Recognizing Chemical Hazards
29 CFR 1910.1200, Appendix A – E
OSHA Publication Number 3084. Chemical Hazard Communication
OSHA Part 1910, Subpart Z
The American Conference of Governmental Industrial Hygienists (ACGIH) listing of Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment
Recognize the purpose and importance of a hazard communication program in the workplace.
Recognize the physical and health hazards inherent with hazardous chemicals.
Identify the purpose of a Safety Data Sheet, and its components.
Identify chemicals and their hazards, through labeling and warning practices.
Recognize the information and training related to hazardous chemicals that should be supplied by an employer.
According to the Occupational Safety & Health Administration (OSHA), the Globally Harmonized System (GHS) covers over 43 million workers who produce or handle hazardous chemicals in more than 5 million workplaces across the country. The GHS is estimated to prevent over 500 workplace injuries and illnesses and 43 fatalities annually, and result in cost savings to American businesses of more than $475 million in productivity improvements, fewer safety data sheet and label updates, and simpler new hazard communication training.
The purpose of the Globally Harmonized System (GHS) is to standardize how we communicate about chemical hazards in the workplace. OSHA has adapted its Hazard Communication Standard to align with the globally harmonized system.
Hazard Communication Standard
Identifies categories of physical hazards:
Gases under pressure
Industrial businesses are required to have a written hazard communication program and to provide workers with additional training regarding site-specific chemicals.
Hazard communication programs should consist of three key areas:
1. Chemical Inventories and Safety Data Sheets (SDS)
Updated inventory of the hazardous chemicals present at the workplace.
Each hazardous chemical must have a Safety Data Sheet (SDS).
Safety Data Sheets must contain required information and be easily understandable and accessible.
2. Labels and Warnings
Identify chemicals and corresponding hazards through labels and warning information.
3. Hazard Communication Training
Reinforces safety practices through a hazard communication training program.
Informs employees of the hazards of non-routine tasks.
Safety Data Sheets (SDS)
The best source of information about a hazardous chemical is the SDS, a technical bulletin of the chemical’s hazards. OSHA requires the information to be consistent between manufacturers. Chemical manufacturers and distributors are required by federal law to furnish SDSs for hazardous products and OSHA requires employers to make them easily available to workers.
Precautions for safe handling of hazardous chemicals include general hygiene, such as no eating and drinking in the work areas. Conditions for safe storage include best practices such as ventilation needs, storage room designs and packaging requirements.
If employees are assigned to respond to accidents and spills, it is especially important that these workers are trained in related responsibilities and properly equipped—and part of being properly equipped is to have easy access to the Safety Data Sheet collection.
Workers must always read the SDS before working with any new chemical. OSHA requires that SDSs be readily available during all work shifts, to every employee. Your facility may keep SDS binders in a central location, or maintain electronic SDSs and provide access through computer terminals. Safety professionals should know where SDSs are located and make this location plain to the workforce.
Company procedures may allow cleanup of small amounts of specific chemicals by people who are not part of a spill response team. However, only trained and properly equipped individuals who have access to spill response kits should clean up even the smallest of spills.
The Hazard Communication Standard requires pictograms on manufacturer and supplier labels of chemical containers to warn of potential hazards of exposure. The pictograms are globally harmonized symbols and represent a distinct hazard. In addition to the original manufacturers’ label, employers may use in-house labels, sometimes referred to as secondary labels. These labels must meet the Hazard Communication Standard requirements.
The National Fire Protection Association and the Workplace Hazardous Material Information System offer acceptable alternative labeling systems and are often used for workplace containers. If an in-house label is used on a container already labeled by the manufacturer, it is an addition and must not block out any of the manufacturer’s label.
If your workplace uses optional in-house labels, you need to understand the labels’ coding and information.
Best practices for employers:
Employers should review the new SDSs in a timely fashion upon receipt.
If the employer does not receive the SDSs in a timely fashion, it should promptly communicate in writing with the manufacturer to obtain the SDSs. If the employer does not receive the SDSs by June 1, 2016, OSHA has indicated that it will not cite employers who show “good faith efforts” to obtain the SDSs.
Employers should continuously evaluate the workplace using the SDSs to identify hazardous chemicals and how their employees may be exposed.
Employers whose employees work with or around hazardous chemicals must ensure that they review the updated SDSs and assess each of the employer’s underlying compliance programs (e.g., emergency action plan, storage of flammable and combustible materials, PPE, respiratory protection, etc.) that may be impacted by the SDSs.
Employers should ensure that employees who work with or around hazardous chemicals are trained to recognize the pictograms and hazard warnings that will be required under the new Hazard Communication Standard. Employers should document this training and develop mechanisms to ensure that employees understand the hazards of working with or around hazardous chemicals.
Hazard Communication Commonly Asked Questions
Question: “Are there new training requirements for staff for the GHS update since the 2014/15 rollout?”
Answer: No. June 1st, 2016, marked the final milestone for GHS phased implementation: “Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.”
However, each time a new physical or health hazard is identified, your employees need training—that’s the mandate for employers.
California’s standard (§5194. Hazard Communication) was revised last year simply to amend the definition of “Safety Data Sheets”, so no training required.
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