Tuesday, November 28, 2006

Hazard Communication Basics Part 3 Chemicals and Labels

For each hazardous chemical which an employer uses, material safety data sheets (MSDS’s) must be obtained. Each sheet must contain at least the following information:

The identity - of the product / chemical as used on the label.

If the chemical is a single substance - its chemical & common name(s).

If the chemical is a mixture of substances - determined to be a hazard, the chemical & common name(s) of all ingredients which have been determined to be health hazards.

The physical hazards - as well as chemical (such as vapor pressure, flash point, potential for fire, explosion, reactivity, etc.).

The signs and symptoms - of exposure to the hazardous chemical.

The OSHA permissible exposure limit - ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the manufacture, importer, or employer preparing the material safety data sheet.

Whether the hazardous chemical is listed - in the National Toxicology Program (NTP) Annual Report on Carcinogens, or has been found to be a potential carcinogen in the Internal Agency for Research on Cancer (IRAC), or by OSHA.

Any applicable precautions - for safe handling and use, including appropriate hygienic practices.

Any Applicable control measures - such as engineering controls, work practices, or personal protective equipment.

Emergency and first aid procedures.

The date of preparation of the MSDS - or the last change to it.

The name, address, and telephone number - of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the MSDS who can provide any additional information.

Employers must maintain - copies of the required MSDS for each hazardous chemical in the workplace, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area[s].

Note: The recommended procedure on each jobsite is to keep a copy of all MSDS’s of the materials on that jobsite, bound in a three-ring binder with your written "HazCom" program and a List of Chemicals- with MSDS’s added to it when a new hazardous substance is introduced. This will insure that your overall "HazCom" program is addressed, available, implemented, and updated at each worksite.

Remember to train your employees of the potential hazards of a new chemical when introduced to their work area[s].

Labels And Other Forms Of Warning

In your workplace, all containers need to be marked, labeled, or tagged with the identity of any hazardous chemicals that are contained within, and, must show the hazard warnings necessary for employee protection. The hazard warnings may be in the form of message, words, pictures, or symbols that indicate general information about the hazard of the chemical(s) contained. Labeling and warning requirement guidelines are as follows:

It is the responsibility of the chemical manufacturer, importer, or distributor - to ensure that each container of hazardous chemicals is labeled, tagged or marked with information regarding the identity of the hazardous chemicals, appropriate hazard warnings, and the name and address of the chemical manufacturer, importer, or other responsible party.

It is the responsibility of the employer - to ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked with the identity of the hazardous chemical contained; and the appropriate hazard warnings.

The employer may use signs - placards, process sheets, batch tickets, operating procedures, or other written materials in lieu of affixing labels to individual stationary (bulk) process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required as outlined earlier in this paragraph.

An employer is not required to label - a portable container into which hazardous chemicals are transferred from a labeled container that are intended only for the immediate use by the employee who performs the transfer.

Employers and employees shall not remove or deface - any existing labels or other forms of warnings on incoming containers of hazardous products, unless the container is immediately marked otherwise with the required information.

Labels or other forms of warning must be legible - printed in English, displayed clearly on the container, and readily available in the work area throughout each work shift. When an employer has an employee who speaks other languages, the information [in their language] may be added to the material, as long as the information is presented in English as well.

The manufacturer, importer, distributor or employer - is not required to affix new labels to containers to comply if the existing labels already convey the required information.

If an employer becomes aware of any significant changes - regarding hazards of a chemical, the labels for those chemicals shall be revised with the new information prior to being distributed or introduced into the workplace again. Hazardous chemicals shipped to the employer after that time must contain the new information.

Note: In reviewing this section, the employer must develop a practice/ program within their company in which hazardous chemicals or products that are incoming, stored, transferred into or broken down into smaller containers, and [or] distributed to individual or various employees and workplaces, shall be treated with the labeling and warning sign practices as outlined in this section.

In addition to proper labeling and other forms of warning practices outlined in this section, and as a part of your "HazCom" program, implement in each workplace proper posting of warning signage for any hazardous area, situation, or condition, that should be conveyed to employees and others in the area. Some examples of this would be; "No Smoking Area" "Flammable", "Hard Hat Area", "Safety Glasses Required In This Area", "Powder Actuated Tools In Use - Please Keep Back", "High Voltage" etc.

It is recommended that an in-depth review of this regulation be made by the employer, and any applicable State regulations addressed prior to implementing a program in your workplace. This is the final part in my three part series on Hazard Communication.