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Why does it always have to be a disaster to remind us of why certain safety measures are important. Perhaps your company doesnt deal with an entire reservoir of chemical waste, but many company need to control some sort of flammable or caustic substance. Here are a few questions to ask yourself about your companies chemical procedures.
Do you have the proper MSDS (Material Safety Data Sheets) on all the chemicals and substances that are handled by your employees?
OSHA estimates that 32 million employees are exposed to hazardous chemicals each year in the United States. Understanding OSHA's Hazard Communication (HazCom) program can be quite confusing at times. OSHA 29 CRF Part 1910 Subpart Z states that the purpose of the program is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, materials safety data sheets and employee training.
Scope and Range of HazCom
All hazardous chemicals as defined by OSHA that employees may be exposed to under normal workplace conditions of use or in a foreseeable emergency are covered under this standard.
Exemptions:
Hazardous substances being removed under CERCLA
Tobacco or tobacco products
Wood or wood products that will not be processed at all
Manufactured articles other than a fluid or particle that are formed to a specific shape during manufacturing
Food or alcoholic beverages which are sold, used, or prepared in a retail establishment, or intended for consumption
Prescription or over-the-counter drugs
Cosmetics
Consumer products where the employer can show that it is used in the workplace in a method, duration, and frequency of exposure which is not greater than experienced by consumers
Ionizing and non ionizing radiation
Biological hazards
Employer Responsibilities - 7 Standards under HazCom:
Chemical inventory
Labeling
Material Safety Data Sheets (MSDS)
Non-routine tasks
Multi-employer workplace
Training
Hazcom plan
Chemical Handling and Maintenance:
Hazardous Chemical Inventory: at minimum, is a list of hazardous chemicals known to be present in the workplace.
It is a good idea to include the common names, trade names, chemical manufacturer, locations and quantities in the inventory.
Types of containers:
Primary- are prelabeled containers of Hazardous Chemicals (HC) that you purchase from the manufacturer or distributor.
Secondary- when employer transfers a HC from primary to another container to store and use smaller quantities.
Stationary- large permanent containers.
Portable- used when small amount of chemical is transferred into another container for immediate use.
Chemical Labeling
Primary container labels must contain:
product name
name and address of manufacturer
health effects including target organs
must be in English and legible
Secondary labeling: employee is responsible to make sure every secondary container of HC is labeled, tagged or marked with at least the following information:
identity of HC
appropriate hazard warnings, pictures, words, and/or symbols which provide at least general hazard information, which in conjunction with MSDS will provide employee with specific information on physical and health hazards
employees must be trained in how to read designated labeling systems
i.e. NFPA, HMIS
HMIS - Hazardous Materials Identification System
health hazard (blue) / 0-4 (4 worst or most)
fire hazard (red) / 0-4
reactivity (yellow) / 0-4
personal protective equipment (white) / listed
NFPA (National Fire Protection Association)
red (flammability)
blue (health)
yellow (reactivity)
white (special hazards)
There are 2 exceptions to labeling portable containers:
containers do not have to be labeled if employee filling container is only employee using chemical.
if there will be no material left in container at the end of the work shift.
Material Safety Data Sheet (MSDS):
Chemical manufacturers and importers must obtain or develop a MSDS for each HC they produce or import.
Manufacturer and importer responsibilities:
prepare MSDS and ensure the information is accurate
update MSDS when aware of new information
provide MSDS with the first chemical shipment or as requested by the employer
Distributor responsibilities:
ensure that MSDS's are provided to other distributors and employers with the initial product shipment or upon request
Employer responsibilities:
provide ongoing maintenance and updates of chemical MSDS
obtain an MSDS for each chemical if not provided with the initial product
make sure that all MSDS's are readily accessible during each work shift
Each MSDS must be in English, employer may obtain copies in other languages.
MSDS are not standardized, but all information described below must be present somewhere on the MSDS:
product information-dates, names, phone numbers, etc.
ingredient information-CAS #, exposure limits, etc.
physical and chemical characteristics
appearance, specific gravity, vapor pressure, etc.
fire and explosion data
fire fighting measures
reactivity data
health hazard information
hazard identification-acute hazards
first aid measures
precautions for safe handling and use
transportation information
labeling information
HazCom Training:
Who needs to be trained?
all full time, part time, temporary and volunteer employees
employer must evaluate each employee's level of knowledge with regard to chemical hazards
How often is training needed?
training at time of initial assignment
when new physical of health hazard is introduced
annual training recommended
What information in presented?
requirements of 29 CFR 1910.1200
any operations in an employee's work area where hazardous chemicals are present
methods and observations used to detect releases
physical and health hazards of chemicals present
measures of protection
location, availability and details of employee HazCom plan
Multi-Employer Worksites:
All employers hiring outside contractors must include the following in their HazCom plan:
the HC's employees may be exposed to
methods the employer will use to provide the contractors on site access to MSDS's
methods the employer will use to inform the contractor of precautionary measures taken to protect themselves when working around HC's.
When it comes to running a safety program, most safety managers do not give a lot of thought to the potential dangers associated with storing and handling flammable liquids. Whether these liquids are fuels, alcohols, or degreasers, they have the potential to start fires, explode, or cause serious health effects. Most companies do not realize it, but there are many standards created by OSHA that regulate how flammable liquids are to be handled and stored in the workplace. Managers should get used to the terms D.O.T. approved safety cans, bonding and grounding, and ventilation. If one is to look into the OSHA standards for flammable liquids, they will see these terms throughout the text. OSHA can and will give citations to companies that do not utilize flammable liquids properly.
Our recommendation is to get a basic understanding of these regulations first. Start with a comprehensive fire safety policy and training protocol. Then put approved safety cans and flammable liquid cabinets into service. Once that is taken care of, start with bonding and grounding applications, and then move into more advanced control processes. Contact a local safety expert to advise you on how to develop you policies and trainings. Conduct a site safety assessment to locate flammable liquid hazards as well as other hazards that exist in your workplace. Flammable liquids pose serious threats to your employees and company property. Take control of them now. Below is a link to an excellent article written by Gary Marcus in EHS Today. This article gives a very basic understanding of how to safely handle and store flammable liquids.
Can you legally use that red plastic $5.00 gas can on your jobsite?
The short answer, probably not.
OSHA Standard 29 CFR 1926.152(a)(1) states "Only approved containers and portable tanks shall be used for storage and handling of flammable and combustible liquids. Approved safety cans or Department of Transportation approved containers shall be used for the handling and use of flammable liquids in quantities of 5 gallons or less.
Anytime the word "shall" is used in a regulation, it means that this rule is mandatory and must be followed.
What is an approved safety can or DOT gas can?
A safety can is (29CFR1926.155(1) an approved, closed container, of not more than 5 gallons capacity, having a flash arresting screen, spring closing lid and spout cover and so designed that it will safely relieve internal pressure when subjected to fire exposure.
Approval is given by a nationally recognized testing laboratory, for example, Underwriters' Laboratory, Inc.
Gas cans can only display DOT approval markings when they meet stringent Department of Transportation requirements. Here is where it gets confusing, inexpensive plastic gas cans may meet EPA (Environmental Protection Agency) requirements, but they do NOT meet DOT rules. Some gas cans may say they meet CARB spill-proof regulations in certain states or AQMD (Air Quality Management District) rules. Again, this doesn't help when trying to comply with OSHA. None of these other regulatory agencies are the same as DOT. They are not interchangeable.
If your head isn't already spinning, one last point. If you are looking for a UL "approval", you will see the following words on the product, UL Listed. If your can has a UL Classified marking, this is not the same as UL Listed (approved). If you want more information about UL markings, go to http://tinyurl.com/pxb9dt
Now that you know the correct can to use, shown below are safety rules to follow when using gas cans. This information can be used for this week's tailgate safety meeting.
Safety Tips for Gas Cans
Portable Gas Cans
Several vehicle fires have occurred as a result of filling metal portable gasoline cans while placed on the back of pickup trucks with plastic bed liners. The insulating effect of the plastic surface prevents the static charge generated by the gasoline flowing into the gas can from grounding. As static charge builds, it can create a static spark between the gas can and the fuel nozzle. When the spark occurs in the flammable range in the gasoline vapor space near the open mouth of the gas can, a fire can occur. Some tips:
Do not fill any container while it is inside a vehicle, a vehicles trunk, pickup bed, or on any surface other than the ground.
Use only an approved container with a cap that fits tightly.
Remove the approved container from the vehicle and place it on the ground. Keep container a safe distance away from the vehicle, other customers, and traffic.
Keep the nozzle in contact with the can during filling.
Fill container about 95% full to allow for expansion.
If gasoline spills on the container, make sure it is evaporated before putting it in your vehicle.
Equipment Refueling
Shut off motor on equipment and give motor rime to cool off before refueling.
Dont refuel near an open flame or near a sparking situation.
Keep a fire extinguisher nearby.
Dont spill the fuel.
Dont overfill the fuel tank. On hot days, allow for expansion.
M.R.S. OSHA Safety, Inc. provides clients customized health and safety solutions throughout the United States. Our solutions range from site-specific programs such as written safety programs, safety inspections, on-site safety training, to ready-to-use solutions such as Tailgate Safety Meetings (a.k.a. Toolbox Talks). Training includes Competent Person Scaffolding or Excavation, 10/30-hour Construction Safety Training, HAZWOPER, Arc Flash Training and First Aid/CPR training.
Look around your workplace--how do you store your chemicals? During inspections, I notice that usually chemicals are stored (or not stored) randomly all over the workplace. They are left where they were last used or shoved back onto shelves with newer chemicals placed in front of them. Shelves are overcrowded and workers have to move stuff around to reach the required container.
When it comes to hazardous materials, we know it's important to have a written policy, Material Safety Data Sheets (MSDS's) and train employees on how to work with chemicals safely, BUT it is also extremely important to store these substances safely. Chemicals must be stored in accordance with strict OSHA (Occupational Safety and Health Administration) regulations. Improper storing and handling can lead to serious consequences. Materials Handling and Storage Regulations are found in 29 CFR 1910 Subpart N. Store everything according to OSHA's general storage requirements.
Storage Basics
Storage of material must not create a hazard. Aisles and passageways must be kept clear. Material must be stored securely. Storage areas shall be kept free from accumulation of materials that constitute hazards from tripping, fire or explosion.
In addition to the basics, OSHA has specific chemical storage requirements (see 29 CFR 1910 Subpart H). These requirements are based on the type of chemical, its container and even on how it's used. For example, in the Flammable and Combustible Liquids section, is information on how much of a chemical that can be on the premises, what kind of storage cabinet is needed and even where you can or cannot put that storage cabinet.
Before a chemical can be stored properly, we need to know its hazards. This is where the MSDS comes in. An MSDS provides us with all data known about a chemical including its hazards. Chemical hazards are: flammable/combustible, reactive, toxic, explosive, oxidizing, carcinogenic and corrosive. They can be health hazards. When trying to determine these hazards, review these sections.
Physical/Chemical Characteristics Section
This gives information on the physical properties of a chemical, including its color and odor so it can be identified. Under what conditions is it a liquid, solid or vapor. What are the freezing or boiling points. Is it an acid or base.
Fire/Explosion Section
This section describes how to prevent a fire or explosion when storing and using the product.
Reactivity Section
This section tells you under which conditions dangerous chemical reactions can occur. How to avoid dangerous mixtures and how to use appropriate storage methods.
Health Hazards Section
This section includes information on acute (short-term) and chronic (long-term) health effects, signs and symptoms. It gives first aid procedures to follow in an emergency.
Hazardous Materials Storage Rules:
Store like chemicals together and away from chemicals that might cause a reaction if mixed.
All chemicals should be labeled and dated.
Flammable materials should be stored in approved, dedicated, flammable materials storage cabinet.
Liquids should be stored in unbreakable or double-contained packaging or storage cabinet should have the capacity to hold the contents if the container breaks.
No flames or hot work in flammable/combustible storage area.
Remember, while it is important to work safely when using chemicals, it is just as important to store hazardous materials safely according to MSDS and OSHA requirements.
M.R.S. OSHA Safety, Inc. provides clients customized health and safety solutions throughout the United States. Our solutions range from site-specific programs such as written safety programs, safety inspections, on-site safety training, to ready-to-use solutions such as Tailgate Safety Meetings (a.k.a. Toolbox Talks). Training includes Competent Person Scaffolding or Excavation, 10/30-hour Construction Safety Training, HAZWOPER, Arc Flash Training and First Aid/CPR training.
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