The Hazard Communication Standard

It is estimated that some 32 million workers are potentially exposed to approximately 650,000 existing chemicals in the workplace. Chemicals can pose a serious hazard for every employee in a warehouse. Chemical exposure may cause or contribute to many serious health effects such as heart ailments, kidney and lung damage, sterility, cancer, burns, and skin rashes. Some chemicals may also be safety hazards and have the potential to cause fires, explosions, and other serious incidents or injuries. 

The federal regulation, OSHA 1910.1200, was issued in May 1986. Surprisingly, some thirteen years after the passage of this chemical hazard law, many employers continue to misunderstand the need for this program. In addition, some employers have no concept of the hazard communication program and the fact that it applies to every workplace. 

The purpose of the Hazard Communication Standard (HCS) is to create an awareness of hazardous chemicals in the workplace. Also, the law allows for appropriate precautionary measures that workers may take for their personal protection. 

OSHA s HCS program requires chemical manufacturers and importers of chemicals to perform hazard determinations on their products. The hazards associated with their products must be made known to the employers who purchase them through the use of product labels and material safety data sheets. Employers must then develop a hazard communication program to educate employees on how to protect themselves from the hazards associated with the chemicals they handle. 

The flow of information on hazardous chemicals is achieved by way for four distinct components  

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All employees, working with highly hazardous chemicals must understand the safety and health hazards (29CFR1910.1200 - the Hazard Communication Standard) by knowing the properties of the chemicals with which they work, safe operating procedures, work practices, and emergency action. 

Employers must ensure that their workers know the potential hazards of the chemicals they work with, how to protect themselves against those hazards (e.g., safe practices, personal protection equipment, etc.), and what to do in case of an emergency. Accordingly, OSHA has established basic communication requirements under the Hazard Communication Standard to inform workers about chemicals in use in the workplace. Under this standard, chemical makers must meet the following requirements ... 

The mission of the OSHA is to save lives, prevent injuries, and protect the health of employees in the workplace.25 OSHA accomplishes these goals through several regulatory requirements including the hazard communication standard (HCS) and the Hazardous Waste Operations and Emergency Response Worker Protection Standard (HAZWOPER). 

There are OSHA standards designed to protect employees from acute chemical hazards resulting lfom reactive incidents-including fires, explosions, and toxic releases. The Hazard Communication Standard (29 CFR 1910.1200) requires chemical manufacturers to evaluate chemicals produced or handled in their workplace and to communicate the hazards associated with the products they produce via labels and MSDSs. The standard also requires all employers to provide information to employees about the hazardous chemicals to which they could be exposed. The PSM Standard (29 CFR 1910.119) requires employers to prevent or minimize the consequences of catastrophic releases of highly hazardous chemicals, including highly reactive chemicals. 

In the Hazard Communication Standard, OSHA requires that all employees are trained in the hazards of the materials they are working with. This standard also requires that MSDSs be available for all hazardous chemicals at the worksite, accompany all shipments, and be sent to all customers. An... 

Hazard Communication Standard (29 CFR 1910.1200). The hazard communication standard requires that all personnel receive training concerning the types of materials handled in the workplace and the potential hazards associated with handling and use of these materials. In addition, the standard requires that a MSDS for each hazardous material be made available for individual employee reference. The MSDS outlines specific material chemical and physical properties, exposure information, emergency response information, regulatory information, and any other information of significance concerning the material. 

Much of OSHA s early work centered around abating mechanical and electrical hazards in the workplace. Beginning with the Hazard Communication Standard in 1986, however, a larger emphasis was placed on eliminating chronic hazards associated with workers exposure to chemicals, including colorants. 

A great deal of frustration has arisen over the way hazardous chemicals are defined by OSHA. Most people feel more comfortable if there is a specific list of chemicals to which they can refer, but there is no such list provided under the Hazard Communication Standard. In addition, chemicals that were not previously considered hazardous because they are virtually inert or are not harmful to humans by contact with skin are now considered a dust hazard (particularly inorganic, nontoxic, noncombustible dusts that can enter the body via the respiratory system). This is where the regulation of colorants under OSHA occurs via the Hazard Communication Standard. 

All employers, including those in agriculture, are covered by the Hazard Communication Standard as of May 1988. Every farm, ranch or business... 

Farmers, ranchers, and businesses are subject to routine general inspections by OSHA. The first time an inspection shows a business is not complying with the Hazard Communication Standard, OSHA can issue a noncompliance citation and a penalty of up to 1,000. Usually, the business is allowed 15 to 30 days to correct the problem. A business that does not correct the noncompliance(s) may be subject to additional penalties of up to 10,000 per violation. 

The GHS applies to pure chemical substances, their dilute solutions and to mixtures of chemical substances. Articles as defined in the Hazard Communication Standard (29 CFR 1910.1200) of the US Occupational Safety and Health Administration, or by similar definition, are outside the scope of the system. 

The Occupational Safety and Health Administration regulates chlorambucil under the Hazard Communication Standard and as a chemical hazard in laboratories, although there is no specific occupational exposure standard for the chemical. The Food and Drug Administration regulates clinical use of the drug and labeling requirements under the Food, Drug, and Cosmetic Act. 

Inspection Procedures for the Hazard Communication Standard (29 Code of Federal Regulations 1910.1200). United States Department of Labor, Office of Health Compliance Assistance, OSHA Instruction CPL 2-2.38C, October 22, 1990. 

The Hazard Communication Standard under 29 CFR 1910.1200 requires employees to be knowledgeable in the hazards of the stored materials. (See also Chapter 4.)... 

Title 29 OSHA regulations, including the Hazard Communication Standard (HCS) Title 40 EPA regulations Title 49 DOT regulations combustible material The U.S. Department of Transportation (DOT) defines a flammable liquid as having a flash point of 140°F/60°C or above. OSHA s criteria (29CFR1910.106) is a flash point abovel00°F/37.8°C. 

Title 29 OSHA regulations, including the Hazard Communication Standard (HCS) ... 

Risk identification. Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances shall be identified. Employees who will be working on the site shall be informed of any risks that have been identified. In situations covered by the Hazard Communication Standard, 29 CFR 1910.1200, training required by that standard need not be duplicated. 

OSHA regulates polychlorinated biphenyls under the Hazard Communication Standard and as chemical hazards in laboratories. OSHA s PEL on an 8-hour TWA for chlorodiphenyls containing 42% chlorine is 1 mg/m. Its PEL on chlorobiphenyls containing 54% chlorine is 0.5 mg/m. These standards are based on the toxic effects other than cancer. NIOSH recommends the exposure to PCBs be controlled to the lowest feasible concentration. 

Managers of laboratory personnel also ensure that additional provisions for personnel protection are made for those who work with particularly hazardous substances and that work with particularly hazardous substances covered under the OSHA Laboratory Standard is performed in a designated area. They must also ensure that SNL personnel understand and comply with SNL s Chemical Hygiene Plan and 29 CFR 1910.1450 (and its appendices), as well as the additional requirements defined in the "Hazard Communication Standard," and the TSCA for chemicals that are developed in the laboratory or imported into the laboratory. 

The Hazard Commimication Standard reqirires each facility to conduct a hazard assessment for each chenucal in the workplace, maintain an inventory of chemicals in the workplace, retain MSDSs for each chemical in the workplace, properly label each chemical according to a uniform labeling policy, train each employee to understand the MSDSs, product labels, and Hazard Communication Standard, and develop a written program that explains how the Hazard Communication Standard is to be implemented at the facility. 

See the Hazard Communication Standard regulations at 29 C.F.R. 1910.1200, issued under the Occupational Safety and Health Act. for a discussion of Material Safety Data Sheets. 

The Hazard Communication Standard (HAZCOM) is performance-based, not specification-based. Performance-based standards are very flexible. They tell you what you have to accomplish and you decide how to do it. Except for a few minor things like ensuring that shipped containers have labels in English, OSHA doesn t care how you meet the goals of the hazard communication standard as long as you meet them. 

A written hazard communication program is a blueprint which describes how a company will achieve the goals set by the Hazard Communication standard. The program must address six critical items ... 

The main purpose of the MSDS is to make employees fuUy aware of any hazards associated with materials they use or handle, as requested by the Hazard Communication Standard, in compliance with the Occupational Safety and Health Administration s (OSHA) regulations. 

A major and valid justification for OSHA to adopt the laboratory safety standard to supersede the general industry standards and the hazard communication standard for the laboratory environment was thatthe laboratory environment is radically different from industrial facilities and most other types of occupations. The organizational structure for research institutions is not nearly so structured, especially in the academic environment,and operations are different in size and character. The laboratory standard uses this difference as a criterion as to whether the laboratory standard is to be applied to a program. 

The chemical and physical hazards of the chemicals in the workplace. This is almost the same as the basic information on PELs and MSDSs hsted in the previous section. Those requirements basically defined limits of exposure and the sources of data. This requirement provides that the employees be given chemically specific hazard information on the chemicals in their work area. It is most important that the chemicals in actual use are the principal ones for which this information is provided. However, generic hazard information by class for chemicals present but not in use should be provided as well. There is always the potential for an accident involving chemicals not in current use. The employees must be informed that they are not to deface or remove the labels on commercial containers of chemicals, since they represent a primary source of information. It is not required by the standard, but following the requirement from the Hazard Communication Standard 29 CFR 1910.1200, that secondary containers intended for use beyond a single work shift should be labeled, it is highly recommended that this be required. 

A characteristic of many research laboratories is that chemicals may be produced or synthesized in the course of the research. If the composition of the chemical is known and it is a hazardous material, all of the training requirements and other provisions of the standard apply. If the composition is not known, it shall be assumed to be hazardous and, with the exception of the requirements for MSDSs and similar information sources, the provisions of the CHP apply. If the chemical is produced for a user outside the laboratory, the provisions of the Hazard Communication Standard (29 CFR 1910.1200) apply, including the requirement for providing an MSDS and proper labeling of the material. Compliance with these requirements will be the responsibility of the individual laboratory and a commitment to this compliance should be in the laboratory CHP. 

Under the hazard communication standard, chemical manufacturers and importers must obtain or develop a MSDS for each hazardous chemical they produce or import. These MSDSs must reflect the latest scientific data. New information must be added to the MSDS within 3 months after it has become available. The manufacturer or importer must provide an MSDS to a purchaser the first time a given item is purchased and an updated version after the information becomes available. A distributor of chemicals must provide MSDSs to their customers. 

There are two important types of labels in laboratories. The labels on commercial containers are usually extremely comprehensive, providing not only information on the nature, amount, and quality of the product but also a very laige amount of safety-related data. Typically a commercial label will readily meet the requirements of the hazard communication standard. On the other hand, labels placed on secondary containers in the laboratory by employees may be something such as soln. A or even less. This may be sufficient if all of the material is to be promptly used by the individual placing the label on the container, but otherwise it is not. In most instances, secondary containers of hazardous chemicals should be marked with labels identifying the chemical in the container and providing basic hazard warnings. The secondary label should be affixed before the container is put into use. 

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