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Introduc)on
• Hazard Communica)on Advanced • Welcome!
– This presenta)on emphasizes the health and physical hazards, and safe work prac)ces surrounding hazardous chemicals in the workplace.
TIP: This presentation is not a substitute for any of the provisions of the Occupational Safety and Health Act of 1970 or for any standards issued by the U.S. Department of Labor. (See 29 CFR 1910.1200 for further information on the standard). Mention of trade names, commercial products, or organizations does not imply any endorsement.
Introduc)on
• Learning Objec)ves • Following this training the student should be able to: • Describe the benefits provided to employees by the Hazard Communica)on Standard (HCS). • List at least four fundamental elements of OSHA’s Hazard Communica)on Standard. • List the 3 primary areas of change to OSHA’s Hazard Communica)on Standard. • Describe at least four required elements of a hazardous chemical label. • Iden)fy the hazards represented by the nine GHS pictograms. • Describe the primary benefits of using an MSDS or an SDS for a hazardous chemical. • Name the required elements of an employer’s wriSen hazard communica)on program. • Iden)fy at least three of the employer’s fundamental responsibili)es under the hazard
communica)on standard. • Recognize when training beyond the scope of this advanced course is necessary.
TIP: “Hazard Communication” is also known as or referred to as Hazard Communication, HCS or even Employee Right to Know)
Introduc)on
• What is Hazard Communica)on? • Chemicals pose a wide range of hazards.
– OSHA's Hazard Communica)on Standard (HCS) is designed to ensure that informa)on about these hazards and protec)ve measures is circulated.
– Chemical manufacturers and importers must evaluate the hazards of chemicals they manage, provide informa)on through labels and safety data sheets (SDSs).
– Employers with hazardous chemicals must: • prepare and implement a wriSen hazard communica)on program, • ensure that containers are labeled, • Ensure that employees are provided access to SDSs, • provide effec)ve training for all poten)ally exposed employees.
Introduc)on
• Benefits • Several benefits are an)cipated with the successful comple)on of this
course. These include: – Training incorpora)ng the latest regulatory requirements and revisions to
HCS; – Clearly understand the requirements of OSHA’s Hazard Communica)on
Standard; – Understand the elements of a wriSen Hazard Communica)on Program; – Promote compliance with OSHA’s HCS; – Minimize poten)al of cita)on and penalty for one of the top standards cited
by OSHA; – Basics of hazardous chemical iden)fica)on, evalua)on and control
techniques; – Poten)al mi)ga)on of hazardous chemical exposures resul)ng in possible
injury and illness, spill cleanup costs etc.
Introduc)on
• Why should chemical hazards be communicated?
• Exposure Risk: Es)mated more than 43 million workers poten)ally exposed to chemical hazards
• # of Chemical Products: Nearly 1 million 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 / Physical Hazards: Poten)al to cause fires, explosions, or oter serious accidents
• Environmental Hazards: Poten)al damage to the environment, plant and animal species.
Who is covered by HCS? General industry, shipyard, marine terminals, longshoring, and construction employers. Chemical manufacturers, importers, employers, and employees exposed to chemical hazards.
Introduc)on
• Purpose of OSHA’s Hazard Communica)on 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.”
TIP: All workplaces where employees are exposed to hazardous chemicals must have a written Hazard Communication Program plan that describes how the standard will be implemented in that facility.
Defini)ons
• Defini)ons • There are a number of very important defini)ons when
talking about hazardous chemicals and hazard communica)on. We’ve provided a PDF from OSHA containing many defini)ons related to hazard communica)on. In the PDF you will be directed to those defini)ons the authors of this course believe are second )er most important (highlighted in yellow) and others that are specified in OSHA’s Hazard Communica)on standard. It is important to note that all the defini)ons are important, otherwise OSHA would not have included them. However those highlighted in the next screens are believed to be the most important by the author for the student to learn at the Advanced level about Hazard Communica)on.
Defini)ons
• Container • "Container" means any bag, barrel, boSle, box, can, cylinder, drum, reac)on vessel, storage tank, or the like that contains a hazardous chemical. For purposes of the HCS, pipes or piping systems, and engines, fuel tanks, or other opera)ng systems in a vehicle, are not considered to be containers.
Defini)ons
• Exposure or Exposed • "Exposure or exposed" means that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes poten)al (e.g. accidental or possible) exposure. "Subjected" in terms of health hazards includes any route of entry (e.g. inhala)on, inges)on, skin contact or absorp)on.)
Defini)ons
• Foreseeable emergency • "Foreseeable emergency" means any poten)al occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.
TIP: Employers would be wise to plan for “worst-case scenarios” as far as potential releases of hazardous chemicals at their facility and must plan accordingly to protect the health and safety of their employees.
Defini)ons
• Hazardous chemical • "Hazardous chemical" means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combus)ble dust, pyrophoric gas, or hazard not otherwise classified.
Defini)ons
• Health hazard • "Health hazard" means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irrita)on; serious eye damage or eye irrita)on; respiratory or skin sensi)za)on; germ cell mutagenicity; carcinogenicity; reproduc)ve toxicity; specific target organ toxicity (single or repeated exposure); or aspira)on hazard.
Defini)ons
• Physical hazard • "Physical hazard" means a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-‐reac)ve; pyrophoric (liquid or solid); self-‐hea)ng; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.
Recent HCS Revisions
• Hazard Communica)on (HCS) – The hazard communica)on standard is meant to ensure that the hazards of all chemicals produced or imported are classified, and that informa)on concerning the classified hazards is transmiSed to employers and employees.
Employees have a right to know: The identities and the hazards of chemicals they are exposed to. Protective measures. Nearly all workers in all sectors are covered by OSHA’s Hazard Communication Standard.
Recent HCS Revisions
• HCS Revisions • Major revisions to OSHA’s Hazard Communica)on Standard or HCS
fall in three primary areas: – Hazard classifica)on: Provides specific criteria for classifica)on of
health and physical hazards, as well as classifica)on of mixtures. – Labels: Chemical manufacturers and importers will be required to
provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precau)onary statements must also be provided.
– Safety Data Sheets: Will now have a specified 16-‐sec)on format.
TIP: The HCS is a generic standard that covers nearly all hazardous chemicals as well as all workplaces where they are used. The concept behind the HCS is that providing information to employers and employees enables them to take steps to ensure protection in their workplaces. It works to reduce illnesses and injuries when employers and employees modify their behavior as a result of receiving the information about the hazards. Employees have a right-to-know the hazards and the identities of the chemicals they are exposed to under the requirements of the HCS. But equally important in terms of worker protection is that employers have access as well. Before the HCS was promulgated, some companies provided such information voluntarily to their customers. But the quality of it ranged significantly, many trade secrets were claimed, and the delivery of it was inconsistent.
Recent HCS Revisions
• What is the GHS? – The GHS: The Globally Harmonized System of Classifica)on and Labeling of Chemicals.
– System for standardizing and harmonizing the classifica)on and labeling of chemicals.
– This system was agreed on at an interna)onal level by governments, industry, and labor, and adopted by the United Na)ons (UN) in 2002.
GHS #6
Recent HCS Revisions
• What is the schedule for implementa)on? – The )meline for implementa)on in the U.S. is as follows:
Date Requirement Who
12/1/2013 Train employees on the new labels and SDSs
Employers
6/1/2015 Comply with final rule except chemical distributors may ship containers without GHS labels
Chemical manufacturers, importers, distributors and employers
12/1/2015 Shipment of chemicals without GHS labels prohibited
Chemical manufacturers, importers, distributors and employers
6/1/2016 Update Hazard Communica)on program; addi)onal training as necessary for newly iden)fied physical or health hazards
Employers
Recent HCS Revisions
• Benefit of Aligning the HCS to the GHS • The Primary benefit is to increase the quality and consistency of informa)on provided to workers, employers and chemical users. – Reduce confusion and increase comprehension of hazards
– Improve downstream risk management – Facilitate training – Help address literacy problems
• Other benefits include facilita)on of interna)onal trade in chemicals.
Recent HCS Revisions
• What are other benefits of incorpora)ng GHS into OSHA’s Hazard Communica)on Standard? – The basic goal of hazard communica)on is to ensure that employers, employees and the public are provided with adequate, prac)cal, reliable and comprehensive informa)on on the hazards of chemicals in order to protect themselves.
– This provides benefits for: • Governments • Companies • Workers • Public
Responsibili)es
• Hazard Communica)on Responsibili)es • Manufacturers, Importers and Distributors
– The hazard communica)on standard's design is simple.
– Chemical manufacturers and importers must evaluate the hazards of the chemicals they produce or import. Using that informa)on, they must then prepare labels for containers and more detailed technical bulle)ns called safety data sheets (SDSs), formerly known as material safety data sheets (MSDSs).
Responsibili)es
• Hazard Communica)on Responsibili)es • Manufacturers, Importers and Distributors
– Chemical manufacturers, importers, and distributors of hazardous chemicals are all required to provide the appropriate labels and SDSs to the employers to whom they ship the chemicals. The informa)on must be provided automa)cally.
– Every container of hazardous chemicals an employer receives must be labeled, tagged, or marked with the required informa)on.
– The suppliers also must send a properly completed SDS at the )me of the first shipment of the chemicals, and with the next shipment aler the SDS is updated with new and significant informa)on about the hazards.
TIP: Remember, a “Hazardous chemical” means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
Responsibili)es
Hazard Communica)on Responsibili)es • What is the employers responsibility?
– Iden)fy and list hazardous chemicals in their workplaces. This includes developing a hazardous chemical inventory;
– Obtain SDSs and labels for each hazardous chemical, if not provided by the manufacturer, importer, or distributor;
– Develop and implement a wriSen hazard communica)on program, including labels, SDSs, and employee training, on the list of chemicals, SDSs and label informa)on; and
– Communicate hazard informa)on to their employees through labels, SDSs, and formal training programs.
Responsibili)es
Hazard Communica)on Responsibili)es • What is the employees responsibility?
– ASend an employers training to gain knowledge of: • Safety Data Sheets • Label, signage and warning requirements • Chemical hazards and warnings applicable to the workplace, including possible entry and work in areas of hazardous chemical use or storage
• Know what to do in the event of a hazardous chemical incident such as a fire, leak, rupture or spill
• Know how to acquire SDSs of the product being used.
TIP: Employees must never bring hazardous chemicals onto the worksite without the employers knowledge and authorization.
Responsibili)es
Hazard Communica)on Responsibili)es • What is the employees responsibility?
– Follow safe work prac)ces established at the workplace which also includes:
• Product subs)tu)on when appropriate • Engineering controls when appropriate • Proper selec)on, maintenance, storage, use and disposal of Personal Protec)ve Equipment
TIP: What is an engineering control? Engineering Controls The first and best strategy is to control the hazard at its source. Engineering controls do this, unlike other controls that generally focus on the employee exposed to the hazard. The basic concept behind engineering controls is that, to the extent feasible, the work environment and the job itself should be designed to eliminate hazards or reduce exposure to hazards. Engineering controls can be simple in some cases. They are based on the following principles: • If feasible, design the facility, equipment, or process to remove the hazard or substitute something that is not hazardous. • If removal is not feasible, enclose the hazard to prevent exposure in normal operations. • Where complete enclosure is not feasible, establish barriers or local ventilation to reduce exposure to the hazard in normal operations.
Hazard Classifica)on
• Chemical manufacturers and importers • Must evaluate chemicals produced to “classify” the chemicals. – Employers are not required to classify chemicals. – OSHA’s HCS now provides specific criteria for classifica)on of physical and health as well as classifica)on of mixtures of chemicals.
Hazard Classifica)on
• Hazard Classifica)on • Chemical manufacturers and importers:
– Must classify chemicals they manufacture or distribute.
• Employers: – Provide informa)on to their employees about the hazardous chemicals to which they are exposed:
• hazard communica)on program • labels and other forms of warning • safety data sheets • informa)on and training.
Hazard Classifica)on
• Physical Hazards: • Hazard Classifica)on – 3 Steps
– Iden)fica)on of relevant data – Subsequent review of those data – Whether the substance or mixture will be classified as a hazardous substance or mixture
• Physical Hazards: – Explosives – Example, dynamite – Flammable gases – Example, hydrogen gas – Flammable aerosols – Example, propellants in aerosol cans (propane, isobutane) – Oxidizing gases – Example, chlorine gas – Gases under pressure – Example, nitrogen gas – Flammable liquids – Example, gasoline – Flammable solids – Example, )tanium powder (weSed) – Self-‐reac)ve substances – Example, compound of dangerous self-‐polymeriza)on (acrylonitrile) – Pyrophoric liquids – Example, triethylborane (an igniter used in jet and rocket engines) – Pyrophoric solids – Example, white phosphorous (military weapons and smoke genera)ng devices) – Self-‐hea)ng substances – Example, alkali metal alcoholates (syntheses of ingredients for the pharmaceu)cal industry) – Substances which in contact with water emit flammable gases – Example, sodium metal – Oxidizing liquids -‐ hypochlorites, (calcium hyopochlorite, found in some swimming pool chlorina)on compounds) – Oxidizing solids –Example, ammonium nitrate (common fer)lizer also used in some explosives) – Organic peroxides – Example, methyl ethyl ketone peroxide – Substances corrosive to metal – Example, sulfuric acid
Hazard Classifica)on
• GHS Health Hazard Criteria • Hazards include: • Acute toxicity – Examples, arsine, hydrogen cyanide gas and
organophosphate pes)cides • Skin corrosion – Example, hydrofluoric acid • Skin irrita)on – Example, poison ivy causing a rash • Eye effects – Example, baSery acid, sodium hydroxide, ace)c acid • Sensi)za)on – Example, solvents causing skin irrita)on aler repeated
exposure • Germ cell mutagenicity • Carcinogenicity • Reproduc)ve toxicity – Example, ethanol (drinking alcohol) • Target organ systemic toxicity: single exposure & repeated exposure –
Examples, asbestos and hydrocarbons • Aspira)on toxicity
Hazard Classifica)on
• Environmental Hazards • Hazards to the aqua)c environment • Acute aqua)c toxicity • Chronic aqua)c toxicity • Remember, OSHA does not regulate environmental issues and we will only make passing references to this during this course.
Chemical Inventory
• Elements • An effec)ve Hazard Communica)on program depends on: – Credibility of management's involvement in the program;
– Inclusion of employees in safety and health decisions; – Rigorous worksite analysis to iden)fy hazards and poten)al hazards, including those which could result from a change in worksite condi)ons or prac)ces;
– Stringent preven)on and control measures; and thorough training.
Chemical Inventory
• Hazard Communica)on Program Elements • Chemical Inventory of hazardous chemicals • WriSen Plan • Labels • Safety Data Sheets – SDSs • Informa)on and Training
Chemical Inventory
• Chemical Inventory • A chemical inventory list should be included in any wriSen Hazard Communica)on Program. – An employer should walk around the office, yard and project sites, recording the product names of all chemicals, along with the manufacturers’ names, addresses and telephone numbers.
– Something as simple as a tube of caulking compound is a product that contains chemicals for which an employer must maintain an SDS and list the product on the chemical inventory.
Chemical Inventory
• Chemical Inventory • If a chemical inventory is not already in place, a good start would
be to review purchase orders and receipts to create an ini)al inventory. Next, the workplace should be inspected to iden)fy any addi)onal chemicals present.
• Chemical inventories are olen maintained as computer files for ease and efficiency in keeping them current. – With knowledge of the chemicals in your possession, hazard
determina)ons can now be performed for chemicals in the inventory. – The chemical inventory or survey can also be used to decide which
chemicals to dispose of as well as to iden)fy poten)ally unsafe storage areas and techniques.
– Some chemicals should not be stored near each other due to incompa)bili)es and poten)al reac)ons.
Chemical Inventory
• Iden)fy Loca)on and Quan)ty • Each chemical’s loca)on and quan)ty should be noted. – When developing the chemical inventory, this is a good )me to properly dispose of half-‐empty and unneeded cans of paint, adhesive and other materials.
– The completed chemical inventory list should be kept with the wriSen program because it may need to be amended as new chemicals are purchased.
Labels
• Labels • Labels
– Key element of Hazard Communica)on. – Have been an important part of the hazard communica)on requirements.
• Labels provide rela)vely easy accessibility to basic informa)on about chemicals in the workplace.
Labels
• As of June 1, 2015 • In 2012, OSHA updated the requirements for labeling of hazardous chemicals under its Hazard Communica)on Standard (HCS).
• As of June 1, 2015, Chemical manufacturers and importers are required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precau)onary statements must also be provided.
Labels
• Labeling – Exis)ng systems have labels that look different for the same product.
– Labeling is regulated by sectors/target audiences. – GHS is intended to address this major disconnect.
Labels
• GHS Label Elements
Product Name or Iden/fier (Iden/fy Hazardous Ingredients) Pictogram(s) (Annexes 1&2)
Signal Word Physical, Health, Environmental Hazard Statements (Annexes 1&2)
Supplemental Informa/on Precau/onary Measures & Pictograms (Annex 3)
First Aid Statements (Annex 3) Name and Address of Company
Telephone Number
Labels
• Your labels may look different so long as they contain ALL of the required elements:
• Pictograms • Signal words • Hazard statements • Precau/onary statements and pictograms • Product iden/fier • Supplier iden/fica/on • Supplemental informa/on
Labels
• Pictograms-‐ Labels • GHS symbols have been incorporated into pictograms for use on the hazardous chemical label.
• Pictograms include the harmonized hazard labels plus other graphic elements.
• For transporta)on, pictograms will have the background, symbol and colors currently used by the UN Recommenda)ons on the Transport of Dangerous Goods.
Labels
• Signal Words-‐ Labels • The signal word indicates the rela)ve degree of severity of a hazard. The signal words for hazardous chemical are: – Danger: for the more severe hazards; and – Warning: for the less severe hazards.
• Signal words are standardized and assigned to the hazard categories with endpoints. Pete Rice
10/26/2012 Only one signal word is allowed on a package. TIP: An endpoint is the worst scenario
resulting from an exposure.
Labels
• Hazard Statements-‐ Labels • Hazard Statements are standardized and assigned phrases that describe the hazard(s) as determined by hazard classifica)on.
• An appropriate statement for each hazardous chemical should be included on the label for products possessing more than one hazard.
Labels
• Precau)onary Statements & Pictograms-‐ Labels • Precau)onary informa)on supplements the hazard informa)on by briefly providing measures to be taken to minimize or prevent adverse effects from physical, health or environmental hazards (See Annex 3).
• There are four types of statements: preven)on, response in cases of accidental spillage or exposure, storage and disposal.
Labels
• Product Iden)fier-‐ Labels • Should be used on a hazardous chemical label and it should match the product iden)fier used on the SDS.
• The UN Proper Shipping Name should also be used on the package.
• Should include the chemical name. For mixtures/alloys, the label should include the chemical iden))es for all ingredients that contribute to hazards.
Labels
• Supplier Iden)fica)on-‐ Label • The name, address and telephone of the manufacturer or supplier of the product should be provided on the label.
Labels
• Supplemental Informa)on-‐ Labels • This is non-‐harmonized informa)on on the container of a hazardous product that is not required or specified under the GHS.
• The labeler should have the op)on of providing supplementary informa)on related to the hazard, such as physical state or route of exposure, with the hazard statement.
Labels
• Supplemental Informa)on • An example of an item that may be considered supplemental is the personal protec)ve equipment (PPE) pictogram indica)ng what workers handling the chemical may need to wear to protect themselves.
• For example, the Hazardous Materials Iden)fica)on System (HMIS) pictogram of a person wearing goggles may be listed.
• Other supplemental informa)on may include direc)ons of use, expira)on date, or fill date, all of which may provide addi)onal informa)on specific to the process in which the chemical is used.
Labels
• Workplace Containers • Any products within the scope of Hazard Communica)on must carry the Hazard Communica)on label at the point where supplied.
• The Hazard Communica)on label must be maintained. • The Hazard Communica)on label/label elements can be used for storage tanks, secondary containers, etc.. However, other informa)on sources (e.g., NFPA, HMIS) may be authorized by the competent authority.
Safety Data Sheets (SDS)
• SDS • So, what do you do if you find a chemical in your workplace, and aler reading the label, s)ll aren’t sure how you should handle it? – Consult the safety data sheet, or SDS for the chemical.
• There should be one available for every chemical you might encounter, and if there isn’t, then request one immediately.
• This is a key component of the hazard communica)on standard.
• Hazard Communica)on specifies the format for the SDS, which we’ll review in the following screens.
.
Safety Data Sheets (SDS)
• SDS • Under the Hazard Communica)on Standard, the labeling
requirements: – Result in valuable key informa)on that must appear on a chemical or its package or container.
– Label does not provide all important and detailed informa)on. • The safety data sheet (SDS):
– Detailed informa)on above and beyond the label so that the user can be informed about the many characteris)cs of the chemical,
– What must be done to safely use or apply the chemical. – SDS must be available for every chemical brought into the workplace or onto a jobsite.
Safety Data Sheets (SDS)
• MSDS vs. SDS • Under OSHA’s Hazard Communica)on 2012 revised standard, the MSDS will be replaced with a Safety Data Sheet (SDS). – Before the Hazard Communica)on Standard 2012, there were several acceptable MSDS formats.
– OSHA’s adop)on of Globally Harmonized Standards (GHS) requires the use of a single format with 16 sec)ons that appear in a specific order.
– Although this change seems to have become a cause for concern, in all prac)cal reality, there is very liSle difference between the two documents.
Safety Data Sheets (SDS)
• SDS • The new SDS should contain 16 headings. • The revised SDS headings, sequence and content are similar to the ISO, EU and ANSI MSDS/SDS requirements, except that sec)ons 2 and 3 are reversed.
TIP: ISO is International Standards Organization, EU is European Union and ANSI is the American National Standards Institute.
Safety Data Sheets (SDS)
• SDS Format • The format of the 16-‐sec)on SDS should include the following sec)ons:
– Sec)on 1. Iden)fica)on Sec)on 2. Hazard(s) iden)fica)on Sec)on 3. Composi)on/informa)on on ingredients Sec)on 4. First-‐Aid measures Sec)on 5. Fire-‐figh)ng measures Sec)on 6. Accidental release measures Sec)on 7. Handling and storage Sec)on 8. Exposure controls/personal protec)on Sec)on 9. Physical and chemical proper)es Sec)on 10. Stability and reac)vity Sec)on 11. Toxicological informa)on Sec)on 12. Ecological informa)on Sec)on 13. Disposal considera)ons Sec)on 14. Transport informa)on Sec)on 15. Regulatory informa)on Sec)on 16. Other informa)on, including date of prepara)on or last revision
Safety Data Sheets (SDS)
• Sec)on 1: Iden)fica)on of the substance or mixture and of the supplier. – Product iden)fier. – Other means of iden)fica)on. – Recommended use of the chemical and restric)ons on use.
– Supplier's details (including name, address, phone number, etc.).
– Emergency phone number.
Safety Data Sheets (SDS)
• Sec)on 2: Hazards iden)fica)on. – HCS classifica)on of the substance/mixture and any na)onal or regional informa)on.
– HCS label elements, including precau)onary statements. (Hazard symbols may be provided as a graphical reproduc)on of the symbols in black and white or the name of the symbol, e.g., flame, skull and crossbones.)
– Other hazards which do not result in classifica)on (e.g., dust explosion hazard) or are not covered by the HCS.
Safety Data Sheets (SDS)
• Sec)on 3: Composi)on/informa)on on ingredients. – Substance Chemical iden)ty.
• Common name, synonyms, etc. • CAS number, EC number, etc. • Impuri)es and stabilizing addi)ves which are themselves classified and which contribute to the classifica)on of the substance.
– Mixture means a combina)on or a solu)on composed of two or more substances in which they do not react. TIP: The European Community number, or EC number, is a unique seven-
digit identifier that is assigned to chemical substances for regulatory purposes within the European Union by the regulatory authorities.
Safety Data Sheets (SDS)
• Sec)on 4: First aid measures . – Descrip)on of necessary measures, subdivided according to the different routes of exposure, i.e., inhala)on, skin and eye contact, and inges)on.
– Most important symptoms/effects, acute and delayed.
– Indica)on of immediate medical aSen)on and special treatment needed, if necessary.
Safety Data Sheets (SDS)
• Sec)on 5: Firefigh)ng measures. – Suitable (and unsuitable) ex)nguishing media. – Specific hazards arising from the chemical (e.g., nature of any hazardous combus)on products).
– Special protec)ve equipment and precau)ons for firefighters.
Safety Data Sheets (SDS)
• Sec)on 6: Accidental release measures. – Personal precau)ons, protec)ve equipment and emergency procedures.
– Environmental precau)ons. – Methods and materials for containment and cleaning up.
Safety Data Sheets (SDS)
• Sec)on 7: Handling and storage. – Precau)ons for safe handling. – Condi)ons for safe storage, including any incompa)bili)es.
Safety Data Sheets (SDS)
• Sec)on 8: Exposure controls/personal protec)on. – Control parameters, e.g., occupa)onal exposure limit values or biological limit values.
– Appropriate engineering controls. – Individual protec)on measures, such as personal protec)ve equipment.
Safety Data Sheets (SDS)
• Sec)on 9: Physical and chemical proper)es. • Appearance (physical state, color, etc.). • Odor. • Odor threshold. • pH. • mel)ng point/freezing point. • ini)al boiling point and boiling range. • flash point. • evapora)on rate. • flammability (solid, gas). • upper/lower flammability or explosive limits. • vapor pressure. • vapor density. • rela)ve density. • solubility(ies). • par))on coefficient: n-‐octanol/water. • autoigni)on temperature. • decomposi)on temperature.
Safety Data Sheets (SDS)
• Sec)on 10: Stability and reac)vity. – Chemical stability. – Possibility of hazardous reac)ons. – Condi)ons to avoid (e.g., sta)c discharge, shock or vibra)on).
– Incompa)ble materials. – Hazardous decomposi)on products.
Safety Data Sheets (SDS)
• Sec)on 11: Toxicological informa)on. – Concise but complete and comprehensible descrip)on of the various toxicological (health) effects and the available data used to iden)fy those effects, including: informa)on on the likely routes of exposure (inhala)on, inges)on, skin and eye contact);
– Symptoms related to the physical, chemical and toxicological characteris)cs;
– Delayed and immediate effects and also chronic effects from short-‐ and long-‐term exposure;
– Numerical measures of toxicity (such as acute toxicity es)mates).
Safety Data Sheets (SDS)
• Sec)on 12: Ecological informa)on. – Ecotoxicity (aqua)c and terrestrial, where available).
– Persistence and degradability. – Bioaccumula)ve poten)al. – Mobility in soil. – Other adverse effects.
Tip: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12, 13, 14 and 15
Safety Data Sheets (SDS)
• Sec)on 13: Disposal considera)ons. – Descrip)on of waste residues and informa)on on their safe handling and methods of disposal, including the disposal of any contaminated packaging.
Safety Data Sheets (SDS)
• Sec)on 14: Transport informa)on. – UN Number. – UN Proper shipping name. – Transport Hazard class(es). – Packing group, if applicable. – Marine pollutant (Yes/No). – Special precau)ons which a user needs to be aware of or needs to comply with in connec)on with transport or conveyance either within or outside their premises.
Safety Data Sheets (SDS)
• Sec)on 15: Regulatory informa)on. – Safety, health and environmental regula)ons specific for the product in ques)on.
Safety Data Sheets (SDS)
• Sec)on 16: Other informa)on including informa)on on prepara)on and revision of the SDS.
Safety Data Sheets (SDS)
• Differences Between MSDS & SDS • SDSs are in use globally. It is useful to have an understanding of the similari)es and differences. (See Appendix A to the OSHA Document).
Safety Data Sheets (SDS)
• Timeline for Implementa)on Date Requirement Who
12/1/2013 Train employees on the new labels and SDSs Employers
6/1/2015 Comply with final rule except chemical distributors may ship containers without GHS labels
Chemical manufacturers, importers, distributors and employers
12/1/2015 Shipment of labels without GHS labels prohibited
Chemical manufacturers, importers, distributors and employers
6/1/2016 Update HazComm program; addi)onal training as necessary for newly iden)fied physical or health hazards
Employers
Training and Informa)on
• What is considered proper training under HCS? • Employees must be trained at the )me they are assigned to work with a hazardous chemical.
• Why? Because it is important for the employee to have informa)on prior to exposure to prevent the occurrence of adverse health effects. This purpose cannot be met if training is delayed un)l a later date.
Training and Informa)on
• More than just providing SDSs • The training provisions of the HCS are not • …
– Sa)sfied solely by giving employee the data sheets to read.
• An employer's training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the informa)on generated in the hazard communica)on program.
Training and Informa)on
• To Sa)sfy Requirement • Training and Informa)on can be accomplished ,,, – In many ways (audiovisuals, classroom instruc)on, interac)ve video), and should include an opportunity for employees to ask ques)ons to ensure that they understand the informa)on presented to them.
TIP: Furthermore, the training must be comprehensible. If the employees receive job instructions in a language other than English, then the training and information to be conveyed under the HCS will also need to be conducted in a foreign language.
Training and Informa)on
• Chemical Category Training • Training need not be conducted on each specific chemical found in the workplace, – but may be conducted by categories of hazard (e.g., carcinogens, sensi)zers, acutely toxic agents) that are or may be encountered by an employee during the course of his du)es.
Training and Informa)on
• Informa)on and Training Topics – Methods and observa)ons that may be used to detect the presence or release of a hazardous chemical at the workplace;
– Basics of physical and health hazards of common hazardous chemical classes found at the worksite;
– Measures employees can take to protect themselves from hazards, such as appropriate work prac)ces, emergency procedures, and personal protec)ve equipment to be used;
– Details of the employers effec)ve Hazard Communica)on Program.
Training and Informa)on
• Methods and Observa)ons • Methods and observa)ons that may be used to detect the presence or release of a hazardous chemical; – May include monitoring conducted by the employer, con)nuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.
– Industrial hygiene type monitoring at which poten)al exposures are evaluated by collec)ng air samples followed by laboratory analysis.
– The use of direct reading instruments to get immediate readouts of dust, gases or vapors or other airborne contaminants.
Training and Informa)on
• Basics of physical and health hazards of common hazardous chemical classes
• This would include the trainer, supervisor or manager being familiar with the SDS to such a level that informa)on is communicated to the employee so that he/she is familiar with physical and health hazards of the substances he/she may poten)ally exposed to.
• Health hazard group: – Acute toxin, Skin corrosive, skin irritant, have the poten)al to cause
serious eye damage/eye irrita)on or be a respiratory or skin sensi)zer. • Physical hazard group:
– Explosives, Flammable gas, Gas under pressure, flammable liquid. • This informa)on is found on the SDS.
Training and Informa)on
• Protec)ve Measures • For example:
– When dry sanding using HEPA vacuum sanders, using wet techniques to keep the dust down, performing sanding tasks in downdral or cross-‐dral prep sta)on.
– For spraying tasks (e.g. paint) performing as many spraying tasks as possible, and all clear-‐coat spraying tasks, in ven)lated spray booths.
– Placing waste paint or solvent drums atop spill containment pallets.
– Consul)ng the SDS, supervisor and if necessary the manufacturer of the hazardous chemical for the specific PPE to be used during a certain ac)vity as some ac)vi)es require a higher level of protec)on than others.
Training and Informa)on
• Details of an effec)ve Hazard Communica)on Program
• Training and informa)on includes … – training employees on the details of the hazard communica)on program developed by the employer, including an explana)on of labels and safety data sheets, and how employees can obtain and use the appropriate hazard informa)on.
– Who, what, when, why, where and how.
Trade Secrets
• Withholding Trade Secret Informa)on • Under the HCS, the chemical manufacturer, importer, or employer on rare occasions … – May withhold the specific chemical iden)ty, including the chemical name, other specific iden)fica)on of a hazardous chemical, or the exact percentage (concentra)on) of the substance in a mixture, from the safety data sheet. This is generally referred to as trade secret protec)on.
TIP: The rules surrounding a claim of trade secret can be relatively complex. For those students looking for more information surrounding this subject, they should read and review the paragraph in the HCS which can be found at 1910.1200(i).
Trade Secrets
• Trade Secrets • A "trade secret" is something that gives an employer an opportunity to obtain an advantage over compe)tors. – For example, a trade secret may be a confiden)al chemical formulas, process data, or a "specific chemical iden)ty."
– Referred to in the Hazard Communica)on Standard. – The term includes the chemical name, the Chemical Abstracts Services (CAS) Registry Number, or any other specific informa)on that reveals the precise designa)on.
Trade Secrets
• Trade Secrets • OSHA’s Hazard Communica)on Standard …
– Strikes a balance between the need to protect exposed employees and the employer's need to maintain the confiden)ality of a bona fide trade secret.
– This is achieved by providing for limited disclosure to health professionals who are furnishing medical or other occupa)onal health services to exposed employees, employees and their designated representa)ves, under specified condi)ons of need and confiden)ality.
Tip In a medical emergency, specific chemical identity must be disclosed to treating physician or nurse.
Conclusion/Summary
• Hazard Communica)on Checklist • Have you been provided safety and health training and informa)on for the
chemicals in your work area? • Do you know how to read and understand the safety and health
informa)on on container labels? • Have you been informed on the loca)on of SDSs or MSDSs for substances
you may be exposed to? • Have you reviewed and do you understand the informa)on provided in an
SDS / MSDS? • Do you know the physical and health hazards and how to protect yourself
from exposure to hazardous chemicals in your work area? • Do you know where to go, who to talk to for addi)onal informa)on
surrounding hazardous chemicals in your work areas? – If you answered “no” to any of these ques)ons, it is important for you to talk
with your supervisor or safety coordinator to get addi)onal informa)on concerning your organiza)ons Hazard Communica)on Program.
Conclusion/Summary
• This Training • It is important to recognize that this training is introductory in nature of the basic elements of OSHA’s Hazard Communica)on Standard (olen referred to as Hazard Communica)on or Employee Right to Know)
• This course is principally intended to provide employers and employees with expected poten)al exposure to hazardous chemicals and substances with Hazard Communica)on training.
Conclusion/Summary
• Other OSHA Standards may apply • Be advised that there are mul)ple standards that may be applicable
when hazardous chemicals are an issue on the worksite. • These include standards for PPE, Respiratory Protec)on, Hazardous
Waste Opera)ons and Emergency Response and more. • This course does not address the mul)tude of hazards that may be
applicable. • For those that manage the development, implementa)on and
administra)on of the Hazard Communica)on Program or supervise employees exposed to hazardous chemicals, the student may consider taking ClickSafety’s Hazard Communica)on for Supervisors and Managers course.
Conclusion/Summary
• Helpful Sources of Informa)on and Assistance • OSHA’s HCS can appear complicated and confusing. – OSHA has developed and introduced many safety and health tools and resources that want to learn more.
– Check out OSHA’s webpage en)tled “Hazard Communica)on, The standard that gave workers the right to know, now gives them the right to understand.”
– Aler all it is “Our Right To Know”. LINK
https://www.osha.gov/dsg/hazcom/
Conclusion/Summary
• Module Summary • To summarize this module. We provided a summary of the Hazard Communica)on (Employee Right
to Know) requirements. • We reviewed and you should now be able to: • Describe the benefits provided to employees by the Hazard Communica)on Standard (HCS). • List at least four fundamental elements of OSHA’s Hazard Communica)on Standard. • List the 3 primary areas of change to OSHA’s Hazard Communica)on Standard. • Describe at least four required elements of a hazardous chemical label. • Iden)fy the hazards represented by the nine GHS pictograms. • Describe the primary benefits of using an MSDS or an SDS for a hazardous chemical. • Name the required elements of an employer’s wriSen hazard communica)on program. • Iden)fy at least three of the employer’s fundamental responsibili)es under the hazard
communica)on standard. • Recognize when training beyond the scope of this advanced course is necessary.