Chemical Hazard Communication

BusinessManagement

  • Author Mark Hohman
  • Published December 14, 2011
  • Word count 1,346

About 32 million workers work with and are potentially exposed to one or more chemical hazards. There are an estimated 650,000 existing chemical products, and hundreds of new ones being introduced annually. This poses a serious problem for exposed workers and their employers.

Chemical exposure may cause or contribute to many serious health effects such as heart ailments, central nervous system, 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 and other serious accidents.

Because of the seriousness of these safety and health problems, and because many employers and employees know little or nothing about them, the Occupational Safety and Health Administration (OSHA) issued the Hazard Communication Standard. The basic goal of the standard is to be sure employers and employees know about work hazards and how to protect themselves; this should help to reduce the incidence of chemical source illness and injuries.

The Hazard Communication Standard establishes uniform requirements to make sure that the hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated, and that this hazard information is transmitted to affected employers and exposed employees.

Employers and employees covered by an OSHA-approved state safety and health plan should check with their state agency, which may be enforcing standards and other procedures "at least as effective as," but not always identical to, federal requirements.

In general, it works like this:

Chemical Manufacturers /Importers/ Distributors

• Determine the hazards of each Manufacturers/ product.

• Communicate the hazard information and associated protective measures downstream to customers

through labels and MSDSs.

Employers

• Identify and list hazardous chemicals in their workplaces.

• Obtain MSDSs and labels for each hazardous chemical, if not provided by the manufacturer, importer, or distributor.

• Develop and implement a written hazard communication program, including labels, MSDSs, and employee training, on the list of chemicals, MSDSs and label information.

• Communicate hazard information to their employees through labels, MSDSs, and formal training programs.

How Can Workplace Hazards Be Minimized?

Chemical manufacturers and importers are required to review available scientific evidence concerning the hazards of the chemicals they produce or import, and to report the information they find to their employees and to employers who distribute or use their products. Downstream employers can rely on the evaluations performed by the chemical manufacturers or importers to establish the hazards of the chemicals they use.

Chemicals that are listed in one of the following sources are to be considered hazardous in all cases:

• 29 CFR 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), and

• Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment, American Conference of Governmental Industrial Hygienists

In addition, chemicals that have been evaluated and found to be a suspect or confirmed carcinogen in the following sources must be reported as such:

• National Toxicology Program (NTP), Annual Report on Carcinogens,

• International Agency for Research on Cancer (IARC), Monographs, and

• Regulated by OSHA as a carcinogen.

Why Is a Written Hazard Communication Program Necessary?

A written hazard communication program ensures that all employers receive the information they need to inform and train their employees properly and to design and put in place employee protection programs. It also provides necessary hazard information to employees, so they can participate in, and support, the protective measures in place at their workplaces.

Employers therefore must develop, implement, and maintain at the workplace a written, comprehensive hazard communication program that includes provisions for container labeling, collection and availability of material safety data sheets, and an employee training program. The written program does not have to be lengthy or complicated, and some employers may be able to rely on existing hazard communication programs to comply with the above requirements. The written program must be available to employees, their designated representatives, the Assistant Secretary of Labor for Occupational Safety and Health, and the Director of the National Institute for Occupational Safety and Health (NIOSH).

How Must Chemicals Be Labeled?

Chemical manufacturers and importers must convey the hazard information they learn from their evaluations to downstream employers by means of labels on containers and material safety data sheets (MSDSs).

Also, chemical manufacturers, importers, and distributors must be sure that containers of hazardous chemicals leaving the workplace are labeled, tagged, or marked with the identity of the chemical, appropriate hazard warnings, and the name and address of the manufacturer or other responsible party. In the workplace, each container must be labeled, tagged, or marked with the identity of hazardous chemicals contained therein, and must show hazard warnings appropriate for employee protection. The hazard warning can be any type of message, words, pictures, or symbols that provide at least general information regarding the hazards of the chemical(s) in the container and the targeted organs affected, if applicable. Labels must be legible, in English (plus other languages, if desired), and prominently displayed.

What Are Material Safety Data Sheets, And Why Are They Needed?

The MSDS is a detailed information bulletin prepared by the manufacturer or importer of a chemical that describes the physical and chemical properties, physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures, and control measures.

Chemical manufacturers and importers must develop an MSDS for each hazardous chemical they produce or import, and must provide the MSDS automatically at the time of the initial shipment of a hazardous chemical to a downstream distributor or user.

Distributors also must ensure that downstream employers are similarly provided an MSDS. Each MSDS must be in English and include information regarding the specific chemical identity of the hazardous chemical(s) involved and the common names. In addition, information must be provided on the physical and chemical characteristics of the hazardous chemical; known acute and chronic health effects and related health information; exposure limits; whether the chemical is considered to be a carcinogen by NTP, IARC, or OSHA; precautionary measures; emergency and first-aid procedures; and the identification (name, address, and telephone number) of the organization responsible for preparing the sheet.

Copies of the MSDS for hazardous chemicals in a given worksite are to be readily accessible to employees in that area. As a source of detailed information on hazards, they must be readily available to workers during each work shift. MSDSs have no prescribed format. Employers must prepare a list of all hazardous chemicals in the workplace. When the list is complete, it should be checked against the collected MSDSs that the employer has been sent. If there are hazardous chemicals used for which no MSDS has been received, the employer must contact the supplier, manufacturer, or importer to obtain the missing MSDS. A record of the contact must be maintained.

What Training Is Needed to Protect Workers?

Employers must establish a training and information program for employees who are exposed to hazardous chemicals in their work area at the time of initial assignment and whenever a new hazard is introduced into their work area.

At a minimum, the discussion topics must include the following:

• The hazard communication standard and its requirements.

• The components of the hazard communication program in the employees’ workplaces.

• Operations in work areas where hazardous chemicals are present.

• Where the employer will keep the written hazard evaluation procedures, communications program, lists of hazardous chemicals, and the required MSDS forms.

The employee training plan must consist of the following elements:

• How the hazard communication program is implemented in that workplace, how to read and interpret information on labels and the MSDS, and how employees can obtain and use the available hazard information.

• The hazards of the chemicals in the work area. (The hazards may be discussed by individual chemical or by hazard categories such as flammability.)

• Measures employees can take to protect themselves from the hazards.

• Specific procedures put into effect by the employer to provide protection such as engineering controls, work practices, and the use of personal protective equipment (PPE).

• Methods and observations—such as visual appearance or smell—workers can use to detect the presence of a hazardous chemical to which they may be exposed.

Mark Hohman has been a radiation therapist, dosimetrist and director during his 15 year healthcare career. He is now working at http://selfdirectedce.com/ radiology ceu as an owner/developer of a radiology continuing education website.

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