1. Hazard Communication 29 CFR 1910.1200
Understanding the Requirements of Hazard Communication

2. References
OSHA CFR
Canadian Provincial Code Regulation and Act
Superfund Amendments and Reauthorization act of 1986
Company Hazard Communication Procedure WI6-3-04

3. Objectives
Introduce the requirements of the Hazard Communication Standard.
Demonstrate understanding of hazardous material labeling requirements.
Demonstrate proper use and understanding of Material Safety Data Sheets.

4. The Hazard Communication Standard
Part I
The Hazard Communication Standard

5. The Hazard Communication Standard
The purpose of the Hazard Communication Standard is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazard is transmitted to employers and employees.
Regulations can be found online at OSHA.gov.

6. Hazard Communication Standard Requirements
29 CFR requires that:
Chemical manufacturers must:
Assess the hazards of their products.
Provide Material Safety Data Sheets and Labeled containers.
Employers must:
Provide a written Hazard Communication program.
Make MSDS’s available to employees.
Properly label all chemicals.
Train employees on the Hazard Communication Standard and use of hazardous chemicals.

7. Hazard Communication “The Right to Know”
Hazard Communication is often referred to as the “Right to Know” program.
This standard requires employers to train employees on the methods that are used to communicate chemical hazards.

8. Hazard Communication Standard
Companies where employees are exposed to chemicals during:
Normal working conditions
Foreseeable emergencies
are required to comply
With OSHA 29 CFR
This includes:
Liquids in containers.
Substances in pipes.
Welding and exhaust fumes.
Solids, gases and vapors.
Discussion Note:
Ask the participants to list the chemicals that they work with in their workplace.

9. Hazard Communication Coordinator
The hazard communication coordinator is: Eric Claflin
This person is responsible for:
Identifying hazardous chemicals.
Preparing and implementing the Hazard Communication Program.
Make sure containers are properly labeled.
Obtain and maintain Material Safety Data Sheets.
Provide or coordinate hazard communication training.

10. Written Hazard Communication Program
Every business is required to have a written Hazard Communication Program.
The required contents of this program are:
Designation of program responsibilities.
Labeling and warning methods used.
Location of MSDS.
The methods employers will use to inform employees of the hazards of non-routine tasks.
List of all the hazardous chemicals in the workplace.
Activity:
Take this moment to review your company’s hazard communication plan with employees.
Discussion Point
The lack of a written hazard communication plan is one of the most commonly cited OSHA violations.
Where is the hazard communication program located at your facility?

11. Program Responsibilities
The program responsibilities are as follows:
Responsibility
Person or Position
Identifying hazardous chemicals.
Dept Manager
Administering written program.
Randall D’Amico
In-Facility chemical labeling.
Chemical shipping labeling.
Shipping
Obtaining and maintaining MSDSs.
Eric Claflin
Running info and training programs.

12. Understanding Health Hazards
Part II
Understanding Health Hazards

13. Routes of Exposure Inhalation Ingestion Absorption Injection
Talk about the different routes of exposure. Why would a person ingest chemicals? Answer: Eating after use without proper hand washing.

14. Types of Hazards - Physical
Physical Hazards
Combustible
Compressed Gas
Explosive
Flammable
Oxidizer
Organic Peroxide
Unstable or Water Reactive
Physical Hazard Definitions:
“Combustible liquid" means any liquid having a flashpoint at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3 deg. C), except any mixture having components with flashpoints of 200 deg. F (93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture
"Organic peroxide" means an organic compound that contains the bivalent -O-O-structure and which may be considered to be a structural derivative of hydrogen peroxide where one or both of the hydrogen atoms has been replaced by an organic radical.
"Oxidizer" means a chemical other than a blasting agent or explosive as defined in (a), that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.
"Water-reactive" means a chemical that reacts with water to release a gas that is either flammable or presents a health hazard.
"Unstable (reactive)" means a chemical which in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shocks, pressure or temperature.
Which of these do you have in your workplace?

15. Types of Hazards - Health
Health Hazards
Carcinogen
Corrosive
Highly Toxic
Irritant
Sensitizer
Toxic
Health Hazard Definitions (29 CFR App A)
1. "Carcinogen:" A chemical is considered to be a carcinogen if:
(a) It has been evaluated by the International Agency for Research on Cancer (IARC), and found to be a carcinogen or potential carcinogen; or
(b) It is listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition); or,
(c) It is regulated by OSHA as a carcinogen.
2. "Corrosive:" A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. For example, a chemical is considered to be corrosive if, when tested on the intact skin of albino rabbits by the method described by the U.S. Department of Transportation in appendix A to 49 CFR part 173, it destroys or changes irreversibly the structure of the tissue at the site of contact following an exposure period of four hours. This term shall not refer to action on inanimate surfaces.
3. "Highly toxic:" A chemical falling within any of the following categories:
(a) A chemical that has a median lethal dose (LD(50)) of 50 milligrams or less per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each.
(b) A chemical that has a median lethal dose (LD(50)) 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.
(c) A chemical that has a median lethal concentration (LC(50)) 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.
4. "Irritant:" A chemical, which is not corrosive, but which causes a reversible inflammatory effect on living tissue by chemical action at the site of contact. A chemical is a skin irritant if, when tested on the intact skin of albino rabbits by the methods of 16 CFR for four hours exposure or by other appropriate techniques, it results in an empirical score of five or more. A chemical is an eye irritant if so determined under the procedure listed in 16 CFR or other appropriate techniques.
5. "Sensitizer:" A chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical.
6. "Toxic." A chemical falling within any of the following categories:
(a) A chemical that has a median lethal dose (LD(50)) 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.
(b) A chemical that has a median lethal dose (LD(50)) 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.
(c) A chemical that has a median lethal concentration (LC(50)) 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.
Which of these do you have in your workplace?

16. Something to consider…..
Which is more hazardous: physical or health hazards?
OSHA Definition of Toxic
A “toxic” chemical, when placed on the skin of an albino rabbit, will kill it within 24 hours.
They are both hazardous, but health hazards tend to harm over time, so they can be difficult to detect and prevent.
Lead your class in a discussion about the difference between physical and health hazards. They are both dangerous, but physical hazards are typically easier to see and understand, while health hazards can occur over a period of time and can be difficult to detect.
Talk about the definition to toxic, and how important it is for them to use the proper PPE to prevent exposure.
It will kill an albino rat within an hour.

17. Acute and Chronic Effects
Acute effects from chemical exposure happen immediately.
Vomiting and burning is an example of acute effects.
Chronic effects happen over a long period of time, and are often more difficult to detect.
Cancer or emphysema are examples of chronic effects.

18. Dose and Response
The dose is the amount of chemical that the employee was exposed to.
The response is how the body reacts to the chemical.
The PEL from the MSDS will tell you what exposure levels are dangerous.

19. Target Organ Effects
Some chemicals will target specific organs for damage.
Hepatotoxins
Target the liver.
Nephrotoxins
Target the kidneys.
Neurotoxins
Target the nervous system.
Cutaneous hazards
Target the skin.
Discussion Point: These chronic health effects are taken from the Material Safety Data Sheet for Benzene.

20. Labeling Requirements
Part III
Labeling Requirements

21. Labeling Requirements
When a chemical is received into the workplace, it must be labeled with:
The identity of the chemical.
The appropriate hazard warning.
Name and address of the manufacturer.
Every workplace chemical container must be labeled with:
The appropriate hazard warning.
Discussion Note:
Unlabeled chemicals is one of the most common OSHA violations.

22. Labeling Requirements
The hazard warning may be in words, pictures, symbols, or a combination of the three.
It must provide employees with specific information regarding the physical and health hazards of the chemical.
Discussion Point: Show an example of the labeling used at your facility. What type of hazards do the labels communicate?
What type of hazard warning is used at your facility?

23. 2 – dangerous 1-Minor 0-none/negligible
NFPA 704 System
NFPA 704 System
Fire Hazard
Health Hazard
Flash Points
4 Deadly
4 Below 73 F
3 Extreme Danger
3 Below 100F
2 Hazardous 4
2 Above 100 F not
1 Slightly Hazardous
exceeding 200 F
0 Normal Material 4 4
1 Above 200 F
0 Will not Burn
Specific Hazard
Reactivity
ACID = acid
4 May detonate
Discussion Point
While this is a commonly used method for labeling, alone it does not meet the requirements of (f). The container must still be labeled with the name of the chemical.
ALK = Alkali
3 Shock & heat may
COR = Corrosive
Detonate
4-Severe Serious
2 – dangerous Minor none/negligible
W = use no water
2 Violent Chemical
Change
1 Unstable, if heated

24. Portable and Secondary Containers
Secondary containers have the same requirements for labeling as primary containers.
Portable containers do not have to be labeled, as long as:
The chemical is transferred from a labeled container.
The portable container is in direct control of the person who performed the transfer.
Discussion Point
While it is permissible to use unlabeled portable containers, this activity should be discouraged. As soon as a portable container is left unattended, it becomes a secondary container, and labeling requirements apply. This is a very common OSHA violation. Inspectors find portable containers that have been left unattended.

25. Portable and Secondary Containers - Example
If an employee transfers paint from a properly labeled container to a portable container, that container does not have to be labeled.
However, if that unlabeled container leaves the direct control of the person who performed the transfer, (such as the employee setting it down and walking away) it must be either labeled or returned to the container is was poured from.
These paint cans are unattended and unlabeled, and are a violation of hazard communication requirements.

26. Transporting Chemicals
Chemicals transported on public highways must have a Department of Transportation (DOT) label.
Special DOT requirements must be adhered to for shipping, receiving and transport.

27. Material Safety Data Sheets
Part IV
Material Safety Data Sheets

28. Material Safety Data Sheets
Material Safety Data sheets provide all the information and safety precautions that are necessary to work with a chemical safely.
Employees must have access to a MSDS for every chemical.
Activity: Distribute a Material Safety Data sheet that is used at your facility. Discuss all of its parts.
Discussion Note:
Understanding Material Safety Data Sheets are critical to the safe use of chemicals (h)(3)(ii) requires that employees must be trained in the physical and health hazards of all the chemicals in the workplace. This can be accomplished by having them review the Material Safety Data Sheets.
(Click to Open)

29. Material Safety Data Sheets
Material Safety Data Sheets may be designed to cover a type of chemical instead of just one.
This is useful in facilities where lots of similar chemicals are used.
MSDS’s must still be available for each individual chemical.
Discussion Note
Material Safety Data Sheets binders can get very large and difficult to manage. Employers can use Material Safety Data sheets that cover chemical types to make the information more manageable. However, the individual sheets must also be available to employees.

30. Permissible Exposure Limits
OSHA has established Permissible Exposure Limits (PEL’s) for each chemical.
The PEL is listed on the Material Safety Data Sheet.
The employer must take steps to prevent employees from exceeding PELs.
Discussion Point: What are the PEL’s for the chemicals employees will be working with?

31. Exposure Controls and Protective Measures
Material data sheets will describe required protective measures, such as:
Ventilation and other engineering controls.
Work practices and procedures that prevent exposure.
Use of personal protective equipment, such as gloves and goggles.
During OSHA visits, OSHA inspectors will often check the MSDS to see if workers are wearing all required PPE.

32. First Aid
The MSDS will tell you what to do in the event that a worker becomes exposed to a chemical.
Eye wash stations are a common requirement for flushing eyes after exposure.
It is important to be familiar with the first aid requirements for chemicals. After an accident is too late to find out.

33. MSDS Activity
What are the health hazards associated with the chemical on your MSDS?
What personal protective equipment is required to work with the chemical?
What are the physical hazards associated with this chemical?
What should you do in the event of a chemical spill?
Activity Note
This is an important activity. It provides the participants familiarity with using MSDS’s, and if all workplace chemicals are discussed in this activity, it meets the training requirements of (h)(3)(ii).
It is also important to note the differences between each Material Safety Data Sheet. While the required content is the same, the format is different.

34. Chemicals Used In The Workplace
Part V
Chemicals Used In The Workplace

35. Common Chemicals In Use
Chemical Name: Ultra-Set A
Hazards: Slightly hazardous, avoid breathing vapors, getting in eyes or prolonged skin contact.
Chemical Used For: Making bags
Instructor Note: Use this slide to discuss the types of chemicals, there hazards, and their application in the workplace. Duplicate this slide for each type of commonly used chemical.
Special Precautions or Work Practices: Wear safety glasses when pouring.

36. Common Chemicals In Use
Chemical Name: Staticide
Hazards: Slightly hazardous
Chemical Used For: Removing
Static charge from parts
Instructor Note: Use this slide to discuss the types of chemicals, there hazards, and their application in the workplace. Duplicate this slide for each type of commonly used chemical.
Special Precautions or Work Practices: Local ventillation and safety glasses

37. Common Chemicals In Use
Chemical Name: Roller Blanket Wash
Hazards: Causes skin and eye irritation, Vapors are an irritant to respiratory tract and mucus membranes. Flammable
Chemical Used For: Washing Blankets, solvent for printing
Instructor Note: Use this slide to discuss the types of chemicals, there hazards, and their application in the workplace. Duplicate this slide for each type of commonly used chemical.
Special Precautions or Work Practices: Wear chemical resistant gloves and glasses. Do not use near open flame

38. Common Chemicals In Use
Chemical Name: Orange Sol Cleaner
Hazards: May cause eye irritation, can cause dermatitis, gastric disturbance if ingested and may irritate mucus membranes if inhaled.
Chemical Used For: General Cleaning
Instructor Note: Use this slide to discuss the types of chemicals, there hazards, and their application in the workplace. Duplicate this slide for each type of commonly used chemical.
Special Precautions or Work Practices: Eye protection for splash risk, gloves for sensitive individuals

39. Hazardous Chemical Release Detection
(h)(3)(i) requires employers to instruct employees in the methods and observations that may be used to detect the presence or release of hazardous chemical
What methods are used in your workplace to detect hazardous chemicals?
Discussion Note:
A visual scan and smell are common methods for detecting hazardous chemicals. However, many chemicals do not smell. Discuss with your participants the way your workplace detects an unauthorized release of hazardous chemicals.

40. Symptoms of Exposure
Dizziness, nausea, rashes, and respiratory irritation are signs of exposure to hazardous chemicals.
Don’t immediately discount the symptoms as just getting sick, evaluate your work area for potential leaks.
If you have these symptoms, you should exit the work area, notify your supervisor, and consult the MSDS.

41. Personal Protective Equipment
There are many different types of PPE used for protection from chemical hazards:
Dust masks and respirators
Glasses, goggles, and face shields
Hearing protection
Gloves
Foot protection
Head protection
Aprons or full-body suits
What is the standard PPE utilized in your work area?
Activity: Discuss the location and proper use of Personal Protective Equipment at your facility.
PPE should only be used when the hazard cannot be eliminated!

42. Summary
Hazard Communication is the method that employers communicate the hazards of the workplace to employees.
Every chemical must labeled with a minimum of the name of the chemical and the appropriate hazard warning.
Material Safety Data Sheets are required for every chemical and must be readily available to employees.
Every company must have a written hazard communication program.
After the participants have had the opportunity to ask questions, distribute the quizzes.

43. Questions?
After the participants have had the opportunity to ask questions, distribute the quizzes.