Tuesday, October 20, 2015

Steps to an effective hazcom training for employers

5. Inform and train employees (cont'd)

HazCom 2012 requires employers to both provide certain information to employees and to train employees. The standard requires employees to be informed of:
  • The general requirements of the Hazard Communication Standard;
  • Where hazardous chemicals are located in their work areas (operations where exposure may occur); and,
  • What the workplace hazard communication program includes, and where and how they can access the program.
 Training, on the other hand, is a more active process. The training conducted to comply with HazCom 2012 must address the following:
  •  Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
  • The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
  • The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees fromexposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and,
  •  The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the SDS, including the format of the SDS (where each type of information is located) and how employees can obtain and use the appropriate hazard information.
 A properly conducted training program will ensure worker comprehension and understanding. It is
not sufficient to either just read material to the workers, or simply hand them material to read. As explained in Dr. Michaels’ OSHA Training Standards Policy Statement (April 28, 2010), OSHA
requires employers to present information in a manner and language that their employees can
understand. If employers customarily need to communicate work instructions or other workplace
information to employees in a language other than English, they will also need to provide safety and
health training to employees in the same manner. Similarly, if the employee’s vocabulary is limited,
the training must account for that limitation. By the same token, if employees are not literate, telling
them to read training materials will not satisfy the employer’s training obligation.

In conducting a training program, you want to create a climate where workers feel free to ask questions. This will help you to ensure that the information is understood. You must always remember that the underlying purpose of the HCS is to reduce the incidence of chemical source
illnesses and injuries. This will be accomplished by modifying behavior through the provision of hazard information and information about protective measures. If your program works, you and your
workers will better understand the chemical hazards in the workplace, and how to protect workers from experiencing adverse effects. The procedures you establish regarding, for example, purchasing,
storing, and handling of these chemicals will improve, and thereby reduce the risks posed to workers exposed to the chemical hazards involved.

Friday, October 9, 2015

Steps to an effective hazcom program for employers

5. Inform and Train Employees

  • Train employees on the hazardous chemicals in their work area before initial assignment, and when new hazards are introduced

  • Include the requirements of the standard, hazards of chemicals, appropriate protective measures, and where and how to obtain additional information 

    The third part of the hazard communication approach in HazCom 2012 is employee information and training (paragraph (h) Employee Information and Training). The key requirement is in paragraph (h)(1):
    (h)(1) Employers shall provide employees with effective information and training on hazardous
    chemicals in their work area at the time of their initial assignment, and whenever a new  chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemicalspecific information must  always be available through labels and safety data sheets.

    For information and training to be effective, the workers in the training must comprehend the
    hazards in the workplace and ways to protect themselves. OSHA does not expect that workers
    will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools. Workers must also be aware of the protective measures available in their workplace, how to use or implement these measures, and who they should contact if an issue arises.

    Information and training may be done either by individual chemical, or by hazard classes and
    categories (such as acute toxicity or flammable liquids). If there are only a few chemicals in the
    workplace, then you may want to discuss each one individually. Where there are large numbers of chemicals, or the chemicals change frequently, you will probably want to train generally based on the hazard classes and categories. Workers must have access to the substance-specific information on the labels and SDSs.

Monday, October 5, 2015

Steps to an effective hazcom program for employers

4. Maintain Safety Data Sheets cont'd

Minimum information for SDS:

Section 1: Identification

This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. The required information consists of:
  • Product identifier used on the label and any other common names or synonyms by which the substance is known.
  • Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.
  • Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier). 1

Section 2: Hazard(s) Identification

This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards. The required information consists of:
  • The hazard classification of the chemical (e.g., flammable liquid, category1).
  • Signal word.
  • Hazard statement(s).
  • Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions of the symbols in black and white or be a description of the name of the symbol (e.g., skull and crossbones, flame).
  • Precautionary statement(s).
  • Description of any hazards not otherwise classified.
  • For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please note that this is a total percentage of the mixture and not tied to the individual ingredient(s).

Section 3: Composition/Information on Ingredients

This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of:
Substances
  • Chemical name.
  • Common name and synonyms.
  • Chemical Abstracts Service (CAS) number and other unique identifiers.
  • Impurities and stabilizing additives, which are themselves classified and which contribute to the classification of the chemical.
Mixtures
  • Same information required for substances.
  • The chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards and are:
    • Present above their cut-off/concentration limits or
    • Present a health risk below the cut-off/concentration limits.
  • The concentration (exact percentages) of each ingredient must be specified except concentration ranges may be used in the following situations:
    • A trade secret claim is made,
    • There is batch-to-batch variation, or
    • The SDS is used for a group of substantially similar mixtures.
Chemicals where a trade secret is claimed
  • A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required.

Section 4: First-Aid Measures

This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. The required information consists of:
  • Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion).
  • Description of the most important symptoms or effects, and any symptoms that are acute or delayed.
  • Recommendations for immediate medical care and special treatment needed, when necessary.

Section 5: Fire-Fighting Measures

This section provides recommendations for fighting a fire caused by the chemical. The required information consists of:
  • Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation.
  • Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns.
  • Recommendations on special protective equipment or precautions for firefighters.

Section 6: Accidental Release Measures

This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. The required information may consist of recommendations for:
  • Use of personal precautions (such as removal of ignition sources or providing sufficient ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing.
  • Emergency procedures, including instructions for evacuations, consulting experts when needed, and appropriate protective clothing.
  • Methods and materials used for containment (e.g., covering the drains and capping procedures).
  • Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning or vacuuming; adsorbent materials; and/or equipment required for containment/clean up)

Section 7: Handling and Storage

This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information consists of:
  • Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited).
  • Recommendations on the conditions for safe storage, including any incompatibilities. Provide advice on specific storage requirements (e.g., ventilation requirements)

Section 8: Exposure Controls/Personal Protection

This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of:
  • OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available.
  • Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed system).
  • Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, skin or respiratory protection needed based on hazards and potential exposure).
  • Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; and breakthrough time of the glove material).

Section 9: Physical and Chemical Properties

This section identifies physical and chemical properties associated with the substance or mixture. The minimum required information consists of:
  • Appearance (physical state, color, etc.);
  • Upper/lower flammability or explosive limits;
  • Odor;
  • Vapor pressure;
  • Odor threshold;
  • Vapor density;
  • pH;
  • Relative density;
  • Melting point/freezing point;
  • Solubility(ies);
  • Initial boiling point and boiling range;
  • Flash point;
  • Evaporation rate;
  • Flammability (solid, gas);
  • Partition coefficient: n-octanol/water;
  • Auto-ignition temperature;
  • Decomposition temperature; and
  • Viscosity.
The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust's explosive potential

Section 10: Stability and Reactivity

This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other. The required information consists of:
Reactivity
  • Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available.
Chemical stability
  • Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled.
  • Description of any stabilizers that may be needed to maintain chemical stability.
  • Indication of any safety issues that may arise should the product change in physical appearance.
Other
  • Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur.
  • List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions).
  • List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation.
  • List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.)

Section 11: Toxicological Information

This section identifies toxicological and health effects information or indicates that such data are not available. The required information consists of:
  • Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact). The SDS should indicate if the information is unknown.
  • Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
  • The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a single dose.
  • Description of the symptoms. This description includes the symptoms associated with exposure to the chemical including symptoms from the lowest to the most severe exposure.
  • Indication of whether the chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions) or found to be a potential carcinogen by OSHA

Section 12: Ecological Information (non-mandatory)

This section provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment. The information may include:
  • Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available (e.g., acute or chronic aquatic toxicity data for fish, algae, crustaceans, and other plants; toxicity data on birds, bees, plants).
  • Whether there is a potential for the chemical to persist and degrade in the environment either through biodegradation or other processes, such as oxidation or hydrolysis.
  • Results of tests of bioaccumulation potential, making reference to the octanol-water partition coefficient (Kow) and the bioconcentration factor (BCF), where available.
  • The potential for a substance to move from the soil to the groundwater (indicate results from adsorption studies or leaching studies).
  • Other adverse effects (e.g., environmental fate, ozone layer depletion potential, photochemical ozone creation potential, endocrine disrupting potential, and/or global warming potential).

Section 13: Disposal Considerations (non-mandatory)

This section provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS. The information may include:
  • Description of appropriate disposal containers to use.
  • Recommendations of appropriate disposal methods to employ.
  • Description of the physical and chemical properties that may affect disposal activities.
  • Language discouraging sewage disposal.
  • Any special precautions for landfills or incineration activities

Section 14: Transport Information (non-mandatory)

This section provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea. The information may include:
  • UN number (i.e., four-figure identification number of the substance)1.
  • UN proper shipping name1.
  • Transport hazard class(es)1.
  • Packing group number, if applicable, based on the degree of hazard2.
  • Environmental hazards (e.g., identify if it is a marine pollutant according to the International Maritime Dangerous Goods Code (IMDG Code)).
  • Guidance on transport in bulk (according to Annex II of MARPOL 73/783 and the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (International Bulk Chemical Code (IBC Code)).
  • Any special precautions which an employee should be aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises (indicate when information is not available).

Section 15: Regulatory Information (non-mandatory)

This section identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. The information may include:
  • Any national and/or regional regulatory information of the chemical or mixtures (including any OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product Safety Commission regulations)

Section 16: Other Information

This section indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here.

Employer Responsibilities

Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency. Furthermore, employers may want to designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.