Hazardous Chemicals in the Workplace

This standard requires a list of hazardous chemicals in the workplace as part of the written hazard communication program. This list will eventually serve as an inventory of everything for which an MSDS must be maintained. At this point, however, preparing the list will help you complete the rest of the program since it will give you some idea of the scope of the program required for compliance in your facility. 

The best way to prepare a comprehensive list is to survey the workplace. Purchasing records may also help, and certainly employers should establish procedures to ensure that in the future purchasing procedures result in MSDSs being received before a material is nsed in the workplace. 

The broadest possible perspective shonld be taken when condncting the survey. Sometimes people think of chemicals as only liqnids in containers. The HCS covers chemicals in all physical forms—liquids, solids, gases, vapors, fumes, and mists— whether they are contained or not. The hazardous nature of the chemical and the potential for exposnre are the factors that determine whether a chemical is covered. If it is not hazardons, it is not covered. If there is no potential for exposure (e.g., the chemical is inextricably bonnd and cannot be released), the rnle does not cover the chemical. 

Look around. Identify chemicals in containers, inclnding pipes, bnt also think about chemicals generated in the work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Read labels provided by suppliers for hazard information. Make a list of all chemicals in the workplace that are potentially hazardous. For your own information and planning, you may also want to note on the list the location(s) of the products within the workplace and an indication of the hazards as found on the label. This will help you as you prepare the rest of your program. 

Paragraph (b) of the standard, scope and application, includes exemptions for various chanicals or workplace situations. After compiling the complete list of chemicals, you should review paragraph (b) to determine if any of the items can be eliminated from the list because they are exanpted materials. For example, food, drugs, and cosmetics brought into the workplace for employee consumption are exempt. Therefore, rubbing alcohol in the first-aid kit would not be covered. 

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Lewis, R.J. (2000) Rapid Guide to Hazardous Chemicals in the Workplace, Wiley, Chichester. 

Amherst, NH 03031-0668 Monitors chemical inventories and locales (603) 672-7230 hazardous chemicals in the workplace. Emergency... 

A survey is made of French and European Union legislation relating to hazardous chemicals in the workplace, and particular attention is paid to regulations concerning exposure to chemicals in the rubber industiy. The carcinogenicity of nitrosamines formed during vulcanisation processes is examined, and methods used in their detection are discussed. 2 refs. 

Following a series of very serious chemical accidents in the 1980s, OSHA began to develop the PSM Standard. The proposed standard was published in 1990, the same year that Congress enacted the Clean Air Act Amendments (CAAA). Section 304 of CAAA required OSHA to promulgate a chemical process safety standard to protect employees from hazards associated with accidental releases of highly hazardous chemicals in the workplace. It further required that OSHA develop and apply the standard to a list of... 

OSHA PSM-covered facilities are required to investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical in the workplace (29 CFR 1910.119 [m] [1]). At the conclusion of an incident investigation, the company is required to prepare a report on the factors that contributed to the incident. At present, OSHA does not require submittal of these incident reports. However, mandatory submission of the reports would increase available data and thus improve the capability of identifying or tracking reactive incidents. 

All employers are required to develop, implement, and maintain at the workplace a written hazard communication program. The program must include the following components (1) a list of hazardous chemicals in the workplace, (2) the methods the employer will use to inform employees of the hazards associated with these chemicals, and (3) a description of how the labeling, material safety data sheet (MSDS), and employee training requirements will be met. 

The following information must be included in the program for employers who produce, use, or store hazardous chemicals in the workplace (1) the means by which MSDSs will be made available to outside contractors for each hazardous chemical, (2) the means by which the employer will inform outside contractors of precautions necessary to protect the contractor s employees both during normal operating conditions and in foreseeable emergencies, and (3) the methods that the employer will use to inform contractors of the labeling system used in the workplace. 

The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of a highly hazardous chemical in the workplace. [1]... 

The HCS, also known as the Employee Right-to-Know Law, is basically concerned with the exposure of workers to hazardous chemicals in the workplace. Under this standard, since 1986, all manufacturers, importers, and distributors of hazardous chemicals have had to label the containers they ship, listing the ingredients and hazards of the material in the containers, and provide Material Safety Data Sheets (MSDSs) to all downstream users, handlers, and storers of these chemicals. 

More detailed information may also be provided to those exposed to hazardous chemicals. In the workplace, for example, material safety data sheets (MSDSs) may be available. In the transport sector, a document such as the North American Emergency Response Guidebook may supplement the information on placards or markings. The details on these information documents vary from system to system for the same chemical. 

In the Act, the Congress directed the Secretary of Labor to pursue to inform employees to prescribe the use of labels or other appropriate forms of warning (Section 6(b)(7)). Resijonsibility for the implementation of the Act was delegated to the newly-formed Occupational Safety and Health Administration (OSHA) under the Department of Labor. OSHA s involvement in the generic approach to insure that employees are apprised of all hazards to which they are exposed (Section 6(b)(7)) and to identify all toxic and hazardous chemicals in the workplace, formally began in 1974. 

The standard requires that the employer ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the identity of the hazardous chemical(s) and the hazard warnings. 

The employer must maintain copies of the required MSDS for each hazardous chemical in the workplace, and shall ensure that they are readily accessible to employees exposed to the hazardous chemicals. 

The employer shall provide employees with information and training on hazardous chemicals in the workplace at the time of their initial assignment, and whenever a new hazardous chemical is introduced into their work area. 

The National Institute of Occupational Safety and Health (Istituto Superiore per la Prevenzione e la Sicurezza del Lavoro - ISPESL). The Institute is one of the technical-scientific bodies of the National Health Sa ce under the Ministry of Health and it operates on all occupational safety and health matters. In addition to the role of the National Advisory Committee on Toxicology in this reject (see below), the task of proposing exposure limits is addressed by ISPESL, which relies on recommendations by the ILO or EC directives that adxlress occupational exposure to carcinogens and other hazardous chemicals in the workplace. 

R. J. Lewis, Rapid guide to hazardous chemicals in the workplace [6-31]... 

Section 4.1 consolidates the requirements for general employee information and training on hazardous chemicals in the workplace such as the location, availability and content of material safety data sheets (MSDSs) for the chemicals and chemical products being used or stored, methods to detect the presence of hazardous chemicals, personal protective measures, the details of the workplace hazard communications program, etc. 

For employers using hazardous chemicals, the most important aspect of the written program in terms of MSDSs is to ensure that someone is responsible for obtaining and maintaining the MSDSs for every hazardous chemical in the workplace. The list of hazardous chemicals required to be maintained as part of the written program will serve as an inventory. As new chemicals are purchased, the list should be updated. Many companies have found it convenient to include on their purchase orders the name and address of the person designated in their company to receive MSDS. 

Means to reduce or eliminate the exposure of the employee to the risks associated with the hazardous chemicals in the workplace. This should include work practices that will reduce the exposures or the use of personal protective equipment. 

The HCS applies to any hazardous chemical in the workplace that employees can be exposed to under normal conditions of use or in a foreseeable emergency. 

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