Hazard Communication

MODULE 11

Purpose of OSHAs Hazard Communication Standard

ensure that employers and employees know about work hazards and how to protect themselves so that the incidence of illnesses and injuries due to hazardous chemicals is reduced.
Hazard Communication Program
Program

Container Labeling

Material Safety Data Sheet

MSDS

Label

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Why should chemical hazards be communicated?

Exposure Risk: About 32 million workers potentially exposed to chemical hazards Profusion of Chemicals: About 650,000 chemical products exist; hundreds of new ones introduced annually Health Effects: May include heart ailments, central nervous system damage, kidney and lung damage, sterility, cancer, burns, and rashes Safety Hazards: Potential to cause fires, explosions, or other serious accidents
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Concept of regulation:
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.
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Who is covered?
General industry, shipyard, marine terminals, longshoring, and construction employers Chemical manufacturers, importers, employers, and employees exposed to chemical hazards

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

Appendix E provides guidelines

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Employer Responsibilities
Inventory: Identify and list hazardous chemicals in workplaces MSDS & Labeling: Obtain Material Safety Data Sheets and labels for each hazardous chemical, if not provided by the manufacturer, importer, or distributor Written Program: Implement a written HazCom program, including labels, MSDS, and employee training Communication & Training: Communicate hazard information to employees through labels, MSDSs, and formal training programs
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Labeling Exemptions
Other federal agencies control labeling requirements for the following substances:
Pesticides Chemicals covered under the Toxic Substance Control Act Foods or food additives Distilled spirits, tobacco Consumer products, lumber, cosmetics Hazardous wastes
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How can workplace hazards be minimized?

Hazard Assessment: The first step in minimizing workplace hazards is to perform a thorough hazard assessment Manufacturer Evaluations: Employers can rely on the manufacturers or importers evaluations of the hazards of the chemicals they use (from MSDS)

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Why is a written program required?

Employer: Program ensures that all employers receive the information they need to inform and train their employees Employee: Program provides necessary hazard information to employees

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Employer RequirementsWritten Program

Must cover at least:
Labels and other forms of warnings Material Safety Data Sheets Employee Information and Training List of chemicals present and MSDS for each Methods used to inform employees of hazards of non-routine tasks Hazards of chemicals in unlabeled pipes
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Multi-Employer Workplaces
When other employers have employees onsite that may be exposed, program must include:
Methods to provide contractor employees with on-site access to MSDS Methods used to inform other employers of precautionary measures for normal and emergency situations The employers chemical labeling system
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Consumer Products Exemption

Any consumer product as defined in the Consumer Product Safety Act where:
Used in the workplace for the purpose intended Exposure within the range that could reasonably be experienced by consumers when used for intended purpose

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Written Program Availability

Written program available on request:
To employees and their representatives Program may be kept at main location

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How must chemicals be labeled?

Containers of hazardous chemicals entering workplace must be labeled with
Identity of chemical Appropriate hazard warnings
Message, picture or symbol Hazards of chemical Target organs affected Legible in English, may have other languages

Name and address of responsible party

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Container Labeling Exemptions

No new labels necessary if existing labels convey required information Labeling not required for portable containers if:
Transferred from labeled containers and Intended for immediate use by employee performing transfer

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Material Safety Data Sheets

Prepared by chemical manufacturer or importer, describing
Physical hazards, such as fire and explosion Health hazards, such as signs of exposure Routes of exposure Precautions for safe handling and use Emergency and first-aid procedures Control measures
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Material Safety Data Sheets

Must be in English and include specific chemical identity and common names Must provide information about:
Physical and chemical characteristics Health effects Exposure limits Carcinogenicity (cancer-causing) Identification (name, address, and telephone number) of the organization responsible for preparing the sheet Must be readily accessible to employees in their work area
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Material Safety Data Sheets

No prescribed format If no MSDS received for a chemical:
Contact supplier, manufacturer or importer Maintain record of the contact

May be kept in any form including operating procedures Addressing hazards of process may make more sense than individual chemicals
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Employee Information and Training

Employees must be provided information and training on hazardous chemicals in their work area:
At the time of their initial assignment Whenever a new physical or health hazard is introduced into their work area May cover categories of hazards or individual chemicals
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Employee Information
Employers must inform employees of:
Training requirements of this section Operations in their work area where hazardous chemicals are present; Location and availability of the written hazard communication program

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What must employee training contain?

Program: Explanation of the HazCom program, including information on labels, MSDSs, and how to obtain and use available hazard information Physical and health hazards of chemicals Protection: Protective measures such as engineering controls, work practices, and the use of PPE Detection: How to detect the presence or release of a hazardous chemical (using monitoring devices, observation, or smell)
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Health Hazard Definitions

Acute: rapid effects, as a result of short-term exposures, of short duration Chronic: effects as a result of long-term exposure, of long duration Corrosive: Visible destruction or irreversible damage to body tissue, including acids and caustics (bases) Definitions in 1910.1200 Appendix A
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Target Organ Effects

Hepatotoxins: liver damage Nephrotoxins: kidney damage Neurotoxins: nervous system effects Agents which act on the blood or hematopoietic system: deprive body tissues of oxygen Agents which damage the lungs
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Target Organ Effects

Reproductive toxins, including teratogens (damage fetuses) and mutagens (damage DNA) Cutaneous hazards: skin damage Eye hazards

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Setting up a program
The Hazard Communication Standard covers both:
Physical hazards (such as flammability), and Health hazards (such as irritation, lung damage, and cancer)

Most chemicals used in the workplace have some hazard potential, and thus will be covered by the rule
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Setting up a program
This rule is more performance-oriented than many other OSHA regulations. You have flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific, rigid requirements

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Setting up a program
Make a list of all chemicals in the workplace that are potentially hazardous
Survey the workplace to make a comprehensive list Identify chemicals in containers, including pipes

Establish purchasing procedures so that MSDSs are received before a material is used in the workplace
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Identify hazardous chemicals in the workplace

Compile a complete list of the potentially hazardous chemicals in the workplace Determine if you have received material safety data sheets for all of them If any are missing, contact your supplier and request one Do not allow employees to use any chemicals for which you have not received an MSDS
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Preparing and implementing a hazard communication program

All workplaces where employees are exposed to hazardous chemicals must have a written plan The plan does not have to be lengthy or complicated

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Employee Training
You may want to discuss each chemical individually if there are only a few chemicals in the workplace You may want to train generally:
Based on the hazard categories (e.g., flammable liquids, corrosive materials, carcinogens) Where there are large numbers of chemicals or Where the chemicals change frequently
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Training Documentation
The rule does not require employers to maintain records of employee training, but many employers choose to do so This may help you monitor your own program to ensure that all employees are appropriately trained

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