Understanding the Hazardous Materials Communication Program

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:

  1. Chemical inventory
  2. Labeling
  3. Material Safety Data Sheets (MSDS)
  4. Non-routine tasks
  5. Multi-employer workplace
  6. Training
  7. 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.
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