OSHA Long Term Care Worker Protection Program

 Recognize the purpose of the hazard communication standard.  Describe the components of a hazard communication program.  Discuss the application of this standard in your workplace settings.

 About 32 million workers work with and are potentially exposed to one or more chemical hazards.  There are approximately 650,000 existing chemical products, and hundreds of new ones being introduced annually.  Chemical exposure may cause or contribute to many serious health effects such as heart ailments, central nervous system damage, kidney and lung damage, sterility, cancer, burns, and rashes.  Some chemicals may also be safety hazards and have the potential to cause fires and explosions.

1. To make sure that the hazards of chemicals are evaluated. 2. To assure that the information concerning the hazards is communicated to employers and employees.

 A hazardous chemical, as defined by the Hazard Communication Standard (HCS), is any chemical which can cause a physical or a health hazard.  This determination is made by the chemical manufacturer, as described in 29 CFR (d).

 OSHA’s Hazard Communication (HazCom) standard applies to general industry, shipyard, marine terminals, longshoring, and construction employment and covers chemical manufacturers, importers, employers, and employees exposed to chemical hazards. Horizontal

 The Hazard Communication Standard (HCS) is based on a simple concept--that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working.

 Employees need to know what protective measures are available to prevent adverse effects from occurring.  The HCS is designed to provide employees with the information they need. MSDS

 Employers are required to provide information to employees about the hazardous chemicals to which they are exposed using: ◦ A hazard communication program. ◦ Labels and other forms of warnings. ◦ Material safety data sheets (MSDS). ◦ Information and education.

Standard Exemptions Any hazardous waste subject to regulations issued under that Act by the Environmental Protection Agency; Tobacco or tobacco products; Wood or wood products, that the only hazard they pose to employees is the potential for flammability or combustibility (wood treated with covered chemicals are not exempt); Drugs, cosmetics, consumer products, nuisance particulates that pose no hazard, radiation, and biological agents.

 Employers must develop a written program that covers at least: ◦ Labels and other forms of warnings ◦ Material Safety Data Sheets ◦ Employee Information and Training

 All workplaces where employees are exposed to hazardous chemicals must have a written plan.  The plan does not have to be lengthy or complicated.

 The written program must cover at least: ◦ A list of the hazardous chemicals known to be present at the facility along with MSDS’s for each chemical. ◦ The methods the employer will use to inform employees of the hazards non-routine tasks. ◦ The hazards of chemicals in unlabeled pipes.

 The employer must make the written program available, upon request, to: ◦ Employees and their designated representatives  If work is carried out at more than one location, the program may be kept at the main location.

 The employer must ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following: ◦ Identity of the hazardous chemical ◦ Appropriate hazard warnings  This above labeling information is required of the manufacturer so the employer must ensure that the original labels from the manufacturer are on all containers and remain legible.

This Unlabeled container does not meet the labeling exemption requirement

 Must be in English and include information regarding the specific chemical identity and common names.  Must provide information about the: ◦ Physical and chemical characteristics ◦ Health effects ◦ Exposure limits ◦ Carcinogenicity (cancer-causing) ◦ Identification (name, address, and telephone number) of the organization responsible for preparing the sheet ◦ General control measures, including PPE ◦ Exposure occurs: emergency and first aid procedures

 Physical hazards, such as fire and explosion  Health hazards, such as signs of exposure  Routes of exposure  Precautions for safe handling and use  Emergency and first-aid procedures  Control measures Prepared by the chemical manufacturer or importer and describe:

 Let’s look at one example.  Please find the chemical and trade name.  Primary route of entry?  What are the health effects?  Exposure limits?  General control measures?  If I am exposed, what are the emergency and first aid procedures?

 MSDS’s must be readily accessible to all employees in their work area.  (g) (8)

 Manufacturers, importers, distributors and employers who become newly aware of significant information regarding chemical hazards shall: ◦ Revise the labels for the chemical within three months. ◦ Revise the MSDS for the chemical within three months.

 One difference between this rule and many others adopted by OSHA is that this one is performance- oriented.  That means that you have the flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific, rigid requirements.  Refer to Appendix E

 Compile a complete list of the potentially hazardous chemicals in the workplace.  Determine if you have received material safety data sheets for all of them.  If any are missing, contact the supplier and request one.  Do not allow employees to use any chemicals for which you have not received an MSDS.

 If employees of other employers could be exposed to hazardous chemicals the program must include: ◦ Methods to provide contractor employees with on-site access to MSDS for each chemical those workers may be exposed to. ◦ The methods used to inform other employers of any precautionary measures to be taken for normal and emergency situations. ◦ The employer’s chemical labeling system. ◦ Examples in healthcare?

 Employers must provide employees information and education on hazardous chemicals in their work area: ◦ At the time of their initial assignment; ◦ Whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area.  Education may cover categories of hazards.

 Employers must inform employees: ◦ Of the training requirements of this section ( (h) Employee information and training.); ◦ Any operations in their work area where hazardous chemicals are present; ◦ The location and availability of the written hazard communication program.

 Employee education shall include at least: ◦ The means to detect the presence or release of a hazardous chemical in the work area; ◦ The physical and health hazards of chemicals in the work area; ◦ Measures employees can take to protect themselves; ◦ PPE if appropriate; ◦ Details of the employers’ specific program.

 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 categories (e.g., flammable liquids, corrosive materials, carcinogens).

 Cleaning supplies/solutions  Large volume liquids in storage  Oxygen  Acetone  Paint, paint thinner  Formaldehyde  Others?

 Individuals bringing chemical/hazardous materials into the workplace…..cleaning solutions, etc.  Covering manufacturer labels.  Pouring hazardous materials into an unmarked container, one that is not going to be used immediately.  Hazardous materials in all areas….need all employees involved and trained.

 The rule does not require employers to maintain records of employee training, but many employers choose to do so.  This can help in monitoring a Hazard Communication program to ensure that all employees are appropriately trained. Hazard Communication

Think safety, not just compliance!