29 CFR 1910.1200 What OSHA Wants You To Know Hazard Communication 29 CFR 1910.1200 What OSHA Wants You To Know

Right To Know / MSDS What are MSDS? Where are your MSDS?

Hazard Communication Standard Agenda: Chemical Hazards Written Hazard Communication Program Employee protective measures Container Labeling Requirements Material Safety Data Sheets MSDS inventory General Spill Clean-Up Personal Protective Equipment Contractor Requirements Objectives: Introduce the OSHA Hazard Communication Standard. Discuss methods and observations used to detect chemicals. Discuss the local Hazard Communication Written Policy and where it is located. Discuss the physical and health hazards of chemicals. Go over the employee protective measures. Discuss the manufacturers label and the secondary labeling. Expain how to use Material Safety Data Sheets (MSDS’s) Introduce some basic rules of safety.

Close Encounters with Chemicals Many chemicals can cause injury or illness if not handled properly. We encounter chemicals almost every day Filling your vehicle with gasoline Cleaning the bathroom Applying pesticides or insecticides Using solvents or acids at work

Chemical Inventory Listing Maintain a current list of ALL chemicals or products on site, including specific uses. Make the list available to all employees. Make the list available during each work shift.

Hazards of Chemicals Physical Hazards: Flammable – below 100° F Combustible – 100 – 200 F Explosive – a chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature. Reactive - reactionary materials can cause damage to the human body by release of gases that will burn, explode, or produce high pressure that can inflict injury to a person nearby Health Hazards: Sensitizer - produces hyperallergic condition Irritant - reversible inflammatory reaction Corrosive - irreversible tissue injury Toxic – poisonous

Hazards of Chemicals Health hazard means that acute or chronic health effects may occur in exposed employees - including chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. Acute toxicity describes the adverse effects resulting from a single exposure to a substance. Chronic Toxicity, which describes the adverse health effects from repeated (lower level) exposures to a substance over a longer period (months to years). Acute Health Effects - usually of rapid onset, brief, not prolonged; sometimes loosely used to mean severe. Referring to exposure, brief, intense, short-term; sometimes specifically referring to brief exposure of high intensity. A chronic health effect is an adverse health effect resulting from long-term exposure to a substance. The effects could be a skin rash, bronchitis, cancer or any other medical condition. An example would be liver cancer from inhaling low levels of benzene at your workplace over several years. The term is also applied to a persistent (months, years or permanent) adverse health effect resulting from a short-term (acute) exposure. Carcinogens – a substance that is known to, believed to, or suspected of causing cancer Toxic – (poisonous) Toxic is defined by OSHA 29 CFR 1910.1200 App A as a chemical which falls in any of these three categories: 1. A chemical that has a median lethal dose (LD50) of more than 50 milligrams per kilogram but not more than 500 milligrams per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each. 2. A chemical that has a median lethal dose (LD50) of more than 200 milligrams per kilogram but not more than 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each. 3. A chemical that has a median lethal concentration (LC50) in air of more than 200 parts per million but not more than 2,000 parts per million by volume of gas or vapor, or more than two milligrams per liter but not more than 20 milligrams per liter of mist, fume, or dust, when administered by continuous inhalation for one hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each. Highly Toxic - a chemical that falls in any of these three categories: 1. A chemical that has a median lethal dose (LD50) of 50 milligrams or less per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each. 2. A chemical that has a median lethal dose (LD50) of 200 milligrams or less per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each. 3. A chemical that has a median lethal concentration (LC50) in air of 200 parts per million by volume or less of gas or vapor, or 2 milligrams per liter or less of mist, fume, or dust, when administered by continuous inhalation for one hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each. Hepatotoxins - A substance capable of causing damage to the liver. Nephrotoxins - A cytotoxin (any substance that kills living cells) that is specific for cells of the kidney. Hematopoietic System = the body’s “blood making” system - bone marrow, spleen, thymus, and lymph nodes

Written Hazard Communication Program Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified for labels and other forms of warning, material safety data sheets, and employee information and training will be met, and which also includes the following: A list of the hazardous chemicals known to be present The methods the employer will use to inform employees of the hazards of chemicals in their work areas.

Written Hazard Communication Program Also includes methods the employer will use to inform other employers (contractors) of chemical hazards, precautionary measures, and the labeling system used The employer shall make the written hazard communication program available, upon request, to employees, or their designated representatives

Employee Protective Measures Container Labeling Who is responsible for labeling secondary containers? A number of labeling systems have been developed in an effort to communicate chemical hazards to employees more effectively The most common systems are: The National Fire Protection Association (NFPA) The Hazardouos Material Information System (HMIS) Some chemical manufacturers have Ready to Use labels.

Label Requirements (continued) Label all chemical containers that are not going to be used immediately. DO NOT USE containers that resemble beverage containers. Have a adequate labeling supply Here are some additional labeling requirements: All containers of hazardous materials must be labeled unless the transfer contain is going to be used by the person doing the trans and they will not leave the container until it is used up; for example, a mop bucket. Containers that resemble a drinking glass, beverage bottle, cup or other type of container used for holding food or drink must not be used for chemical storage. The employer must provide adequate supplies of labeling.

Manufacturer’s Labeling Primary Containers Identity of the hazardous chemical(s) Appropriate hazard warnings Poison Danger Warning Caution First Aid Statement Name and address of manufacturer or responsible party The manufacturer shall provide a label on the original container that has the same name as they have on the MSDS. The degree of hazard signal words shall be on the label: Poison being the most hazardous, then Danger, Warning and Caution being the least hazardous. The label should also have First Aid Statement to show you what to do in case it is an eye, skin, or etc. hazard; for example, Eye Irritant may say flush eyes for 15 minutes then get medical attention immediately. It is required to have the manufacturer or distributors name on the label so if the employee or health professional needs more information they know who to contact.

Secondary Labeling Requirements Same information as Primary Labels Identity of the hazardous chemical(s) Appropriate hazard warnings Poison Danger Warning Caution First Aid Statement Name and address of manufacturer or responsible party

Secondary Labeling Requirements Secondary labels may be hand written if: They are legible and the ink doesn’t smear or run They contain the required information Identity of the hazardous chemical(s) Appropriate hazard warnings Poison Danger Warning Caution First Aid Statement Name and address of manufacturer or responsible party

Secondary Labeling Requirements “… not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.” 1910.1200(f)(7) Handing container to another person – label required Breaks & Lunch – out of your direct control – label required Mop Buckets – unattended – label required The employee who does the transferring from a large container to a small container does not have to label the secondary container if they do not abandon it; for example, if they leave the job site or go home the container has to be labeled. All secondary containers such as spray bottles; gallon or quart jugs have to have the secondary labeling on them. The mop buckets do not have to be labeled if they are used in the shift that the person did the transfer. If the chemical is in a spray bottle, quart or gallon container unlabeled and you did not put the chemical in it; do not use the unknown chemical!

Hazard Rating System Two numbering systems NFPA (National Fire Protection Association) HMIS (Hazardous Material Identification System) National Paint and Coatings Association

Product Safety Hazard labeling Caution/warning/danger/poison National Fire Protection Association system Red = fire hazard Blue = health hazard Yellow= reactivity White= specific hazard 0 through 4 HMIS (Hazardous Material Identification System) White= specific hazard & PPE Requirements

Five Hazards Levels HMIS: NFPA: 4 Severe 3 Serious 2 Moderate 1 Slight 0 Minimal NFPA: 4 Extreme 3 High 2 Moderate 1 Slight 0 Insignificant

NFPA Diamond

HMIS

MSDS Each material safety data sheet shall be in English (although the employer may maintain copies in other languages as well), and shall contain at least the following information: All U.S. MSDS’s are to be in English from the manufacturer or distributor. The manufacture does not have to provide the MSDS in any other language. The employer may maintain copies of MSDS’s in another language. However, the employer must train the employee in the employee’s language the safety information.

Material Safety Data Sheets SECTION CONTENTS I Product Identity II Ingredients Identity Information III Physical/Chemical Characteristics IV Fire/Explosion Data V Physical Hazard Data VI Health Hazards Data VII Precautions for Safe Handling and Use VIII Control Measures – PPE IX Additional Information

Section I – Product Identity Product Name Manufacturer’s Information Name Address Phone Number – business hours 24-hour Emergency Phone Number National Chemical Emergency hotline

Section II - Ingredients/ Identity Information Name(s) of Hazardous Chemicals Top 5 by weight CAS# (Chemical Abstract Service Registry Number) OSHA PEL – Permissible Exposure Limit ACGIH – Time Weighted Averages for concentrate. STEL – Is the exposure concentration that is not to be exceed for a Short Term Exposure (15 Minutes) This section is general section II and it first lists the OSHA hazardous chemicals for the 29 CFR (Code of Federal Regulations) paragraph 1910.1200. After these ingredients may be listed items that are not hazardous per OSHA; some east coast states require the top five ingredients be listed even though they are not hazardous. We can tell these items because there is no TLV or PEL or percentages after the chemical name in the ingredient section. OSHA Exposure Limits are time weighted average exposures that are not to be exceed. The Americal Conference of Governmental Industrial Hygienist have usually more current restrictions on chemicals that OSHA PEL’s and they are based on a 8 hour work exposure. One might think of the PEL and TWA like speed limits on highways; it is a guide to safe working levels. Normally we do not work 8 hours a day or 40 hours a week with chemicals, in that case, we look at STEL’s or Short Term Exposure Limits to provide information for short term 15 minute exposures.

Section III - Physical / Chemical Characteristics Why? Physical and chemical changes can affect the type and degree of hazard Boiling Point – Temperature a liquid becomes a gas. Vapor Pressure –Pressure exerted on the container between the liquid level and the cap. Vapor Density – Is the vapor heavier or lighter than air Solubility In Water – How well does the product mix with water We are concerned about physical hazards because a product may be flammable or explosive if improperly handled or by knowing these properties the product is going to go from a liquid to a vapor. The boiling point is the temperature that a liquid is going to become a vapor or gas in the air. Vapor pressure is the pressure that a liquid in a container can put on the cap. Did you ever open a can of gasoline in the summer and the vapor forced out of the cap. Vapor Density is helpful to know if a product vapors are heavier than air or lighter than air. If it is lighter than air and flammable then it may become a safety hazard when large amount of product is spilled in a closed building and the area is heated with a gas furnace with a polite light. Solubility in water becomes a concern because if the product is not soluble in water and it is spilled it may only float on the top of the water. For example if it is a flammable solvent; it is burning and you try to put it out with water it may only spread the flame.

Section III - Physical / Chemical Characteristics Specific Gravity – Is the product heavier or lighter than water Percent Volatile By Volume – How much of the product will evaporate? Evaporation Rate – How fast does it evaporate? Appearance and Odor – Changes can indicate product is not what you thought was in the container. Specific Gravity is important in case of a spill we need to know if it is heavier or lighter than water. Is it soluble or partly soluble or not soluble in water? % Volatile can mean how much of the product will evaporate if cap is not put on container. In case of floor finish subtract volatile from 100 and this gives solid content. Evaporation rate means does it leave the surface faster than water like a mineral spirit. Color and odor changes can mean someone poured unused material back into the container and it spoiled or maybe diluted the product.

Section IV - Fire and Explosion Hazard Data Flash Point – The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite. Flammable Limits = LEL (Lower Explosive Limit) and UEL (Upper Explosive Limit) Firefighting Information – What Material to use (water, foam, etc.) to put out a fire involving this chemical; special precautions, etc. Flash point is the lowest temperature at which a liquid gives off enough vapor to ignite. Lower explosive limit is the smallest concentration of a gas in the air that when a ignition source is present it will ignite. Upper explosive limit is the vapor concentration of the product is high that there is not enough oxygen for the vapor to ignite; there is often no data on the MSDS of complex mixtures. Firefighting information may include what type of fire extinguisher to use to put out the fire and possible personal protective equipment that the fire fighters might need such as self contained respirators and other special precautions.

Section V - Physical Hazards Stability – How well the chemical resists change. Incompatibility (Materials to Avoid) – Mixing two chemical may form a toxic or explosive mixture. Hazardous Decomposition Products or Byproducts – When a product breaks down by heat, chemical reaction, decay etc. to form an new hazardous chemical Stability is how well does the product resist change, such as, exposure to temperature cause a non hazardous material to break down into something explosive or make a new health hazard. Most of the maintenance chemicals that we work with are stable. Incompatibility is when two chemicals mix and create a new hazard; for example a sink is cleaned with a acid cleaner and then someone dumps bleach down the drain a toxic chlorine gas may be formed. Never mix acid cleaners such as toilet bowl cleaners with alkaline floor polish removers. Also never pour acid into water; it can create and explosion. PUT THE WATER INTO THE ACID. Make a W the draw a line into the middle to form an A is an easy way to remember this. Hazardous Decomposition Products or Byproducts may form when a product is heated, spoils and breaks down into new hazardous chemicals or simpler compounds.

Section VI - Health Hazard Data Definition – A chemical substance that is either an Acute (immediate) health hazard = Usually minutes, hours or several days. or Chronic (delayed) health hazard = Regular exposure over months, years, or a lifetime

Section VI - Health Hazard Data Routes of Entry Ingestion: Entry may occur by eating, drinking or smoking without washing hands first Absorption: Entry my occur through contact with skin, eyes, nose, mouth, etc. Inhalation: Entry may occur through the inhalation of chemical vapors – not the fragrance in a product

Section VI - Health Hazard Data Carcinogen or Potential Carcinogen must be listed if greater than 0.1% by weight. Signs and Symptoms of Exposure – How to recognize exposure (taste, irritations, headache, nausea, etc.) Medical Conditions Generally Aggravated By Exposure – Conditions that could be made worse by exposure Emergency and First-Aid Procedures – What to do in case of exposure. If prolonged over exposure to a carcinogenic substances the individual may develop cancer or have tumors that show accelerated growth. Some examples of carcinogens are Arsenic, Lead chromate, and etc. Medical Conditions Generally Aggravated by Exposure, for example, a person may be allergic to a chemical so when they are exposed to some perfumes or solvents they have Bronchitis, Asthma, Heart Condition, Dermatitis, etc. Emergency and First Aid Procedures are necessary in cases of chemical contact with eyes, nose, mouth, skin, or in the event an individual becomes overexposed by inhalation or ingestion.

Section VII – Precautions for Safe Handling and Use Steps to be taken in case material is released or spilled Precautions to be taken in handling and storage

Section VIII – Control Measures How to keep yourself safe Respiratory Protection (Specify Type) Ventilation Local Exhaust Protective Gloves Eye Protection Other Protective Clothing or Equipment Work / Hygienic Practices

Section IX – Additional Information Transportation Information for example Signage requirements, etc.

MSDS Inventory The first page in the MSDS book should be a list of the MSDS that should be in the book Consistently in the top 5 violations issued by OSHA

General Precautions For Spill Clean-Up Wear appropriate protective equipment Read MSDS Follow Ventilation Requirements Clean up small spills to prevent them from being mistaken for water For large spills, contact supervisor Store acidic products away from alkaline products to prevent reactions in case of leaks or spills When diluting, always add acids to water, never water to acids

Personal Protective Equipment The objective for wearing personal protective equipment is to prevent dangerous chemical contact with your person or street clothes Dust masks and respirators Glasses, goggles, and face shields Gloves Foot protection (Rubber boots) Aprons or full-body suits 99% of the chemicals involved in housekeeping, especially once diluted, pose minimal risks as long as precautions are followed Read MSDS

Contractor Safety Requirements Outside Contractors must: Inform representatives about chemicals Provide MSDS’s upon request Facility or employer representatives must: Inform the contractor about chemicals The Hazard Communication standard requires that outside contractors inform facility representatives of the chemicals that they will be using during their work. In addition, the contractors should be prepared to provide MSDS’s upon request to the employer. The facility or employer representative must also inform the contractor of chemicals used in the area where the contractor personnel will work. The employer must also be prepared to provide MSDS’s upon request of the contractor. The objective is to make sure that all employees are informed of workplace chemical hazards.

Employee Information and Training Employers shall provide employees with effective 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 Flammability, carcinogenicity, etc. Specific chemicals Chemical-specific information must always be available through labels and material safety data sheets.

Employee Training Employee training shall include at least: 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 and health hazards of the chemicals in the work area

Employee Training Employee training shall include at least: The measures employees can take to protect themselves from these hazards including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals appropriate work practices emergency procedures personal protective equipment to be used

Employee Training Employee training shall include at least: The details of the hazard communication program developed by the employer, including an explanation of the labeling system the material safety data sheet how employees can obtain and use the appropriate hazard information

Hazard Communication Summary Identify chemical hazards Read labels and MSDS Follow warnings and instructions, or ask your supervisor if in doubt Use the appropriate PPE Practice sensible, safe work habits Learn emergency procedures

Are there any Questions? Hazard Communication Are there any Questions?

Quiz The Hazard Communication Standard Addresses: Communicating information concerning and appropriate to employees. Maintaining a Hazard Communication Program for the workplace (T/F) The Employer must provide MSDS in a language understood by the employee.

Quiz Employee training shall include at least: (T/F) Appropriate work practices (T/F) Emergency phone numbers (T/F) Personal protective equipment to be used MSDS – It is the ’s responsibility to provide them; it is the __________’s responsibility to maintain them; and it is the ’s responsibility to read them.

Quiz Routes of entry include , , and . (T/F) Changes in a product’s color is not really important. (T/F) Training should occur when a contractor is going to be doing work on-site with a paint remover. Secondary labels must contain the manufacturer’s name and address, the name, and the warning.

Quiz (T/F) Secondary labels are always required. (T/F) MSDS must be kept at every worksite. (T/F) Mop buckets need secondary labels under certain circumstances. Employee training shall occur at the time of their or whenever a is introduced

Answers The Hazard Communication Standard Addresses: Communicating information concerning hazards and appropriate protective measures to employees. Maintaining a written Hazard Communication Program for the workplace (F) The Employer must provide MSDS in a language understood by the employee.

Answers Employee training shall include at least: (T) Appropriate work practices (F) Emergency phone numbers (T) Personal protective equipment to be used MSDS – It is the manufacturer’s responsibility to provide them; it is the employer’s responsibility to maintain them; and it is the employee’s responsibility to read them.

Answers Routes of entry include inhalation , skin or eye contact , and ingestion . (F) Changes in a product’s color is not really important. (T) Training should occur when a contractor is going to be doing work on-site with a paint remover. Secondary labels must contain the manufacturer’s name and address, the chemical or product name, and the hazard warning.

Answers (F) Secondary labels are always required. (T) MSDS must be kept at every worksite. (T) Mop buckets need secondary labels under certain circumstances. Employee training shall occur at the time of their initial assignment or whenever a new hazard is introduced

Hazard Communications Thank You For Your Participation