Hazard Communicat

ion & Temp Workers

OSHA Compliance for Temp Agencies and Host Employers

The Hazard Communication Standard (HCS) is based on a simple concept

Employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to at work

Background

They also need to know what protective measures are available to prevent adverse effects from occurring

The HCS is designed to provide employees with the information they need

Background

Hazard Communication Standard

(a)Purpose(b)Scope(c)Definitions(d)Hazard Classification(e)Written Program(f) Labels(g)Safety Data Sheets(h)Employee Training(i) Trade Secrets(j) Effective Dates

Written Program

Four Major Changes

1. Hazard Classification (changed from hazard determination)

2. Labels3. Safety Data Sheets (changed

from (M)SDS)4. Information and Training

Will affect nearly 40 million workers and 5 million workplaces.5

4

Haz Com Revisions

Benefits:• Improved worker comprehension =

appropriate handling and use of chemicals• Improved access to information• Harmonized classification of health and

physical hazards• Specific elements for labeling and

SDS• Reduced burden on overseas exports/imports

6

7

Effective Completion

DateRequirements Who

Dec 1, 2013 Train employees on new labels and Safety Data Sheet format

Employers

June 1, 2015

December 1, 2015

June 1, 2016

Compliance with modified provisions of final rule except:

Distributors shall not ship containers labeled unless it is a GHS label

Update workplace labeling and HAZCOM program. Additional employee training on newly found physical or health hazards

Chemical manufacturers, importers, distributors & employers

Employers

Transition period

May comply with final HAZCOM std. or current std., or both

Chemical manufacturers, importers, distributors & employers

A significant portion of the standard pertains only to chemical manufacturers, importers, and distributors

Employers who do not produce chemicals only have to focus on establishing a workplace program and communicating information to their workers

Chemical Manufacturers

Employers are required to provide information to their employees about the hazardous chemicals to which they are exposed using: A hazard communication program labels and other forms of warnings (material) safety data sheets ((M)SDS) information and training

Employers

Employers must develop a written program that covers at least: Labels and other forms of warnings

(Material) Safety Data Sheets

Employee Information and Training

Employer Requirements – Written Program

Employers must develop a written program that covers at least: A list of the hazardous chemicals known to be present at the facility

along with (M)SDS’s for each chemical

The methods the employer will use to inform employees of the hazards non-routine tasks

The hazards of chemicals in unlabeled pipes

Written Program

Labels on shipped containersRequired Elements on shipped containers

Product identifierSignal words Hazard statements Pictograms Precautionary statements Name, address, and telephone number of the

chemical manufacturer, importer, or other responsible party

A new Appendix C, Allocation of Label Elements, has been provided to indicate the label requirements by hazard class and category

Labels are to be updated within 6 months of getting new and significant information about the hazards, or ways to protect those exposed

The employer must ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: The label information on the shipped container, or Product identifier and words, pictures, symbols, or

combination providing general information on the hazards of chemicals

Labels must be legible, in English, and prominently displayed on the container or readily available in the work area

Workplace Labeling

Labels, Tags, and Markings

The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use by the employee who performs the transfer

Container Labeling Exemption for Portable Containers

Example of Simple Label

Example of Complex Label

Labels

OSHA is maintaining the current approach to allowing alternatives to labels on each stationary process container

The exception for portable containers under the control of the person who filled them with the chemical remains the same.

Labels on incoming containers are not to be removed or defaced unless immediately replaced by another label

Workplace labels are to be prominently displayed and in English, although other languages are permitted as well

Pictograms

Labels

Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, drums, and for training their employees on the hazards listed on the labels in the workplace.

Labels must continue to be: legible contain the pertinent information (such as the hazards and

directions for use) not able to be defaced, (i.e., fade, get washed off,) or

removed in any way

(Material) Safety Data Sheets ((M)SDS)are one of the most important tools available to employers for providing information, and protectionto workers from hazardous chemicalswhich are used in the workplace.

Safety Data Sheets (SDS)

Safety Data Sheets (SDS)Identifies chemicals by nameTells potential harm and how

chemicals will enter the body (Inhalation, ingestion, and/or skin absorption)

Explains signs and symptoms of exposures

Explains emergency procedures

Safety Data Sheets (SDS)

The GHS uses a specified order of information, as well as title descriptions, on the 16-section safety data sheet.

Health, physical and environmental hazard criteria for substances and for classification of mixtures.

Consistent with voluntary industry consensus standards, such as ANSI.

Should improve comprehensibility and issues regarding accuracy of information.

Safety Data Sheet Format

1. Identification of the substance or mixture and of the supplier

2. Hazards identification3. Composition/

information on ingredients

4. First-aid measures 5. Fire-fighting

measures6. Accidental release

measures7. Handling and storage8. Exposure

controls/personal protection

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological information

12. Ecological information13. Disposal considerations 14. Transport information 15. Regulatory information 16.Other information,

including date of preparation or last revision  

Safety Data Sheets (SDS)

SDS in the workplace for each hazardous chemical

Readily accessible during each work shift to employees when they are in their work area(s)

Employers must provide employees information and training on hazardous chemicals in their work area: At the time of their initial assignment

Whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area

Training may cover categories of hazards

Employee Information and Training

Employee Training

OSHA standard coveredOperations in their work area where chemical is

usedPictogramsLocation of program, list of chemical, and SDS

Detection of chemicalHazards of chemicalProtection measuresEmergency

proceduresLabeling system used

Employee Training

Although this paragraph remains essentially the same, updates includeTraining to include label elements and new

safety data sheet format - by December 1, 2013

Training to reflect any new hazards identified in the workplace - by June 1, 2016

Training – prescribed label elements and order of information on data sheets facilitate training/comprehensibility.

Temporary Employees

Worksite Specific HazCom Training Chemicals in use Methods of detection and

prevention Emergency procedures

Written HazCom Program

Generic HazCom Training How to read SDS Labeling requirements Pictograms Elements of HazCom

Standard SDS maintenance Workplace labeling