Wednesday, April 29, 2015

Steps to an effective hazcom program for employers

3. Ensure Containers are Labeled

  • Keep labels on shipped containers
  • Label workplace containers where required
 Labels are the first part (paragraph (f) Labels and Other Forms of Warning) of the three-part approach
to communicating information downstream mentioned earlier. A label must be on the immediate container of every hazardous chemical. The label is an immediate type of warning since it is present in the work area, right on the actual container of a hazardous chemical. It is a snapshot of the hazards and protective information related to the chemical, and a summary of the more detailed information available on the SDS.
When you purchase a hazardous chemical from a supplier, you will receive a container that is labeled with the information required under the HCS. Employers can rely on the information provided by their suppliers. The label requirements in the HCS changed significantly with the publication of HazCom 2012. Under the prior standard, chemical manufacturers and importers were required to convey the hazards and identity of the products, but were not given specifications on how this was to be done. As a result, labels varied in terms of how the information was conveyed, the terminology used, and the design of the label. This made it more difficult for employers and workers to access and comprehend the information presented than if chemical manufacturers and importers follow the same approach.
The label requirements for the revised standard are more specific, which will lead to increased uniformity. This should benefit employers and workers by providing the information in standardized language and graphics, making it easier to understand, and helping to ensure that labels on containers of the same chemical from different suppliers have the same information.
HazCom 2012 provides chemical manufacturers and importers the information to be conveyed once they have determined the hazard of a chemical. The labels you receive on a shipped container must have the following information, located together (other information may also appear on the label):
■ Product identifier
■ Signal word
■ Hazard statement(s)
■ Pictogram(s)
■ Precautionary statement(s)
■ Name, address, and phone number of the responsible party
■ The product identifier is any chemical, common, or trade name or designation that the chemical manufacturer or importer chooses to use on the label. The term must also appear on the SDS. The signal word, hazard statement(s), pictogram(s), and precautionary statement(s) are the label elements that comprise the primary information about hazards and protective measures on the label.
■ A signal word is a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in the standard are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for the less severe hazards. Signal words were not
previously used in the HCS, although they do often appear on consumer labels. It is important to be aware of—and train workers on—the way signal words convey a difference in the severity of the hazard. While the product is hazardous wherever a signal word is indicated, the signal word chosen can give a preliminary idea of the relative significance of the effect.
■ A hazard statement is a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Example: Fatal if swallowed.
The hazard statement(s) for a hazardous chemical describe the hazard(s) in text, in a simple, direct manner. There is a hazard statement for each hazard category of a hazard class, and it will vary depending on the degree of hazard. The example presented above is a hazard statement for acute oral toxicity. The hazard statement conveys that the chemical is severely toxic, and ingestion of the chemical results in death. But for less toxic chemicals, the hazard statement may be “toxic if swallowed” or “harmful if swallowed.” As with
the signal words, this information conveys the relative severity of the hazard, which impacts how it is handled and controlled.
■ A pictogram is a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category. Under HazCom 2012, pictograms are black symbols, on a white background, with a red diamond border. For example, this is the pictogram for oxidizers:
Pictograms are an important addition to the hazard communication tools in the standard. A pictogram draws the attention of a label reader, and you and your workers should be aware that the appearance of a pictogram in a red diamond frame means that a hazard of concern is present in the product. Some of the
pictograms in the standard have symbols that resemble the hazardous effect, and others are merely meant to attract attention. Pictograms may be used for several different hazardous effects as well.
Pictograms have long been used internationally because they convey information without text. This allows users who are either literate in a different language than that used on the label or who are not literate at all to understand that the chemical is hazardous.
One of the systems that has long used pictograms is the international transport system. This system has been adopted by the U.S. Department of Transportation (DOT), and is familiar to those who handle shipping containers in the United States. The symbols have been harmonized as much as possible for the hazards covered both in transport and in the workplace. While both pictograms are diamond-shaped, the transport system’s pictograms have backgrounds of various colors. Where the shipping container is also the container used in the workplace, workers must be made aware of the DOT pictograms1, as they may appear on the label in addition to, or instead of, the HazCom 2012 pictograms used to represent the same hazard. See Figure 4 for examples of DOT pictograms. Note that the environment pictogram located in the center
of the bottom row in Figure 3 is not required under the OSHA standard since OSHA does not regulate environmental hazards. However, you may see this pictogram used on labels and SDSs to convey environmental hazards, and that will provide useful information for you to use in managing your chemicals.

Friday, April 17, 2015

Steps to an effective hazcom program for employers

2. Prepare and implement a written hazard communication program

  • Prepare a written plan to indicate how hazard communication will be addressed in your facility.
  • Prepare a list or inventory of all hazardous chemicals in the workplace.
 Paragraph (e), Written Hazard Communication Program, requires employers to prepare and implement a written hazard communication program. This does not need to be lengthy or complicated. The main intent of the requirement is to help ensure that compliance with the standard is done in a systematic way and that all elements are coordinated. Thus, the program must describe how the employer will address the requirements
of paragraphs (f) Labels and Other Forms of Warning; (g) Safety Data Sheets; and (h) Employee Information and Training, in the workplace. A sample written program is provided in Appendix A of this guide.
In addition, the written program must include the following items:
■ Paragraph (e)(1): A list of the hazardous chemicals known to be present in the workplace. The list may be kept using any product identifier from the SDS. Thus, the list may be kept by product name, common name,
or chemical name. The important aspect of this requirement is that the term used on the list must also be available on both the SDS and the label so that these documents can be cross-referenced. The list can be compiled in whatever way the employer finds most useful and applicable to the workplace. A list of all
hazardous chemicals in the entire workplace may be most suitable for very small facilities, where there are few work areas and all workers are potentially exposed to essentially the same products. For larger workplaces, it may be more convenient to compile lists of hazardous chemicals by work area and have
them assembled together as the overall list for the workplace. The list is an inventory of chemicals for which
the employer must ensure that there is an SDS available. Compiling the list also helps employers keep track of the chemicals present, and to identify chemicals that are no longer being used, and thus could be removed from the workplace. Removing such chemicals may also reduce potential adverse effects that could occur in the workplace.
The best way to prepare a comprehensive list may be to survey the workplace. Purchasing records may also help and employers should establish procedures to ensure that purchasing procedures result in receiving SDSs before a material is used in the workplace. Prior to purchasing chemicals, review the hazards of the chemicals and evaluate if less hazardous chemicals can be used instead.
“Product identifier” means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS.
The broadest possible perspective should be taken when doing the survey. Sometimes people think of “chemicals” as being only liquids in containers. The HCS covers chemicals in all forms—liquids, solids, gases, vapors, fumes, and mists—whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If the chemical is not hazardous, it is not covered by the standard. If there is no potential for exposure (e.g., the chemical is inextricably bound and cannot be released), the chemical is not covered by the standard.
Look around. Identify chemicals in containers, including pipes, but also think about chemicals that are generated during work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Read the labels provided by suppliers for hazard information. Make a list of all chemicals in the workplace that are potentially hazardous. For your own information and planning, you may
also want to note on the list the location(s) of the products within the workplace, and an indication of the hazards as found on the label. This will help as you prepare the rest of your program.
Paragraph (b) of the standard, scope and application, includes exemptions for various chemicals or workplace situations. After compiling the complete list of chemicals, you should review paragraph (b) to determine if any of the items can be eliminated from the list because they are exempted materials. For example, food, drugs, and cosmetics brought into the workplace for personal consumption by workers are exempt.
Once you have compiled a complete list of the potentially hazardous chemicals in the workplace, the next step is to determine if you have received SDSs for all of them. Check your files against the inventory you have just compiled. Employers are required to have SDSs for all hazardous chemicals that they use. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by keeping a copy of a letter or e-mail, or a note regarding telephone conversations. If you cannot show a good faith effort to receive the SDS, you can be cited for not having the SDS for a hazardous chemical. If you have SDSs for chemicals that are not on your list, figure out why. Maybe you do not use the chemical anymore. Or maybe you missed it in your survey. Some suppliers provide SDSs for products that are not hazardous. These SDSs do not have to be maintained.
Do not allow workers to use any hazardous chemicals for which you have not received an SDS. The SDS provides information you need to ensure that proper protective measures are implemented prior to worker exposure.
■ Paragraph (e)(1)(ii): Methods to inform employees of the hazards of non-routine tasks. The written program needs to include how an employer will inform workers of hazards that are outside of their normal work routine. While workers’ initial training will address the types of exposures they will encounter in their
usual work routines, there may be other tasks to be performed on occasion that will expose these workers to different hazards, as well as require novel control measures. For example, in a manufacturing facility, it may be necessary periodically to drain and clean out reactor vessels. For this task, workers may be exposed to cleaning chemicals that are not normally in the workplace, and the usual controls for the process may not protect them, so personal protective equipment may have to be worn. The written program needs to address how the employer will handle such situations and make sure that workers involved have the necessary information to stay protected.
■ Paragraph (e)(2): Multi-Employer Workplaces. Where there is more than one employer operating on a site, and employees may be exposed to the chemicals used by each employer, the employer’s written hazard
communication program must address:
— How on-site access to SDSs will be provided to the other employer(s).
— How such employers will be informed of needed precautionary measures.
— How such employers will be informed of the on-site labeling system if it is different from the labels specified for shipped containers under the standard.
In summary, if you are not a new employer, you should already have a written hazard communication program for your workplace. Review your written program to ensure that it is consistent with the HazCom 2012 requirements. It may need to be updated; for example, you may have to add or delete chemicals from the list in the program, or change your description of the approach to workplace labeling.
If your workers’ job assignment requires travel between various geographical locations, you may keep the written program at the primary work location.
Many trade associations and other professional groups have provided sample programs and other assistance materials to employers. These have been very helpful to many employers since they tend to be tailored to the particular industry involved. You may wish to investigate whether your industry trade groups have developed such materials. Additionally, a sample written hazard communication program is included in Appendix A
to this guide.
Although such general guidance may be helpful, you must remember that the written program has to reflect what you are doing in your workplace. Therefore, if you use a generic program it must be adapted to address the facility that it actually covers. For example, the written plan must list the chemicals present at the site, indicate who is to be responsible for the various aspects of the program in your facility, and indicate where written materials will be made available to workers.
If OSHA inspects your workplace, the OSHA Compliance Safety and Health Officer (CSHO) will ask to see your written plan.

Monday, April 6, 2015

Steps to an effective hazcom program for employers

1. Learn the Standard/Identify Responsible Staff

Obtain a copy of OSHA’s Hazard Communication Standard.
• Become familiar with its provisions.
• Make sure that someone has primary responsibility for coordinating implementation.
• Identify staff for particular activities (e.g., training).

 You are already on your way to accomplishing Step 1 by reading this guide. It is always best to review the actual provisions of the standard to ensure you are in full compliance. OSHA provides online access to the standard, as well as guidance, interpretations, and other relevant materials on its hazard communication web page: www.osha.gov/dsg/hazcom. The full regulatory text can be found at: www.osha.gov/dsg/hazcom/
HCSFinalRegTxt.html.

As noted above, the provisions that apply to employers simply using chemicals in the workplace, rather than those that produce or import chemicals, are found primarily in the following paragraphs:
(e) Written Hazard Communication Program;
(f) Labels and Other Forms of Warning;
(g) Safety Data Sheets; and
(h) Employee Information and Training.

You can focus on the requirements in these paragraphs to determine what is needed for compliance in your workplace. There may also be other provisions of the standard that help establish compliance requirements in some workplaces.

Paragraph (b), Scope and Application, specifies two types of work operations where the coverage of the rule is limited. These are laboratories and operations where chemicals are only handled in sealed containers (e.g., a warehouse). Employers with these types of work operations have reduced obligations under the HCS and basically only need to keep labels on containers as they are received; maintain SDSs that are received, and give employees access to them; and provide information and training to employees. Laboratories and operations where chemicals are only handled in sealed containers do not have to have written hazard communication programs and lists of chemicals.

The limited coverage for laboratories and sealed container operations addresses your obligation to your own workers in the operations involved. However, when laboratory employers or employers where only sealed containers are involved act as chemical manufacturers, distributors or importers, they must fulfill their duties as suppliers. For example, in warehouse operations where the employees are only exposed to sealed containers, paragraph (b)(4) of the standard would apply. When these chemicals are distributed to downstream users, paragraph (b)(4) requires the company to provide HazCom 2012-compliant labels and SDSs to downstream customers at the time of the first shipment and when the SDS is updated.

Paragraph (c), Definitions, can be used to determine the meaning of some provisions in HazCom 2012 through the definitions provided for the terms used in them. This guide will highlight some of these definitions, but you may want to consult the definitions for other terms to help ensure you fully understand your  compliance obligations in the workplace.

Hazard communication must be a continuing program in your facility. Compliance with the HCS is not a “one shot deal.” In order to have a successful program, it will be necessary to assign responsibility to staff for both the initial and ongoing activities needed to comply with the standard. In some cases, these activities may already be part of current job assignments. For example, site supervisors are frequently responsible for on-the-job training sessions. Early identification of the responsible workers, and their involvement in the development of your plan of action, will result in a more effective program design.

In order to ensure you have an effective program and address all of the necessary components, responsibility for implementation of hazard communication should be assigned to someone to coordinate. While different
people may be responsible for certain parts of implementation, there should nevertheless be someone who has overall responsibility. Approaching compliance consistently, and comprehensively, is the key to success.

The person responsible for the overall coordination may not be the best person to accomplish all of the elements. For example, training workers may require different expertise than coordinating compliance. The standard allows employers the flexibility to do what is best in their own facilities as long as compliance with all elements is achieved.