Developing a Hazardous Chemical Communication Program

by Dr. Isabel Perry, “The Safety Doctor”

848 Words

It is estimated that there are almost 700,000 chemical products in existence today, and hundreds more are developed every year. Almost 32 million Americans work with and are potentially exposed to chemical hazards.  Because of the potentially serious consequences, the Occupational Safety and Health Administration (OSHA) has issued The Hazardous Waste Communication Standard.  Its purpose is to ensure that employers and employees know about the hazards and how to protect themselves.  OSHA believes that this knowledge will help reduce the number of accidents and injuries caused by hazardous chemicals.

Exposure to hazardous chemicals may cause or contribute to many serious health ailments, including, but not limited to heart ailments, cancer, damage to the central nervous system, kidney and lung damage, sterility, burns and rashes.  Some chemicals also have the potential to cause fires and explosions.

All chemicals, whether imported or produced in the US , fall under uniform requirements and are evaluated.  The information is then provided to employers and the employees exposed to the chemicals.    

Many, but not all, states have OSHA-approved state safety and health plans.  These plans must be at least as stringent as the federal regulations, and must be enforced by state agencies must enforce their plans.

The Hazardous Communication Standard covers all chemicals.  This is not true of the OSHA health rules.  These rules state that the companies that produce chemicals have the primary responsibility for providing information.  Employers must then obtain the information and provide it to their employees.

The main steps are:

¨      Assign an individual the responsibility for carrying out the program.  That individual must be given a copy of the Hazardous Communication Standard. This can be obtained by contacting the OSHA Publications office in Washington , D.C. , one of the ten regional OSHA offices or an area office in your state.  Information is also available on the OSHA website (www.osha.gov), and can be found at the local university library.

¨      After studying the standard, write a Hazardous Communication Program.  The program must include:

o       Designation of an individual responsible for carrying out the various aspects of the program

o       A list of hazardous chemicals in each work area and the location of MSDSs

o       Procedures for obtaining and maintaining MSDSs

o       Procedures for container labeling and maintenance of the labeling system

o       Description of the employee training program 

o       Procedures for notifying contractors about hazardous chemicals

¨      Next, a list must be made of all hazardous chemicals or raw materials present or in use at a facility.  This needs to be a comprehensive list of every chemical and raw material, (even if used only occasionally), including any on order at the time of the inventory.  This list needs to be updated whenever new or different chemicals are brought to the worksite.

¨      Once a list is compiled, there are some chemicals that aren’t included in the Standard:

o       Pesticides

o       Food

o       Food additives

o       Drugs

o       Cosmetics

o       Medical or veterinary products

o       Alcoholic beverages (distilled spirits) not intended for industrial use

o       Wine, beer

o       Consumer products

¨      Manufacturers, suppliers and distributors of hazardous chemicals are required to provide a MSDS for each hazardous chemical.  If there are chemicals on site for which there are no MSDSs, one must be requested.  The manufacturer decides whether a material is hazardous or not and put that information on the MSDS. 

¨      One person should be assigned to update the chemical inventory periodically and obtain MSDSs for item on the list.

¨      MSDSs should be readily available to all employees.  They must be able to be provided the same day, and on the same shift they are requested.

¨      Once the chemicals have been identified, their containers must be labeled in English.  The label must contain:

o       the name of the hazardous material

o       a warning such as (corrosive, flammable, etc)

o       the name and address of the manufacturer

¨      Employees must not remove the labels or damage them

¨      If the company uses portable containers to move chemicals, they may not need to be labeled.  Containers that are filled and used during a shift don’t need to be labeled.

¨      Although pipes and piping systems don’t need to be labeled, employees must be informed of the hazardous chemicals contained in the pipes.

¨      Containers that have a fixed process, like reactor vessels or degreasers, may have a sign with written instructions in the immediate area.

¨      Employers must train and inform employees and contractors about the hazardous chemicals and the protective measures to be taken.  Someone with knowledge of the Hazardous Communication Standard and the hazards of all chemicals at that facility should give the training.

¨      Employees need training when they are new, when new chemicals are brought into the area, when they move to a different area, and also periodically to keep safety uppermost in their minds.

Make sure that management and employees know about chemical hazards on the job and how to protect themselves.  This knowledge will help reduce the number of accidents and injuries caused by hazardous chemicals and contribute to a safer working environment for everyone!

Dr. Isabel Perry is an internationally-known safety expert, motivational speaker, author, and safety educator.  Based in Orlando , Florida , she can be reached at 407-291-1209 or via e-mail at [email protected]