solids, vapors, fumes and mists Make it available Keep it current Serves as a list to obtain and maintain MSDS

HOW

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Chemical Inventory

_______________ shall compile, annually review, and update as necessary a complete inventory of all products that employees normally come in contact with and contain hazardous ingredients. The list of such products will be maintained using _____________. A copy of this list will be kept on file for review at ___________________.

Loc: Address: Company NamePH: Contact: Hazard Communications

Fax: Date of I nventory: Chemical Inventory

I tem UN Relief Flash Boiling Container Storage Sprin Sup. N.F.P.A. Rating

# Chemical Name Class # CAS Number PS Vents Point Point Type Size Qty Loc Height Site DensityAgent H F R S Trade / Product Name MSDS

1 Pyrethrins (Level I I ) 2.1 1950 8003-34-7 M N/A <20 F NE D oz 12 I N/A Main N/A CO2 1 3 0 Pro Control Total Release Y

2 Pyrethrins (Level I I I ) 2.1 1950 8003-34-7 M N/A -4 N/A D oz 12 I N/A Main N/A Foam 1 2 1 P.I . Contact Insecticide Y

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LABELS

WHAT Describe how we are going to ensure containers are labeled

Manufacturers label In-house ( i.e. HMIS)

Immediate use Under the control of, AND Used only by that employee, AND Within the work shift of transfer

3

Labeling

All hazardous chemical containers used at this workplace will clearly identify the chemical on the label, and include an appropriate hazard warning and the manufacturer’s name and address. No container will be released for use until this information is verified. ___________ will ensure that all containers are labeled with a copy of the original manufacturer’s label or a label that has the appropriate identification and hazard warning.

Also, it may be necessary at times to transfer products from the original container into a secondary container. Should this occur, the secondary container is required to be labeled. Replacement labels shall include, at a minimum, the identity of the hazardous material(s) (common and/or trade name), appropriate hazard warnings or alternatively, words, pictures, symbols or combination thereof, which provide at least the general information regarding the hazards of the products.

LABELS

MSDS’s

WHAT Where they are kept and how to access Who will manage and update Who to contact if one is missing

HOW Hard copies Electronic Readily accessible

4

Material Safety Data Sheets

Safety Data Sheets are readily available to all employees. Employees can review Safety Data Sheets for all hazardous chemicals used at this workplace. [Identify the file location if they are stored in a paper file. Describe how to access them if they are stored electronically].

The Safety Data Sheets are updated and managed by __________. If a Safety Data Sheet is not available for a hazardous chemical, immediately notify __________.

HNT’S

WHAT Hazardous Non-routine Tasks (HNT’s) A task that is required only on occasion and where employee are not completely

familiar with all aspect of the job How employees will be informed Identify the tasks and what information you will provide

Example New products BBP hazards Heat hazards

5

Non-Routine Tasks

When required to perform non-routine tasks with hazardous chemicals, a special training session will be conducted by the Manager to inform the employee of the hazardous chemicals to which he/she might be exposed and the proper precautions to take to reduce or avoid exposure.

Examples of special tasks that may expose employees to hazardous chemicals include the following:

MULTIEMPLOYERS

HOW Hazardous chemical information will be relayed to other employees (contractors,

customers, ours)

WHAT Availability of MSDS’s Labeling system Protective measures Safe handling

6

Multiemployers

It is the responsibility of ___________ to provide contractors and their employees with the following information if they may be exposed to hazardous chemicals in our workplace:

• The identity of the chemicals, how to review Safety Data Sheets, and an explanation of the container and pipe labeling system.

• Safe work practices to prevent exposure.

This person will also obtain a Safety Data Sheet for any hazardous chemical a contractor brings into the workplace.

TRAINING

WHEN Upon initial hire New chemicals or hazards are introduced Reason to doubt employee proficiency

HOW Training format

WHAT Overview of HazCom requirements Hazardous chemicals present Written plan and location How to read labels & review MSDS Physical & health affects of hazardous chemicals Methods used to determine the presence or release of hazardous chemicals How to reduce or prevent exposures Emergency procedures to follow if exposed or material release

7

DOCUMENT

TRAINING7

Training

Employees who work with or may potentially be exposed to hazardous products will receive training on the safe use of the products at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about are introduced into their work area. All newly hired employees shall receive training at the time of employment as part of their Employee Orientation Program. Information and training may be designed to cover categories of hazards (i.e., flammability, carcinogencity) or specific products. A training program that uses both audiovisual materials and classroom type training has been prepared. The training program is divided into general awareness and department specific.

RECORDKEEPING

Written Program

Training Records

MSDS

Air monitoring records

Click icon to add picture

OVERVIEW

WHAT A common, coherent approach to classifying and communicating chemical

hazards– Harmonized definitions of hazards

– Specific criteria for labels

– Standard MSDS format

WHY Providing enhanced and consistent info on chemical hazards leads to:

– Better employee protection

– Better employee understanding

– Better trade for companies (reduced barriers)

IMPACT ON HAZCOM

Bulk of technical requirements are in Appendices

Definitions– Added, deleted, or modified

Written program

Notable changes– Using “hazard classifications” rather than “hazard determination”– MSDS’s (extensive changes)– Labels (more defined)

HAZARD CLASSIFICATIONS

Moves away from hazard determination– Performance oriented– Relies heavily on professional judgment of evaluator

• Human or animal studies• OSHA, NTP (National Toxicology Program), IRAC (International Agency for Research on

Cancer)

Specific criteria for classifying health & physical hazards into– Hazard Class – (nature of hazard – Flammability)

– Hazard Category – (degree of severity within each hazard class)

All current chemicals will need to be reclassified according to the new classes and categories

Some chemicals formerly not classified as hazard may now be hazardous

Some chemicals formerly hazardous may not be hazardous under the new criteria

Old Health Hazards GHS Health Hazards


Toxic Highly toxic Corrosive Sensitizer Target organs (kidney, liver, CNS,

etc.)

Acute toxicity Skin corrosion/irritation Serious eye damage or irritation Respiratory/skin irritant Germ cell mutagenicity Carcinogenicity Reproductive toxicity Target organ – single exposure Target organ – repeated

exposure Aspiration

Old Physical Hazards GHS Physical Hazards


Explosive Oxidizer Compressed gas Combustible liquid Flammable liquid Flammable gas Flammable solid Organic peroxide Pyrophoric Unstable Water reactive

Explosives

Flammable gases

Flammable aerosols

Oxidizing gases

Gases under pressure

Flammable liquids

Flammable solids

Self reacting chemicals

Pyrophoric solids

Self heating chemicals

Chemicals which, in contact with water, emit flammable gases

Oxidizing liquids

Oxidizing solids

Organic peroxides

Corrosive to metals

Physical Hazards Health Hazards


Name change Sections 12 -1 5 non-

mandatory Address info outside of

OSHA’s jurisdiction No change to accessibility

Standardized format Identification Hazard(s) identification Composition/information on ingredients First-aid measures Fire-fighting measures Accidental release measures Handling and storage Exposure controls/PPE Physical & chemical properties Stability & reactivity Toxicological information Ecological information Disposal considerations Transport information Regulatory information Other info, including date of preparation or

last revision

SAFETY DATA SHEET

LABELS

Written, printed or graphic information concerning the chemical that is on the container or outside packaging.

Standardized information– Pictogram– Signal Word– Hazard Statement– Precautionary Statement

LABELING

Standardized– Product identifier– Signal words

• Danger, Warning– Hazard statements– Pictograms– Precautionary statements– Supplier

A composition that may include a symbol plus other graphic elements…intended to convey specific information about the hazards of a chemical.

LABELING: PICTOGRAM

LABELING



A word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label.

Danger Warning

LABELING: SIGNAL WORD

LABELING



A statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical [and] the degree of hazard.

Examples May cause cancer May cause respiratory irritation Extremely flammable liquid and vapor Heating may cause fire and explosion

LABELING: HAZARD STATEMENT

LABELING



A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling.

Examples Do not breath dust/fume/gas/mist/vapors/spray Store in a well ventilated space Protect from sunlight

LABELING:PRECAUTIONARY STATEMENT

LABELING



LABELING: WORKPLACE

Use same GHS label provided by MFG

Another alternative (i.e. NFPA, HMIS)– Labeling method must be consistent with the revised HazCom standard

(i.e. classifications, categories, etc.)

FIFRA labels pre-empt OSHA’s label requirements– EPA has not moved to amend its labeling regulations with GHS

Does this pose a problem for workers and their employers?

LABELING: WORKPLACE

OSHA’s revised requirements could be inconsistent with FIFRA labels since some of label elements [i.e. pictogram(s), signal word(s), and/or hazard statement(s)] could be different for the same hazards.

TRAINING

Upon initial hire

New chemicals or hazards are introduced

Reason to doubt employee proficiency

GHS Label

FIFRA label– EPA guidance recommends Registrants include on their SDS the FIFRA

label info and a brief explanation for any differences between this info and that on the SDS

• Pesticide Registration (PR) Notice 2012-1

TIMELINE

Compliance dates

Effective Date Requirement Who it Affects

Dec. 1, 2013 Train all employees on the new label elements and Safety Data Sheet format

Employers

June 1, 2015 Comply with all modified provisions of this rule, except distributors that are allowed to ship products labeled by manufacturers under the old system until Dec. 1, 2015

Chemical manufacturers, importers, distributors and employers

Dec. 1, 2015 Comply with all modified provisions of the rule Distributors

June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards

Employers

Note: During the transition period, all chemical manufacturers, importers, distributors and employers may comply with either the final standard, the current standard or both. Source: OSHA

SUMMARY

Written program– Maintain and review periodically– Does it work? Can you make it better?

Provide MSDS’s or SDS’s in central location– Where are yours? Are they up-to-date? Are they

accessible? Employees trained?

Labeling– What is your system? Employees trained?

Train employees– Initially– Anytime a new hazard or chemical is introduced– New GHS requirements (Dec 1, 2013 & June 1, 2016)

Assistance– PestSure– OSHA

Policy

Training MSDS

Labels

QUESTIONS

safety tidbit... osha has estimated that more than 32 million workers are exposed to 650,000...

Documents

definitions slide

hazardous chemical products

hazardous chemicals

exposed workers

exposed employees

exposed means

possible hhazardous

effective hazcom program