HAZARDOUS COMMUNICATION SUBPART Z hour Lesson Sam Mason, CMfgT, CSTM Authorized OSHA Trainer Morehead State University

Purpose  The purpose of the standard is to make sure that the hazards of chemicals are evaluated  That information concerning their hazards is communicated to employers and employees

 More than 30 million workers are potentially exposed to one or more chemical hazards.  Estimated 650,000 existing hazardous chemical products,  hundreds of new ones are being introduced annually  This poses a serious problem for exposed workers and their employers. Why????

Historically  Humans have found or made 50 million different chemicals here on Earth, the vast majority over the last few decades.  Number of unique chemicals now registered in a database maintained by the American Chemical Society as of yesterday Alexis Madrigal Wired Science

New Rate  It took 33 years to get the first 10 million chemicals registered  A mere nine months to get the last 10 million chemicals into the database.  acceleration is due to better tracking by the American Chemical Society Alexis Madrigal

Who is covered  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

Background  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

Background  The Hazard Communication Standard (HCS)  will result in a reduction of illnesses and injuries caused by chemicals.  Helps employers with having the information they need to design an appropriate protective program.

 The HCS also allows:  The need to know what protective measures are available to prevent adverse effects from occurring  and provides employees with the information they need MSDS Background

 Employees will be better able to participate in the programs effectively  when they understand the hazards involved, and to take steps to protect themselves.  Together (the employer and employee actions)  will prevent the occurrence of adverse effects caused by the use of chemicals in the workplace Again…the Why??

Chemical Manufactures  A significant portion of the standard pertains only to chemical manufactures, importers, and distributors  Employers who do not produce chemicals only have to focus on establishing a workplace program and communicating information to their workers  Appendix E provides a guide

Employers  Employers are required to provide information to their 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 training

Warehouse and Retail Operations  In work operations where employees only handle chemicals in sealed containers, which are not opened under normal conditions  Employers must only do the following:  Ensure labels on incoming chemicals are not defaced or removed  Maintain copies of any material safety data sheets that are received with incoming shipments  Obtain MSDS a.s.a.p. for shipments received w/out MSDS

 Provide employees with information and training (no written program required) to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container Warehouse and Retail Operations

Labeling Exemptions  Other federal agencies control the labeling requirements for the following substances:  Pesticides  Chemicals covered under the Toxic Substance Control Act  Foods or food additives  Distilled Spirits, tobacco  Consumer products, lumber, cosmetics  Hazardous wastes

Employer Requirements- Written Program  (e)(1)  Employers must develop a written program that covers at least:  Labels and other forms of warnings  Material Safety Data Sheets  Employee Information and Training

 Employers must develop a written program that covers 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 Employer Requirements- Written Program

Multi-Employer Workplaces  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 employers chemical labeling system

Consumer Products Exemption  Any consumer product as defined in the Consumer Product Safety Act where the employer can show that:  It is used in the workplace for the purpose intended  The use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended

Written Program Availability  The employer must make the written program available, upon request, to:  Employees and their designated representatives  Where work is carried out at more than one location, the program may be kept at the main location

Labels, Tags and Markings  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

Hazardous Materials Placards  10.8” x 10.8”  Set on a 45 degree  Non Bulk containers have similar label  4” x 4”  Four indicators to alert emergency personnel about the Hazard Color Hazard Class Visual Symbol United Nations Number

Hazardous Materials Placards  Colors  Red – flammable  Green – non-flammable  Yellow – Oxidizer  Blue – danger when wet  White – inhalation hazard and poison  Black and White – corrosive  Red and White Stripe – flammable solid/ spontaneously combustible  White and Yellow – Radiation  Orange – Explosives  Black and White Stripes – Miscellaneous Hazard

Hazardous Materials Placards  There are 9 classes for hazardous materials:  Class 1 explosives  Class 2 gases (flammable, nonflammable, inhalation hazard/poison, or oxygen)  Class 3 liquids that burn (flammable and combustible liquids, based on their flashpoint)  Class 4 flammable solids, spontaneously combustible, or dangerous when wet materials  Class 5 oxidizers and organic peroxides  Class 6 poison/toxic solids and liquids, infectious materials  Class 7 radioactive (three sub classes)  Class 8 corrosives (acids and bases)  Class 9 miscellaneous Hazard Class

Hazardous Materials Placards  There are hundreds of four digit numbers used, from 1001 (acetylene) to 9279 (hydrogen, absorbed in metal hydride).  The number in some cases is specific to a chemical and in other cases reflects a variety of hazardous materials.  1017 is only used for chlorine,  1005 has five chemical listings,  1993 is used for eight chemical listings and  2810 is used for 36 chemical listings UN Number

Container Labeling Exemption for Portable Containers  The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use by the employee who performs the transfer

The employer need not affix new labels to comply with the standard if existing labels already covey the required information

New Hazard Information  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

MSDS kept in other forms  MSDS may be kept in any form including operating procedures  It may be more appropriate to address the hazards of a process rather than individual hazardous chemicals

Employee Information and Training  Employers must provide employees information and training 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  Training may cover categories of hazards

Employee Information  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 Training  Employee training 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  Details of the employers specific program

Employee Training Training shall include the following:  An explanation of the Hazard Communication Program.  An explanation of MSDSs and how to access an MSDS.  A review of chemicals used on site.  A review of the locations of work areas using hazardous products.  Identification of hazards associated with the use of chemicals.  A review of protective measures required for specific hazards.  An explanation of the labeling system used.

Hazard Definitions (c)

Chemical Exposure Severity & Duration  “Acute” effects usually occur rapidly as a result of short-term exposures, and are of short duration  “Chronic” effects generally occur as a result of long-term exposure, and are of long duration

Corrosive  Visible destruction, or irreversible damage to body tissue  Acids  Caustics (or bases) pH Scale Acids Caustics (or bases)

Target Organ Effects

Hepatotoxins  Chemicals which produce liver damage  Signs and Symptoms: Jaundice, liver enlargement  Chemicals: Carbon Tetrachloride, nitrosamines  Found: HVAC Freon, cosmetics, latex, pesticides

Nephrotoxins  Chemicals which produce kidney damage  Signs and Symptoms: Edema  Chemicals: Halogenated Hydrocarbons, uranium  Found: flame retardants, fire extinguishants, refrigerants, prope llants, solvents, pharmaceuticals

Neurotoxins  Chemicals which produce their primary toxic effects on the nervous system  Signs and Symptoms: Narcosis, behavioral changes, decreased motor function  Chemicals: Mercury, carbon disulfide, lead

 Found:  Adhesives, Agent Orange, aspartame, ammonia, arsenic, benzene, carbonless copy paper, carbon monoxide, carpet cleaning agents, CCA (copper-chromium- arsenate), chemical warfare agents, chlorine, combustion products, contaminated or defective products, copper-chromium-arsenate, damp buildings, dioxin, drugs, formaldehyde, gamma butyrolactone, gasoline, glues, heavy metals, herbicides, lacquer sanding sealer, lead, lithium, MDI (methyl diisocyanate), MEK (methyl-ethyl-ketone), manganese, mercury, metals, methylene chloride, mixed toxic waste, mold, municipal sludge, mycotoxins, naphthalene, n-hexane, oil and gas field emissions, opiates, organic metals, paint, paint remover, pesticides (organochlorines, organophosphates, etc.), phenolic resins, pollution (ground, soil, water, air), polychlorinated biphenyl (PCB), radiation injuries, smoke removing agents, solvents, styrene, synthetic carpets, TDI (toluene diisocyanate), toluene, toxic waste, trichloroethane, trichloroethylene, welding fumes, wood preservatives, xylene, etc. Neurotoxins

 Illnesses:  chemical sensitivity syndrome, environmental illness, memory dysfunction, multiple chemical sensitivity, neurologic illnesses due to toxic chemicals (amyotrophic lateral sclerosis, movement disorders, multiple sclerosis, paralysis,, etc.), panic disorder, Parkinson's disease, tremor, etc.  Brain Damage:  Common symptoms can include problems with memory, concentration, reaction time, sleep, thinking, language, as well as depression, confusion, personality changes, fatigue, and numbness of the hands and feet. Neurotoxins

Agents which act on the blood  Decrease hemoglobin function, deprive the body tissues of oxygen  Signs and Symptoms: Cyanosis, loss of consciousness  Chemicals: Carbon monoxide, cyanides

 Cyanide Poisoning Treatment Coalition

 Found:  Cyanide is contained in cigarette smoke and the combustion products of synthetic materials such as plastics. Paper, Plastics and textiles industries Chemicals used to develop photographs Metallurgy for electroplating, metal cleaning, and removing gold from its ore Cyanide gas is used to exterminate pests and vermin in ships and buildings. Agents which act on the blood

Agents which damage the lungs  Chemicals which damage pulmonary tissue  Signs and Symptoms: Cough, tightness in the chest, loss of breath  Chemicals: Asbestos, silica  Found:

 drywall and joint compound  plaster  gas mask filters pre 1960s  mud and texture coats  vinyl floor tiles, sheeting, adhesives  roofing tars, felts, siding, and shingles  "transite" panels, siding, countertops, and pipes  popcorn ceilings,  fireproofing  caulk  gaskets  packing, a system for sealing a rotating shaft  brake pads and shoes  clutch plates  stage curtains  fire blankets  interior fire doors  fireproof clothing for firefighters  thermal pipe insulation  filters for removing fine particulates from chemicals, liquids and wine  dental cast linings  HVAC flexible duct connectors  drilling fluid additives Asbestos and Silicas

Reproductive toxins  Chemicals which damage reproductive capabilities  Includes chromosomal damage (mutations) and damage to fetuses (teratogenesis)  Signs and Symptoms: Birth defects, sterility  Chemicals: Lead

 Found:  House paint before  Toys and furniture painted before  Painted toys and decorations made outside the U.S.  Lead bullets, fishing sinkers, curtain weights.  Plumbing, pipes, faucets. Lead can be found in drinking water in homes whose pipes were connected with lead solder. While new building codes require lead-free solder, lead is still found in some modern faucets.  Soil contaminated by decades of car exhaust or years of house paint scrapings. Thus, lead is more common in soil near highways and houses.  Hobbies involving soldering, stained glass, jewelry making, pottery glazing, miniature lead figures  Children's paint sets and art supplies (always look at labels).  Pewter pitchers and dinnerware.  Storage batteries. Lead

Cutaneous hazards  Chemicals which effect the dermal layer of the body  Signs and Symptoms: Defatting of the skin, rashes, irritation  Chemicals: Ketones, chlorinated compounds  Found: Acetones, Cleaner solvents, dry cleaning chemicals, plastics, filtration, degreasing agents and pesticides

Eye hazards  Chemicals which affect the eye or visual capacity  Signs and symptoms: Conjunctivitis, corneal damage, blurred vision, burning or irritation  Chemicals: Solvents, corrosives

Material Safety Data Sheets (MSDS) are one of the most important tools available to employers for providing information, and protection to workers from hazardous chemicals which are used in the workplace.

(g)(2) MSDS, required information  Identity of the chemical  Physical and chemical characteristics  Physical hazards  Chemical hazards  Primary routes of entry  PEL’s or other exposure limits  Control measures  Emergency procedures  Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens  precautions for safe handling and use  Date of preparation  Name, address and telephone of the manufacturer

Material Safety Data SheetU.S. Department of Labor May be used to comply withOccupational Safety and Health Administration OSHA's Hazard Communication Standard,(Non-Mandatory Form) 29 CFR Standard must be consulted for specific requirements. Form Approved OMB No IDENTITY (As Used on Label and List)Note: Blank spaces are not permitted. If any item is not applicable, or no information is available, the space must be marked to indicate that. Section I Manufacturer's NameEmergency Telephone Number Address (Number, Street, City, State, and ZIP Code)Telephone Number for Information Date Prepared Signature of Preparer (optional)

Section II - Hazard Ingredients/Identity Information Hazardous Components (Specific Chemical Identity; Common Name(s))OSHA PELACGIH TLVOther Limits Recommended%(optional)

Section III - Physical/Chemical Characteristics Boiling PointSpecific Gravity (H 2 O = 1) Vapor Pressure (mm Hg.)Melting Point Vapor Density (AIR = 1)Evaporation Rate (Butyl Acetate = 1) Solubility in Water Appearance and Odor

Section IV - Fire and Explosion Hazard Data Flash Point (Method Used)Flammable LimitsLEL UEL Extinguishing Media Special Fire Fighting Procedures Unusual Fire and Explosion Hazards

Section V - Reactivity Data StabilityUnstableConditions to Avoid Stable Incompatibility (Materials to Avoid) Hazardous Decomposition or Byproducts Hazardous PolymerizationMay OccurConditions to Avoid Will Not Occur

Section VI - Health Hazard Data Route(s) of Entry:Inhalation?Skin?Ingestion? Health Hazards (Acute and Chronic) Carcinogenicity:NTP?IARC Monographs?OSHA Regulated? Signs and Symptoms of Exposure Medical Conditions Generally Aggravated by Exposure Emergency and First Aid Procedures

Section VII - Precautions for Safe Handling and Use Steps to Be Taken in Case Material is Released or Spilled Waste Disposal Method Precautions to Be taken in Handling and Storing Other Precautions

Section VIII - Control Measures Respiratory Protection (Specify Type) VentilationLocal ExhaustSpecial Mechanical (General)Other Protective GlovesEye Protection Other Protective Clothing or Equipment Work/Hygienic Practices

Setting up a program  The HCS covers both:  Physical hazards (such as flammability), and  Health hazards (such as irritation, lung damage, and cancer)  Most chemicals used in the workplace have some hazard potential, and thus will be covered by the rule

 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 Setting up a program

 Make a list of all chemicals in the workplace that are potentially hazardous  The best way to prepare a comprehensive list is to survey the workplace  Identify chemicals in containers, including pipes  Establish purchasing procedures so that MSDSs are being received before a material is used in the workplace Setting up a program

Identify hazardous chemicals in the workplace.  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 your supplier and request one  You should not allow employees to use any chemicals for which you have not received an MSDS

Preparing and implementing a hazard communication program  All workplaces where employees are exposed to hazardous chemicals must have a written plan  The plan does not have to be lengthy or complicated

Employee training  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)

Documentation  The rule does not require employers to maintain records of employee training, but many employers choose to do so  This may help you monitor your own program to ensure that all employees are appropriately trained Hazard Communication