Presentation Topics • Overview to the Approach of the Standard • Physical and Health Hazards • Hazard Determination • Labeling Requirements • Material Safety Data Sheets • Training Requirements • Written Program
History of “Haz-Com” • First attempts at communicating hazards- hieroglyphics in the Egyptian tombs. • 19th Century- chemists often provided users with “notes” regarding chemical properties. • 20th Century- labels were used • Voluntary for industries until 1960s • 1970 - OSHA developed a 2 page format for MSDS for use in the maritime industries
Right-to-Know Laws • November 25, 1985 - Effective date for the Manufacturing Sector • September 23, 1987 - Expanded to cover all non-manufacturing employees • February 9, 1994- Final Rule with minor modifications
EPA Community Right-to-Know • Superfund Amendments and Reauthorization Act (SARA) of 1986 • Congress mandated under SARA that chemicals required to have MSDSs under OSHA provisions, will be subject to the SARA reporting requirements to communities.
OSHA Standards Title 29 • CFR 1910.1200 - General Industry • CFR 1915.99 - Shipyard • CFR 1917.28 - Marine terminals • CFR 1918.90 - Longshoring • CFR 1926.59 - Construction • Covers chemical manufacturers, importers, distributors, employers and employees exposed to chemical hazards.
Overview of the Approach • Unique Standard • covers more workers than any other single health standard • 35 million employees exposed to hazardous chemicals in over 3.5 million establishments. • covers all industries and all size facilities. • performance based standard - sets goals for compliance, but does not state how to reach the goals.
Overview of the Approach • HCS is a generic standard - covering 650,000 hazardous chemical products • Criteria driven- No set list of “hazardous chemicals” - chemicals must meet definition or criteria. • “Right-to-Know”- employees have the right to know about the hazards in their workplace & what to do to minimize those hazards.
Overview to the Approach • Downstream flow of information • Chemical manufacturers - must prepare and provide information to customers or employers - labels and MSDS • Employers - must communicate information to employees by labels, MSDS and training to provide better employee protection • Employees - must use the information to participate in the protective programs
Number of Violations- Haz Com Hazard Communication - Written program Hazard Communication - Training initially and for new hazards Hazard Communication - Information and training Hazard Communication - MSDS Hazard Communication - Label identification Number of Serious Violations - FY 01
Purpose • Ensure that the hazards of all chemicals produced are evaluated & that information about these hazards is transmitted to employees. • Reduce incidence of chemical source illnesses and injuries. • Written Programs • Labels • MSDS • Training
Scope and Application • Who & What are Covered • all chemical manufacturers & importers must assess hazards; distributors must transmit information to customers. • employers must provide information to employees. • any chemical which is known to be present in the workplace that an employee may be exposed under normal or emergency conditions.
Scope & Application/ Exemptions • Laboratories & Warehousing Operations • Labels on incoming containers must not be removed or defaced • MSDS must be maintained when received or upon employee request; accessible during each work shift; not required on every hazardous chemical • Written programs are not required
Exemptions - Labeling • Products subject to labeling requirements of other agencies include: • pesticides • food, food additive • drugs • cosmetics • medical or veterinary devices • distilled spirits; tobacco products • hazardous waste
Section Does Not Apply • Hazardous waste subject to EPA • Tobacco or tobacco products • Wood (unless treated or processed) • Articles • Food or alcoholic beverage for consumption • Drug in the final solid form • Cosmetics packaged for consumers
Section Does Not Apply – cont. • Consumer products used with duration and frequency of a consumer • Nuisance particulates with no health or physical hazard • Ionizing and nonionizing radiation • Biological hazards
Definitions • “Hazardous Chemical”- any chemical which is a physical or health hazard • “Exposure”- an employee is subjected in the course of employment to a chemical that is a physical or health hazard and includes potential (e.g. accidental or possible) exposure; “subjected” ~ any route of entry, inhalation, ingestion, skin or absorption.
Hazard Determination • Chemical manufacturers & importers are responsible for evaluating the hazards of the chemicals they produce. • Employers may rely on these hazard evaluations • Appendix A (Health Hazard Definitions) • Appendix B (Hazard Determination)
Hazard Determination - cont. • Chemicals must be evaluated for its potential to cause adverse health effects and its potential to pose a physical hazard, such as flammability. • All chemicals listed: • 29 CFR 1910, Subpart Z; PELs • ACGIH TLVs • Listed by National Toxicology Program (NTP) • International Agency for Research on Cancer (IARC)
Hazard Determination - cont. • Mixtures • If tested as a whole, the results will be used to determine if it is hazardous. • A mixture has the same health hazards as its components if 1% or greater. • If a carcinogen is present at 0.1 %, it is hazardous. • Chemical manufacturers must document the hazard determination procedures used.
Hazards in the Workplace • Workplace hazards can be divided into two main categories: • Physical Hazards • Health hazards
Physical Hazards • Compressed Gases • Explosives • Combustibles • Flammables • Organic Peroxides • Oxidizers • Water Reactives
Physical Hazards • Compressed Gases • found in cylinders • hazards involve pressure, projectiles and asphyxiation e.g. nitrogen • Explosives • rapid and violent decomposition • hazards include noise, and potential for fire
Physical Hazards • Combustibles • Flashpoint > 100 deg. F, but < 200 deg. F. • burns slowly; hazard is fire potential • Flammables • Flashpoint < 100 deg. F. • easy to ignite, burns quickly • hazard is fire potential e.g. acetone
Physical Hazards • Organic Peroxides • Compounds which form unstable mixtures • When formed, these mixtures may generate violent reactions with explosion potential • An example is perchloric acid
Physical Hazards • Oxidizers • A chemical that initiates or promotes combustion in other materials. • May also release oxygen to assist in combustion. • Examples include chorine and concentrated sulfuric acid.
True or False? Water is the best material for putting out all chemical fires.
Physical Hazards • Water Reactives • Materials that react violently when exposed to water or possibly water vapor in air • May release toxic gases during the reaction.
Incompatible Chemicals • Flammables and oxidizers • Flammables and any ignition source • Acids and cyanides • Strong acids and strong alkalines • Concentrated acids and water • Organic solvents and corrosives • Corrosives and other reactive materials
Can you mix these chemicals? • Bleach (chlorine) with ammonia? • Sodium hydroxide with hydrochloric acid? • Ammonia nitrate with sodium nitrite? • Hydrogen cyanide with sulfuric acid?
Handling Flammable Chemicals • Keep containers closed when not in use • Keep away from ignition sources • Avoid contact with incompatible materials • Only transfer to approved containers • Bond all receiving containers • Clean up spills and dispose of waste properly
Proper Storage of Flammable Chemicals • Ensure that storage areas meet regulatory requirements • Replace all bung caps with drum vents after receiving containers • Ground all drums properly • Store quantities in approved storage rooms and cabinets • Store only in small quantities
True or False? A health hazard is the ability of a chemical to affect your health either quickly or over a long period of time.
Health Hazards • A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. • Appendix A • Appendix B
Health Hazards • Irritants • Corrosives • Sensitizers • Carcinogens • Toxics/ Highly Toxic Agents • Reproductive Toxins • Target Organ Chemicals
Health Hazards • Irritants • Materials which cause inflammatory response on tissue. • Effects are usually reversible. • May effect eyes, skin, and respiratory tract • Examples include solvents, acids and bases.
Health Hazards • Corrosives • Materials which cause destruction of tissue. • Effects may not be reversible. • May effect eyes, skin, and respiratory tract • Examples are strong acids and bases
Health Hazards • Sensitizers • Material may cause an allergic like response. • Usually after repeated exposures to high exposures. • May effect the skin or respiratory tract • Examples are isocyanates
Health Hazards • Carcinogens • Materials which are capable of causing cancerous tumors. • Usually are specific for certain types of cancer. • Examples include benzene and asbestos.
Health Hazards • Highly Toxic Agents • Determining the toxicity of compounds involves dose response studies • LD50 • Oral dose required to produce death in 50% of exposed species, usually within the first 30 days. • LC50 • Airborne concentration that when inhaled will kill 50 % of exposed species.
Health Hazards • Reproductive Toxins • Materials which are capable of disrupting the reproduction system. • Mutagens - cause cellular mutations • Teratogens - causes birth defects • Examples include lead and ethylene oxide
Health Hazards • Target Organ Chemicals • Chemicals which concentrate in, or damage specific organs. • Common target organs include central nervous system, liver, kidney, bone and blood.
Target Organ Chemicals • Hepatotoxins • produce liver damage • carbon tetrachloride • Nephrotoxins • produce kidney damage • halogenated hydrocarbons
Target Organ Chemicals • Neurotoxins • affect central nervous system • mercury, benzene • Respiratory: • Agents that damage the lungs • Asbestos, silica
Target Organ Chemicals • Hematopoietic: • toxins that affect the blood or circulatory system • carbon monoxide, cyanides and benzene
Occupational Exposure Guidelines • PEL: Permissible Exposure Limit • TLV: Threshold Limit Value • REL: Recommended Exposure Limit
PEL: Permissible Exposure Limit • Set by OSHA • Legal Standard • 29 CFR 1910.1000 • Many are based on 1968 ACGIH TLVs
TLV: Threshold Limit Value • Established by ACGIH • Airborne concentrations of substances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse health effects. • Exposure guidelines • Published annually
REL: Recommended Exposure Limit • Established by NIOSH • Acts under the authority of OSH Act of 1970 • Develops recommendations for limits of exposure to potentially hazardous substances or conditions in the workplace • Recommends preventive measures • Recommendations transmitted to OSHA for use in promulgating legal standards