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Protecting Employees from Workplace HazardsOSHA Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories
Introduction Presenter - Colleen Cunanan, AKOSH
Industrial Hygienist
Purpose – familiarize you with OSHA’s Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories Standards [CFR 1910.1200 & 1910.1450]
Overview Hazard Communication Standard (HCS)
2012 standard revision to incorporate the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
Requirements of the standard
Occupational Exposure to Hazardous Chemicals in Laboratories Standard (Lab Standard) Requirements of the standard
Comparison of the Lab Standard to HCS
OSHA’s Hazard Communication Standard29 CFR 1910.1200
What is Hazard Communication? OSHA Hazard Communication Standard 29
CFR 1910.1200 – “Right to Know” went into effect in November 1985
The purpose of Hazcom is to communicate workplace chemical hazards and appropriate protective measures to employees
Employees have a Right to Know about the hazards in their work areas and the potential effects of these hazards upon their health and safety
What is Global Harmonization? A common and coherent approach to
defining and classifying hazards, and communicating information on labels and safety data sheets
Provides the underlying infrastructure for establishing a national, comprehensive chemical safety program
How will Global Harmonization help? Improve comprehensiveness
Improve consistency
Improve understanding
Changes to HCS Hazard Classification
Labels
Safety Data Sheets
Timeline for ComplianceEffective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and safety data sheet
(SDS) format.
Employers
June 1, 2015*
December 1, 2015
Compliance with all modified provisions of this final rule,
except:The Distributor shall not ship
containers labeled by the chemical manufacturer or
importer unless it is a GHS label
Chemical manufacturers, importers, distributors and
employers
June 1, 2016 Update alternative workplace labeling and hazard
communication program as necessary, and provide additional
employee training for newly identified physical or health
hazards.
Employers
Transition Period to the effective completion dates noted above
May comply with either 29 CFR 1910.1200 (the final standard), or
the current standard, or both
Chemical manufacturers, importers, distributors, and
employers
Key Elements of the Hazard Communication Standard (HCS) Written Program – must be developed and tie
all the following elements together
Training - all employees must be trained to identify and work safely with hazardous materials
Labeling - containers of hazardous materials must have labels which identify the material and warn of its potential hazard to employees
Safety Data Sheets (SDSs) - detailed description of each hazardous material present in the workplace
HCS Written Program Information and training the employee will
receive regarding workplace hazards Labeling and other forms of warning utilized in
the workplace Maintenance of SDSs for every chemical Chemical inventory Methods the employer uses to inform employees
of hazards of non-routine tasks and hazards of chemicals in unlabeled pipes in work areas
Methods of communicating hazards to other employers (contractors)
Additional Alaska Requirements Chemical inventory with locations
Physical Agent Data Sheets (PADs)
Table Z-1-AExample - Acetone
Fed PEL – TWA 1000 ppm AK PEL – TWA 750 ppm, STEL 1000 ppm
HCS Training RequirementsEmployee training is an integral part of the hazard communication program and must be provided:
At the time of initial assignment Whenever a new hazard is introduced into the workplace, and When employees may be exposed to other employers’
workplace hazards
Hazard Communication – Site specific training Details of employer’s Hazcom program Specific hazards in the workplace Methods to detect presence or release of a hazardous
chemical Methods to reduce hazards - product substitution, engineering
controls, administrative controls, and personal protective equipment
Training – Non-routine TasksPrior to starting work on such projects, affected employees will be given information on hazards to which they may be exposed during such activity
This information will cover:Specific hazardsMeasures the employer has taken to reduce the risk of these hazardsRequired protective/safety measures
Labels Warn of potential hazards
Not intended to be the only source of information
Serve as an immediate warning
What must be labeled? The OSHA Hazard Communication
Standard requires that ALL hazardous materials be labeled. Labels must appear either on the container itself, a batch ticket, placard, or process sheets
Hazardous chemicals in portable containers which are for the immediate use of the employee who performs the transfer is the exception to this rule
Manufacturer/Importer Label Requirements Product identifier Signal word Hazard statement Pictograms Precautionary statements Name, address, and phone number of
responsible party
GHS Pictograms and HazardsHealth Hazard Flame Exclamation
Mark
• Carcinogen• Mutagenicity• Reproductive Toxicity• Respiratory Sensitizer• Target Organ Toxicity• Aspiration Toxicity
• Flammables• Pyrophorics• Self-Heating• Emits Flammable Gas• Self-Reactives• Organic Peroxides
• Irritant (skin and eye)• Skin Sensitizer• Acute Toxicity (harmful)• Narcotic Effects• Respiratory Tract Irritant• Hazardous to Ozone Layer(Non Mandatory)
GHS Pictograms and HazardsGas Cylinder Corrosion Exploding Bomb
• Gases under Pressure
• Skin Corrosion/ burns• Eye Damage• Corrosive to Metals
• Explosives• Self-Reactives• Organic Peroxides
GHS Pictograms and HazardsFlame Over
CircleSkull &
CrossbonesEnvironment
(Non-mandatory)
• Oxidizers • Acute Toxicity (fatal or toxic)
• Aquatic Toxicity
GHS Compliant Label
Workplace Labeling Standard is “performance based” –
allows flexibility in labeling system Employers may use NFPA, HMIS, or
duplicate the shipped label (GHS)
Workplace LabelingMust include:
Product identifier – must match SDS and chemical inventory
Words, pictures, symbols or combination of these that will provide employees with specific information regarding the physical and health hazards
Workplace LabelingEnsure labels are not removed, defaced, or unreadable
For hard to label containers use:
Signs or placards Process sheets or
batch tickets
Safety Data Sheets (SDSs) Formerly referred to as Material Safety Data Sheets
(MSDSs)
SDSs provide detailed health and safety information and precautions for handling hazardous substances, including emergency and first aid procedures
Employer must have a SDS for each hazardous chemical in the workplace and ensure SDSs are accessible to all employees
SDS Requirements
HCS requires a standardized 16 section format1. Identification2. Hazard(s) Identification3. Composition/information on ingredients4. First-aid measures5. Fire-fighting measures6. Accidental release measures7. Handling and storage8. Exposure controls/personal protection
9. Physical and chemical properties10. Stability and reactivity 11. Toxicological information12. Ecological information13. Disposal considerations14. Transport information15. Regulatory information16. Other information
PADs – Alaska Requirement Cold Stress Hand-Arm Vibration Heat Stress Ionizing Radiation Lasers Noise Radio Frequency/Microwave Radiation Ultraviolet Radiation
OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories29 CFR 1910.1450
Key Elements of the Lab Standard Scope – laboratory use of chemicals; supersedes other
subpart Z requirements except: PEL limitations Skin and eye contact prohibition Monitoring/medical surveillance requirements
Written chemical hygiene plan – defines how employees will be protected and exposures will be kept below PELs
Training – all employees must be trained on chemical hazards
Medical consultation and examinations – provided free to employee by licensed physician under certain circumstances
Hazard identification – labels and SDSs
What is “laboratory use” of chemicals?1) Chemical manipulations are carried out on a
“laboratory scale”;2) Multiple chemical procedures or chemicals are
used;3) Procedures involved are not part of a
production process, nor in any way simulate a production process; and
4) “Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals.
Written Chemical Hygiene Plan (CHP)
Must be:Capable of protecting employees from health hazards associated with hazardous chemicals in laboratoryCapable of keeping exposures below PELsReadily available to all employees
Required CHP Elements SOPs for work involving use of hazardous
chemicals Criteria to determine and implement
control measures to reduce employee exposure
Requirement that fume hoods and other protective equipment are functioning properly and measures taken to ensure adequate performance of such equipment
Required CHP Elements Provisions for training and information Procedures requiring prior approval Provisions for medical consultation and
examination Responsible personnel – Chemical
Hygiene Officer Provisions for additional employee
protection when working with particularly hazardous substances
Lab Standard Information and Training Requirements Employees must be apprised of hazards
of chemicals present in their work areas
Must be provided at time of initial assignment and prior to assignment involving new exposure situation
Lab Standard Information and Training RequirementsEmployees must be informed of:
Contents of 1910.1450 and appendices Location of employer’s CHP PELs Signs and symptoms of exposure to
chemicals in the laboratory Location of reference materials such as
SDSs
Lab Standard Information and Training RequirementsEmployee training must include:
Methods and observations that may be used to detect presence or release of hazardous chemical
Physical and health hazards of chemicals in the work area
Measures employees can take to protect themselves such as appropriate work practices, emergency procedures, and personal protective equipment (PPE)
Medical Consultation and Examinations Opportunity shall be provided when:
Signs/symptoms shown Monitoring indicates need An “event” results in likelihood of exposure
Shall be followed by Dr’s written opinion Requires the employer provide info to Dr Shall be:
At no cost to employee Provided by a licensed physician
Hazard Identification Labels on incoming containers shall not
be removed or defaced
SDSs received with incoming shipments of hazardous chemicals must be maintained and be made readily accessible
Hazard IdentificationChemicals developed in lab:If composition is known, employer must determine if it is hazardous and provide appropriate trainingIf composition is unknown (e.g. a byproduct) employer will assume it is hazardous If produced for outside user, employer must comply with HCS – SDS and labeling requirements
Differences from HCS SDS requirements Chemical inventory requirement Lab Standard supersedes other regs Annual review of CHP Medical evaluations Chemical Hygiene Officer Monitoring requirements
Similarities to HCS Same objective
Same definitions
Written program
Training and information requirements
Questions?