Tuesday, September 29, 2015

Steps to an effective hazcom program for employers

4. Maintain Safety Data Sheets cont'd

Chemical manufacturers and importers are required to obtain or develop an SDS for each hazardous chemical they produce or import. Chemical manufacturers, importers, and distributors are responsible for ensuring that their customers are provided a copy of these SDSs, at the time of the first shipment, and when an SDS is updated with new and significant information. Employers must have an SDS for each hazardous chemical which they use. Employers may rely on the information received from their suppliers unless they know the information is incorrect. If you do not receive an SDS automatically, you must request one as soon as possible. If you receive an SDS that is obviously inadequate, with,
for example, blank spaces, you must request an appropriately completed one. If your request for an SDS or for a corrected SDS does not produce the information needed, you should contact your
local OSHA area office for assistance in obtaining the SDS. Employers must maintain the current
version of the SDS; if a new SDS is received with a shipment, they must maintain and make available
the new SDS.

The SDSs must be in English. Many larger manufacturers also produce SDSs in other languages. If you have workers who speak language(s) other than English, you may be able to obtain SDSs in those languages to ensure effective hazard communication.

Employers must maintain copies of SDSs in their workplaces, and must ensure that SDSs are readily
accessible to workers when they are in their work areas during their work shifts. This accessibility
may be accomplished in many different ways. You must decide what is appropriate for your particular workplace. Some employers keep the SDSs in a binder in a central location (e.g., in a pick-up truck on a construction site). Others, particularly in workplaces with large numbers of chemicals, provide access electronically. However, if access to SDSs is provided electronically, there must be an adequate back-up system in place in the event of a power outage, equipment failure, or
other emergency involving the primary electronic system. As long as workers can get the information
when they need it, any approach may be used. When workers must travel between workplaces during a work shift, SDSs may be kept at the primary workplace facility. No matter what system is used,  employers must ensure that workers and medical personnel can immediately obtain the required information in an emergency.

In order to ensure that you have a current SDS for each chemical in the plant as required, and that worker access is provided, OSHA’s CSHOs will be looking for the following items in your program:

1. Designation of person(s) responsible for obtaining and maintaining the SDSs;
2. How such sheets are maintained in the workplace (e.g., in notebooks in the work area(s) or electronically), and how workers obtain access to them when they are in their work area during the work shift;
3. Procedures to follow when the SDS is not received at the time of the first shipment;
4. An SDS for each hazardous chemical in the workplace, and training of workers that includes review of SDS format and use.

For employers using hazardous chemicals, an important aspect of the hazard communication program is to ensure that someone is responsible for obtaining and maintaining the SDSs for every hazardous chemical in the workplace. To ensure that your hazard communication program improves safety and health with regard to chemical use, you should review the SDSs, and use the information to choose the needed protective measures to prevent or reduce exposures in your workplace. SDSs should be used to evaluate your workplace, and establish a plan to ensure it is safe. The following is a section-by-section description of the information required for each part of the SDS from Appendix D of HazCom 2012. Become familiar with the information available in each section of an SDS so that you will be able to more quickly access this information in an emergency and make better use of the data available.

Tuesday, September 22, 2015

Steps to an effective hazcom program for employers

4. Maintain Safety Data Sheets

  • Maintain safety data sheets for each hazardous chemical in the workplace
  • Ensure that safety data sheets are readily accessible to employees
The second part in the approach to communicating information in HazCom 2012 is to maintain
SDSs (paragraph (g) Safety Data Sheets and Mandatory Appendix D). The SDSs are the source
of detailed information on hazardous chemicals. This includes information for many different
audiences—employers, workers, safety and health professionals, emergency responders, government agencies, and consumers. It is difficult for one document to serve the needs of all of these different audiences since some require much more technical information than others. Therefore, the SDS sections have generally been organized so that the information of most use to exposed workers, emergency responders, and others who do not need extensive technical detail is in the beginning of the SDS, while the more technical information most commonly read by health and safety professionals is located in the later sections. For example, a description of a chemical’s health
effects appears in Section 2, hazard identification, but the toxicological data upon which the
determination of these effects is based appears in Section 11, toxicological information. All of the
sections are available to any reader, but there is a difference between what is necessary for a broader audience (workers and emergency responders, for example), and what might be needed by others designing protective measures or providing medical services.

The SDS requirements in HazCom 2012 are based on an internationally agreed upon 16-section SDS.
This format is based on ANSI Z400.12, so it is most likely already familiar to your employees.
HazCom 2012 establishes section headings for the SDS, as well as the order in which they are to be
provided, and the minimum information required to be included in each section under Appendix D
of the standard. However, the information in some of the sections are non-mandatory because they
address information that involve the requirements of other government bodies, and thus are not
under OSHA’s jurisdiction. Even though these sections are not considered mandatory by OSHA, the headings are still required to be present on the SDS. They will provide useful information for you to address other requirements you may need to follow. The sixteen sections are as follows, with the non-mandatory sections indicated in italics:
1. Identification
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure control/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information