Hazard Communication (Employee Right-to-Know)

1. Hazard Communication (Employee Right-to-Know) AEE Safety Training Program 2008

2. Employee Right-to-Know • 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. 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 evaluate the hazards of the chemicals they produce or import, and • Prepare labels and material safety data sheets (MSDSs) to convey the hazard information to their downstream customers. • All employers with hazardous chemicals in their workplaces must have labels and MSDSs for their exposed workers, and train them to handle the chemicals appropriately.

4. Four Major Elements of the Program • Material Safety Data Sheets (MSDS) and Inventory of Chemicals • Labels • Written Program • Training

5. 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.

6. 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 MSDS's. • File a copy of the chemical inventory with the Project Safety Plan or with the Health and Safety Coordinator.

7. Material Safety Data Sheets (MSDS's) • Obtain a MSDS for each chemical before it is used. • Review each MSDS 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 MSDS's where they are accessible at all times. • Replace MSDS sheets when updated sheets are received (or at least every 3 years). • Communicate any significant changes to those who work with the chemical. • MSDS's are required for all hazardous materials used on site by project personnel.

8. Labels • Unless each container has appropriate labeling, label all chemical containers with: • Identity of the hazardous chemical(s), • Appropriate hazard warnings, and • Name and address of the chemical manufacturer, importer, or other responsible party.

9. 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.

10. Informing Contractors/Subcontractors • Provide contractors/subcontractors the following information on chemicals used by or provided to AEE 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 MSDS’s and written chemical inventory.

11. HAZCOM Training • Conduct 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 • Annually thereafter. • Document both online and site-specific training

12. Content of This Online Training • HAZCOM program • Compliance checklist • Applicable regulatory requirements • Labeling • Chemical inventory • How to read an MSDS

13. Content of Site-Specific Training • Names of those responsible for implementing this program. • Unit manager • Lab Manger • Project Manager • SHE Coordinator • Location of the program, chemical inventory and MSDS's. • Chemicals used locally, their hazards (chemical & physical). • Safe work practices using chemicals.

14. Checklist for Compliance • Obtained a copy of the OSHA Standard. • Read and understood the requirements. • Assigned responsibility for tasks. • Prepared an inventory of chemicals. • Ensured containers are labeled. • Obtained MSDS for each chemical. • Prepared written program. • Made MSDSs available to all workers. • Conducted training of workers. • Established procedures to maintain current program. • Established procedures to evaluate effectiveness.

15. Checklist for Compliance – 1 & 2 Obtain a copy of the standard. • Safety Coordinators, Unit, Laboratory and Office Managers should print and review a copy of OSHA Hazard Communication Standard 29 CFR 1910.1200 • 1910.1200, Hazard communication • Appendix A, Health hazard definitions (Mandatory) • Appendix B, Hazard determination (Mandatory) • Appendix C, Information sources (Advisory) • Appendix D, Definition of "trade secret" (Mandatory) • Appendix E, Guidelines for employer compliance (Advisory) • OSHA Document 3111 (2000) Hazard Communication Guidelines for Compliance http://osha.gov/Publications/osha3111.pdf • GUIDANCE FORHAZARD DETERMINATION FOR COMPLIANCE WITH THEOSHA HAZARD COMMUNICATION STANDARD (29 CFR 1910.1200)http://osha.gov/dsg/hazcom/ghd053107.html Read and understand the requirements.

16. 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 Safety Coordinators or designated H&S professionals are responsible for local implementation of the program and 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)

17. Checklist for Compliance - 4 • Prepare an inventory of chemicals • Date • Location • Chemical name/product name • Quantity • Is it labeled? • Do you have MSDS?

18. Prepare an inventory of chemicals • Any hazardous material in any quantity on AEE property or sites will be identified on a list by the SHE 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 MSDS), 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 more frequently, as necessary.

19. Checklist for Compliance - 5 • Ensure containers are labeled • "... the employer shall ensure that each container of hazardous chemicals in the work place is labeled, tagged or marked with... (i) Identity of the hazardous chemicals...and (ii) Appropriate hazard warnings, or alternatively, words, pictures, symbols or combination thereof,...to...provide the employees with the specific information regarding the physical and health hazards of the hazardous chemicals."

20. Example of acceptable label ISOPROPYL ALCOHOL (2 - Propanol) FLAMMABLE LIQUID ABC Chemical Co. 123 Main St. City, State Zip

21. 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.

22. 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.

23. NFPA Diamond

24. HMIG -- Hazardous Material Identification GuideHMIS -- Hazardous Material Information System • The OSHA Hazard Communication Standard (HCS) requires all chemicals in the workplace to be labeled in a manner that warns of any hazards the chemical may present. The actual format and method of labeling is not specified, so there are several different formats in use. The NFPA hazard diamond is one such method. Two other HCS compliance systems that are very similar to one another are described here. • The Hazardous Material Identification Guide (HMIG) is a labeling system developed and sold through Lab Safety Supply Inc. The Hazardous Material Information System (HMIS) is a labeling system developed by the National Paint and Coatings Association (NPCA) and sold through Labelmaster Inc. Both systems use a label with four color bars and a space at the top where the name of the chemical should be written (see figure this page). The blue, red, and yellow colored bars indicate, respectively, the health, flammability, and reactivity hazard associated with the material. These three bars 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. Although the details of how numbers are assigned may vary somewhat between systems, this is essentially the same overall scheme as is used in the NFPA system. (But see also the note on differences between NFPA and HMIG.) The fourth, white bar is marked "protective equipment" in the HMIG system, and "personal protection" in the HMIS system. Both systems (HMIG and HMIS) place a letter in this bar to indicate the kind(s) of personal protective equipment (PPE) that should be used in order to handle the material safely. The letters used are A - K and X. Meanings of the letters are the same in both systems, and both systems augment the letter code with icons or pictograms showing the kinds of PPE to be used. • A significant difference between the HMIG and HMIS systems is that the 1995 revised HMIS system includes a second box on the blue (health hazard) bar. If this second box holds an asterisk (*), then the health hazard associated with the material is a chronic (long-term) effect.

25. HMIG Labels

26. HMIG Label

27. Similarities and Differences between NFPA and HMIS • Both the NFPA Hazard Identification System and the Hazardous Material Identification Guide (HMIG or HMIS) may be used to comply with the labeling requirement of the OSHA Hazard Communication Standard (HCS). These systems, although similar, differ in some important respects. • Similarities • Both systems have three color-coded fields to indicate the flammability (red), health (blue), and reactivity (yellow) hazards associated with the material. • Both use a system of five numbers, ranging from 0 to 4, to indicate the severity of hazard, with 0 being the least and 4 being the most hazardous. • Differences • They differ in layout -- NFPA uses four diamonds, HMIG uses vertically stacked bars. • The differ in interpretation of the fourth, white field (special handling in the NFPA system; protective equipment in the HMIG system). • Possibly the most significant difference, however, has to do with the intended audience for each of the systems. The HMIG (or HMIS) was devised as an HCS compliance tool, and has employees who must handle hazardous chemicals in the workplace as the intended audience. The NFPA system was designed to alert fire fighters arriving on the scene of a fire to the hazards associated with materials present at that location. Therefore, the numbers assigned in the NFPA system assume that a fire is present. No such assumption holds in the HMIG/HMIS system. For this reason, the numbers that are assigned to the flammability, health, and reactivity hazards may differ between the NFPA and HMIG systems, even for the exact same chemical.

28. NFPA and HMIG Labels • NFPA and HMIG labels can be obtained, for example, from • http://www.labsafety.com/store/Signs_-_Labels_-_Tapes/Labels/RTK_-_Chemical_Labels/60373/ or • http://www.shippinglabels.com/RTK/chemical_labels.asp • or generated internally

29. Write On HMIG Labels Can be Obtained from Labsafety.com Use HMIG Write-On Labels to identify hazard ratings quickly and easily on containers in your workplace. Two sizes of self-adhesive paper Labels help you warn workers about dangers. Small Labels have room for you to write in the chemical name, manufacturer, date and rating. Large Labels allow you to add all the same information as the Small Labels plus room for the common name. Roll of 1000. http://www.labsafety.com/store/Signs_-_Labels_-_Tapes/Labels/RTK_-_Chemical_Labels/60373/

30. Checklist for Compliance - 6 • Obtain MSDS for each chemical • Manufacturers/suppliers are required by law to provide a copy of MSDS for every product • You probably can find your MSDS on the Internet • All MSDSs in your inventory should be less then three years old • A separate section of this training is dedicated to reading and understanding MSDSs

31. Checklist for Compliance – 7, 8 • Prepare written HSC program. • Made MSDSs available to all workers. • At AEE written HSC program is included in SHE Volume VI, SOP H-8 Hazard Communication Written Program (this link is to the intranet site and will not work outside of restricted AEE network) • Please note that this program needs to be locally customized at every location to include NAMES of local responsible parties • Written program and MSDS should be placed in Right-to-Know Center easily accessible by all employees; various options for RTK Centers are listed here http://www.labsafety.com/store/Signs_-_Labels_-_Tapes/Right-to-Know_-_RTK/RTK_Information_Stations/ • Field HASPs should include a section on HSC and all MSDS for all chemicals to be used in the field

32. 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 MSDS • Please make sure that our HSC program is active, employees are trained, chemicals are labeled, MSDS are current and available to all employees and subcontractors • The Corporate Safety Department will continue auditing our programs and making sure they are effective

33. Understanding MSDS for OSHA Hazard Communication and WHMIS Training AEE Training Program 2008

34. Understanding MSDS • The information provided in this presentation supplements Canadian WHMIS and the US Hazard Communication training • Typical MSDS is reviewed using acetone as an example • This detailed approach should be used when providing chemical-specific part of the training. Each MSDS 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

35. OSHA Recommended Format for Material Safety Data Sheets (MSDSs) • In 1985, US Occupational Safety & health Administration (OSHA) established a voluntary format for MSDSs (OSHA Form 174) to assist manufacturers and importers who desired guidance on organizing MSDS information. • When completed correctly, an MSDS prepared using Form 174 contains all of the information required by OSHA Hazard Communication Standard (29CFR1910.1200). • However, Form 174 does not use the more organized and comprehensive 16-section format. • …more from http://www.osha.gov/dsg/hazcom/msdsformat.html

36. Minimum MSDS Content – Form 174 • Identity • Hazardous Ingredients • Physical/Chemical Characteristics • Fire and Explosion Hazard Data • Reactivity Data • Health Hazard Data • Precautions for Safe Handling and Use • Control Measures

37. OSHA Form 174 – Sections 1, 2

38. OSHA Form 174 – Section 3, 4, 5

39. OSHA Form 174 – Section 6

40. OSHA Form 174 – Section 7, 8

41. ANSI 16-section MSDS Format • OSHA believes that use of a consistent format will improve the effectiveness of MSDSs by making information easier for the reader to find, regardless of the supplier of the MSDS. • Because the 16-section format is accepted by consensus as the most appropriate format, OSHA no longer endorses that Form 174 be used for the preparation of MSDSs. • Use of Form 174, however, is still acceptable under the HCS if it is completed correctly.

42. ANSI 16-section MSDS Format • In order to promote consistent presentation of information, OSHA now recommends that MSDSs follow the 16-section format established by the American National Standards Institute (ANSI) standard for preparation of MSDSs (Z400.1). • By following this recommended format, the information of greatest concern to workers is featured at the beginning of the data sheet, including information on chemical composition and first aid measures. • More technical information that addresses topics such as the physical and chemical properties of the material and toxicological data appears later in the document. • While some of this information (such as ecological information) is not required by the OSHA Hazard Communication Standard (HCS), the 16-section MSDS is becoming the international norm.

43. ANSI 16-section MSDS Format • Manufacturer and supplier identification, Contact information • Hazard(s) identification • Composition/information on ingredients • First-aid measures • Fire-fighting measures • Accidental release measures • Handling and storage • Exposure controls/personal protection • Physical and chemical properties • Stability and reactivity • Toxicological information • Ecological information • Disposal considerations • Transport information • Regulatory information • Other information

44. Section 1: Chemical Product and Company Identification • This section links the chemical name on the label to the MSDS. The MSDS also lists the name, address and the phone number of the company, manufacturer or distributor who provides the chemical. • Example: Acetone • Product Identification • Synonyms: Dimethylketone; 2-propanone; dimethylketal CAS No.: 67-64-1 Molecular Weight: 58.08 Chemical Formula: (CH3)2CO Product Codes:J.T. Baker: 5008, 5018, 5356, 5580, 5965, 5975, 9001, 9002, 9003, 9004, 9005, 9006, 9007, 9008, 9009, 9010, 9015, 9024, 9036, 9125, 9254, 9271, A134, V655 Mallinckrodt: 0018, 2432, 2435, 2437, 2438, 2440, 2443, 2850, H451, H580, H981

45. Section 2: Composition/Information on Ingredients • This section must identify all the hazardous ingredients of the material. For example, • Ingredient - Acetone • CAS 67-64-1 • Percent 99 - 100% • Hazardous – Yes

46. Section 2: Composition/Information on Ingredients • MSDS should list the chemical components as follows (1910.1200(g)(2)(i)(C)(1)): • The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except that chemicals identified as carcinogens shall be listed if the concentrations are 0.1% or greater

47. Section 3: Hazards Identification • This section discusses the health and safety hazards of the product. The section may include safety ratings of the material, safe storage guidelines, PPE recommended to handle the material, and potential health effects by the route of entry

48. Section 3: Hazards Identification • Emergency Overview • DANGER! EXTREMELY FLAMMABLE LIQUID AND VAPOR. VAPOR MAY CAUSE FLASH FIRE. HARMFUL IF SWALLOWED OR INHALED. CAUSES IRRITATION TO SKIN, EYES AND RESPIRATORY TRACT. AFFECTS CENTRAL NERVOUS SYSTEM.NFPA Ratings • Health Rating: 2 – Moderate • Flammability Rating: 3 - Severe (Flammable) • Reactivity Rating: 0 - None • Contact Rating: 3 - Severe • Lab Protective Equip: GOGGLES & SHIELD; LAB COAT & APRON; VENT HOOD; PROPER GLOVES; CLASS B EXTINGUISHER • Storage Color Code: Red (Flammable)

49. Section 3: Hazards Identification • Potential Health EffectsInhalation:Inhalation of vapors irritates the respiratory tract. May cause coughing, dizziness, dullness, and headache. Higher concentrations can produce central nervous system depression, narcosis, and unconsciousness. Ingestion:Swallowing small amounts is not likely to produce harmful effects. Ingestion of larger amounts may produce abdominal pain, nausea and vomiting. Aspiration into lungs can produce severe lung damage and is a medical emergency. Other symptoms are expected to parallel inhalation. Skin Contact:Irritating due to defatting action on skin. Causes redness, pain, drying and cracking of the skin. Eye Contact:Vapors are irritating to the eyes. Splashes may cause severe irritation, with stinging, tearing, redness and pain. Chronic Exposure:Prolonged or repeated skin contact may produce severe irritation or dermatitis. Aggravation of Pre-existing Conditions:Use of alcoholic beverages enhances toxic effects. Exposure may increase the toxic potential of chlorinated hydrocarbons, such as chloroform, trichloroethane.

50. Section 4: First Aid Measures • This section lists very basic first aid procedures for all routes of entry such as: • Inhalation:Remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Get medical attention. • Ingestion:Aspiration hazard. If swallowed, vomiting may occur spontaneously, but DO NOT INDUCE. If vomiting occurs, keep head below hips to prevent aspiration into lungs. Never give anything by mouth to an unconscious person. Call a physician immediately. • Skin Contact:Immediately flush skin with plenty of water for at least 15 minutes. Remove contaminated clothing and shoes. Get medical attention. Wash clothing before reuse. Thoroughly clean shoes before reuse. • Eye Contact:Immediately flush eyes with plenty of water for at least 15 minutes, lifting upper and lower eyelids occasionally. Get medical attention.