Hazard Communication 2012 (Employee Right-to-Know)

1. Hazard Communication 2012 (Employee Right-to-Know) AEI Safety Training Program 2013

2. Employee Right-to-Know • Recently updated OSHA’s Hazard Communication Standard (HCS) is based on a simple concept—that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring. OSHA designed the HCS to provide employees with the information they need to know. • The HCS standard’s common name is “Employee Right-to-Know”

3. Alignment with the Globally Harmonized System • The requirements of new HAZCOM standard are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. • The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets (SDS) and employee training.

4. Purpose & Scope • In order to ensure chemical safety in the workplace, information must be available about the identities and hazards of the chemicals. OSHA's Hazard Communication Standard (HCS) requires the development and dissemination of such information: • Chemical manufacturers and importers are required to classify the hazards of the chemicals they produce or import, and • Prepare labels and safety data sheets (SDSs) to convey the hazard information to their downstream customers. • All employers with hazardous chemicals in their workplaces must have labels and SDSs for their exposed workers, and train them to handle the chemicals appropriately.

5. Four Major Elements of the Program • Safety Data Sheets (SDS) and Inventory of Chemicals • Labels • Written Program • Training

6. Implementation • Office Locations: • Implementation of this program is the responsibility of the local management (Unit Manager, Laboratory Manager, Office Manager) • Field Activities: • Implementation of this program is the responsibility of the Project Manager.

7. Hazardous Material Inventory • Maintain a hazardous material inventory that lists all of the hazardous materials used at each workplace (i.e., office/lab/ field location). Use chemical names consistent with the applicable SDS's. • File a copy of the chemical inventory with the Project Safety Plan or with the Health and Safety Coordinator.

8. Safety Data Sheets (SDS's) • Obtain a SDS for each chemical before it is used. • Review each SDS when it is received to evaluate whether the information is complete and to determine if existing protective measures are adequate. • Maintain a collection of all applicable and relevant SDS's where they are accessible at all times. • Replace SDS sheets when updated sheets are received (or at least every 3 years). • Communicate any significant changes to those who work with the chemical. • SDS's are required for all hazardous materials used on site by project personnel.

9. Labels • Unless each container has appropriate labeling, label all chemical containers as described further in this presentation

10. Hazardous Non-routine Tasks • Periodically, employees are required to perform hazardous, non-routine tasks. Prior to starting work on such projects, provide each employee with information about hazards to which they may be exposed during such an activity. • This information will include: • Specific chemical hazards. • Protective/safety measures which must be utilized. • Measures that have been taken to lessen the hazards including ventilation, respirators, presence of another employee and emergency procedures.

11. Informing Contractors/Subcontractors • Provide contractors/subcontractors the following information on chemicals used by or provided to AEI personnel: • Names of hazardous chemicals to which they may be exposed while on the jobsite. • Precautions the employees may take to lessen the possibility of exposure by usage of appropriate protective measures. • Location of SDS’s and written chemical list.

12. HAZCOM Training • Conduct HAZCOM training of all employees potentially exposed to hazardous materials on the following schedule: • Before new employees begin their jobs. • Whenever new chemicals are introduced into the workplace, or • Document both online and site-specific training

13. Content of This Online Training • HAZCOM program • Compliance checklist • Applicable regulatory requirements • Labeling • Chemical list (inventory) • How to read an SDS

14. Content of Site-Specific Training • Names of those responsible for implementing this program. • Unit/Office manager • Lab Manger • Project Manager • HSE Coordinator • Location of the program (in HASP or if in separate document, where it can be found), chemical inventory and SDS's. • Chemicals used locally, their hazards (chemical & physical). • Safe work practices using chemicals.

15. Checklist for Compliance • Obtained a copy of the current OSHA Standard. • Read and understood the requirements. • Assigned responsibility for tasks. • Prepared a list (inventory) of chemicals. • Ensured containers are labeled. • Obtained SDS for each chemical. • Prepared written program (can be included in HASP). • Made SDSs available to all workers. • Conducted training of workers. • Established procedures to maintain current program. • Established procedures to evaluate effectiveness.

16. Checklist for Compliance – 1 & 2 Obtain a copy of the standard. • HSE Coordinators, Unit, Laboratory and Office Managers should print and review a copy of OSHA Hazard Communication Standard 29 CFR 1910.1200 • http://www.osha.gov/dsg/hazcom/ghs-final-rule.html Read and understand the requirements.

17. Checklist for Compliance - 3 • Assign responsibility for tasks at the local level. • Local management (unit manager, office manager, laboratory manager) are responsible for the overall implementation of the hazard communication program • Corporate Safety Department provides coordination, company-wide policy, generic company-wide training, and monitors compliance with the program • Qualified Local HSE Coordinators or designated H&S professionals are responsible for site-specific training • Designated employees are responsible for particular program elements such as chemical inventory development and labeling (should be appointed by the local management)

18. Checklist for Compliance - 4 • Prepare a list (inventory) of chemicals • Date • Location • Chemical name/product name • Quantity • Is it labeled? • Do you have SDS?

19. Prepare an inventory of chemicals • Any hazardous material in any quantity on AEI property or sites will be identified on a list by the HSE Coordinator (for office locations), SHSC (for sites), supervisor (for work areas), or designee. The information on the list includes the substance name (as referenced on the SDS), storage location, and quantity. The inventory may be compiled for the workplace as a whole or for individual work areas. • The inventory will be updated quarterly, or when new chemical is introduced.

20. Checklist for Compliance 5 - Labeling • English. • Do not remove or deface. • Label on shipped containers • Product Identifier • Signal Word • Hazard Statement • Pictogram(s) • Precautionary Statement • Name address and telephone number of the chemical manufacturer, importer, or other responsible party.

21. Label Comparison – Old HCS vs. New GHS

22. Component of New GHS Label

23. Product Identifier • Product identifier: how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. • The same product identifier must be both on the label and in Section 1 of the SDS (Identification).

24. Signal Word • Signal word: used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words, “Danger” and “Warning.” • Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. • There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning,” then only “Danger” should appear on the label.

25. Signal Word Danger Used for more severe hazard categories. A category 1 corrosive which causes serious eye damage would carry the danger signal word. Used for less severe hazard categories. A category 3 flammable liquid and vapor would carry the warning signal word. Warning

26. Pictograms • Pictogram: OSHA’s required pictograms must be in the shape of a square set at a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame set at a point without a hazard symbol is not a pictogram and is not permitted on the label. OSHA has designated eight pictograms under this standard for application to a hazard category. When are pictograms required? ? = Oxidizers

27. Pictogram Definitions

28. Hazard Statement(s) • Hazard statement(s): describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” • All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.

29. Precautionary statement(s) • Precautionary statement(s): means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.

30. Chemical Manufacturer’s Info • Name, address and phone number of the chemical manufacturer, distributor, or importer

31. Portable Container Labeling • Often, laboratory operations require transferring chemicals from the original labeled container into a secondary container (e.g., beaker, flask, or bottle). Portable containers must comply with the labeling requirements listed above if any of the following events occur: • The material is not used within the work shift of the individual who makes the transfer. • The worker who made the transfer leaves the work area. • The container is moved to another work area and is no longer in the possession of the worker who filled the container.

32. Portable Container Labeling • Portable containers allowed without label if: • Intended only for immediate use of employee who performs the transfer “Immediate Use” means the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it was transferred. Container cannot be left unattended for any length of time. SODA ?

33. Labels Remember GHS hazard class 1 is the greatest hazard. GHS class 4 is the lesser hazard. NFPA/HMIS hazard class 4 is the greatest hazard. NFPA/HMIS class 1 is the lesser hazard.

34. Uniform Labels / In House Labels • Pictures may be used to identify hazards or required personal protective equipment. • This information may also be on the manufacturers label.

35. Label Review If there is no label or I cannot read the label what do I do? Stop Read Tell

36. Ensure containers are labeled • Employees and contractors will be informed that they should check all incoming hazardous material container labels for the following information: • identity of product appropriate hazard warning • name and address of chemical manufacturer, importer, or other responsible party • Labels must be legible and prominently displayed. No existing label will be removed or defaced on containers of hazardous materials.

37. NFPA & HMIS Labeling HMIS Both labels must identify the chemical name and hazards. Information available via SDS. Note: On these labels, 4 is greatest hazard! NFPA 704

38. NFPA 704 Hazard Identification System • The National Fire Protection Agency (NFPA), in section 704 of the National Fire Code, specifies a system for identifying the hazards associated with materials. Although the system was developed primarily with the needs of fire protection agencies in mind, it is of value to anyone who needs to handle potentially hazardous material. • The hazard identification signal is a color-coded array of four numbers or letters arranged in a diamond shape. You will see hazard diamonds like this on trucks, storage tanks, bottles of chemicals, and in various other places. The blue, red, and yellow fields (health, flammability, and reactivity) all use a numbering scale ranging from 0 to 4. A value of zero means that the material poses essentially no hazard; a rating of four indicates extreme danger. The fourth value (associated with white) tends to be more variable, both in meaning and in what letters or numbers are written there.

39. NFPA Diamond

40. Checklist for Compliance - 6 • Obtain SDS for each chemical • Manufacturers/suppliers are required by law to provide a copy of SDS for every product • You probably can find your SDS on the Internet • A separate section of this training is dedicated to reading and understanding SDSs

41. Checklist for Compliance – 7, 8 • Prepare written HSC program. • Made SDSs available to all workers. • At AEI written HSC program is included in HSE Volume VI, SOP H-8 Hazard Communication Written Program (this link is to the intranet site and will not work outside of restricted AEI network) • Please note that this program needs to be locally customized at every location to include NAMES of local responsible parties • Written program and SDS should be placed in Right-to-Know Center easily accessible by all employees; • Field HASPs should include a section on HSC and all SDS for all chemicals to be used in the field

42. Checklist for Compliance – 9, 10, 11 • Conduct training of workers. • Establish procedures to maintain current program. • Establish procedures to evaluate effectiveness • The following portion of this training is dedicated to reading and understanding SDS • Please make sure that our HSC program is active, employees are trained, chemicals are labeled, SDS are current and available to all employees and subcontractors • The Corporate Safety Department will continue auditing our programs and making sure they are effective

43. Understanding SDS 2012 for OSHA Hazard Communication Training AEI Training Program 2013

44. Definition • “Safety Data Sheet (SDS)” • Means written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of this section. • Formally called Material Safety Data Sheets.

45. Sample SDS (please click and review) • Sample SDS • Standardized Format • 16 Sections • English • Access • Readily available during work shift • Notebook binder or filing cabinet • Can be electronic • No barriers to immediate employee access • Is there a backup system?

46. SDS Components

47. Understanding SDS • Typical SDS is reviewed • This detailed approach should be used when providing chemical-specific part of the training. Each (M)SDS for ALL products used by every employee should be reviewed and discussed in details • Emergency response planning for incidental exposure, including availability of FA/CPR trained personnel, first aid stations, eye wash stations, emergency showers, and proper storage and use requirements should be included as well as spill response planning

48. Section 1: Identification

49. Section 2: Hazard Identification

50. Section 3: Composition/Information on Ingredients