Protecting Employees from Workplace Hazards OSHA Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories

Introduction Presenter - Colleen Cunanan, AKOSH Industrial Hygienist Purpose – familiarize you with OSHA’s Hazard Communication & Occupational Exposure to Hazardous Chemicals in Laboratories Standards [CFR 1910.1200 & 1910.1450]

Overview Hazard Communication Standard (HCS) 2012 standard revision to incorporate the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Requirements of the standard Occupational Exposure to Hazardous Chemicals in Laboratories Standard (Lab Standard) Comparison of the Lab Standard to HCS

OSHA’s Hazard Communication Standard 29 CFR 1910.1200

What is Hazard Communication? OSHA Hazard Communication Standard 29 CFR 1910.1200 – “Right to Know” went into effect in November 1985 The purpose of Hazcom is to communicate workplace chemical hazards and appropriate protective measures to employees Employees have a Right to Know about the hazards in their work areas and the potential effects of these hazards upon their health and safety 43 million workers are exposed to hazardous chemicals in over 5 million workplaces (OSHA, Modification…GHS 2012) 575,000 hazardous chemical products in these workplaces (NIOSH 48 FR 53323)

What is Global Harmonization? A common and coherent approach to defining and classifying hazards, and communicating information on labels and safety data sheets Provides the underlying infrastructure for establishing a national, comprehensive chemical safety program The new hazard communication standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets. However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.

How will Global Harmonization help? Improve comprehensiveness Improve consistency Improve understanding Many countries have regulations regarding the dissemination of information on chemical hazards. While similar, they are different enough to require multiple labels and safety data sheets for the same product traded internationally. GHS is intended to aid in communication. Based on the following principles: Information should be conveyed in more than one way. Phrases used to indicate degree of severity should be consistent across different hazard types.

Changes to HCS Hazard Classification Labels Safety Data Sheets Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result. Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. Safety Data Sheets: Will now have a specified 16-section format.

Timeline for Compliance Effective Completion Date Requirement(s) Who December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers June 1, 2015* December 1, 2015 Compliance with all modified provisions of this final rule, except: The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label Chemical manufacturers, importers, distributors and employers June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Transition Period to the effective completion dates noted above May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both Chemical manufacturers, importers, distributors, and employers

Key Elements of the Hazard Communication Standard (HCS) Written Program – must be developed and tie all the following elements together Training - all employees must be trained to identify and work safely with hazardous materials Labeling - containers of hazardous materials must have labels which identify the material and warn of its potential hazard to employees Safety Data Sheets (SDSs) - detailed description of each hazardous material present in the workplace

HCS Written Program Information and training the employee will receive regarding workplace hazards Labeling and other forms of warning utilized in the workplace Maintenance of SDSs for every chemical Chemical inventory Methods the employer uses to inform employees of hazards of non-routine tasks and hazards of chemicals in unlabeled pipes in work areas Methods of communicating hazards to other employers (contractors)

Additional Alaska Requirements Chemical inventory with locations Physical Agent Data Sheets (PADs) Table Z-1-A Example - Acetone Fed PEL – TWA 1000 ppm AK PEL – TWA 750 ppm, STEL 1000 ppm Per Alaska statute (8 AAC 61.1110(f)(3)), employer must post a list of the chemical name/product name of any toxic or hazardous substance and physical agent with an identification of workplace location Per Alaska statute (8 AAC 61.1110(a)), employer must have PADs for any physical agent present at workplace. Information and training must be provided upon initial assignment and whenever a new physical agent is introduced to their work area. Alaska has more stringent PELs than Fed OSHA. A copy should be included in SDS binder as SDSs typically list only the Fed OSHA limits.

HCS Training Requirements Employee training is an integral part of the hazard communication program and must be provided: At the time of initial assignment Whenever a new hazard is introduced into the workplace, and When employees may be exposed to other employers’ workplace hazards Hazard Communication – Site specific training Details of employer’s Hazcom program Specific hazards in the workplace Methods to detect presence or release of a hazardous chemical Methods to reduce hazards - product substitution, engineering controls, administrative controls, and personal protective equipment

Training – Non-routine Tasks Prior to starting work on such projects, affected employees will be given information on hazards to which they may be exposed during such activity This information will cover: Specific hazards Measures the employer has taken to reduce the risk of these hazards Required protective/safety measures Measures to reduce risk of hazards could include ventilation, ensuring presence of another employee, providing a respiratory protection program, and establishing emergency procedures.

Labels Warn of potential hazards Not intended to be the only source of information Serve as an immediate warning

What must be labeled? The OSHA Hazard Communication Standard requires that ALL hazardous materials be labeled. Labels must appear either on the container itself, a batch ticket, placard, or process sheets Hazardous chemicals in portable containers which are for the immediate use of the employee who performs the transfer is the exception to this rule

Manufacturer/Importer Label Requirements Product identifier Signal word Hazard statement Pictograms Precautionary statements Name, address, and phone number of responsible party Under the current Hazard Communication Standard (HCS), the label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements: Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards. Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS. Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.

GHS Pictograms and Hazards Health Hazard Flame Exclamation Mark • Carcinogen • Mutagenicity • Reproductive Toxicity • Respiratory Sensitizer • Target Organ Toxicity • Aspiration Toxicity • Flammables • Pyrophorics • Self-Heating • Emits Flammable Gas • Self-Reactives • Organic Peroxides • Irritant (skin and eye) • Skin Sensitizer • Acute Toxicity (harmful) • Narcotic Effects • Respiratory Tract Irritant • Hazardous to Ozone Layer (Non Mandatory)

GHS Pictograms and Hazards Gas Cylinder Corrosion Exploding Bomb • Gases under Pressure • Skin Corrosion/ burns • Eye Damage • Corrosive to Metals • Explosives • Self-Reactives • Organic Peroxides

GHS Pictograms and Hazards Flame Over Circle Skull & Crossbones Environment (Non-mandatory) • Oxidizers • Acute Toxicity (fatal or toxic) • Aquatic Toxicity

GHS Compliant Label

Workplace Labeling Standard is “performance based” – allows flexibility in labeling system Employers may use NFPA, HMIS, or duplicate the shipped label (GHS) Allowed labeling must be consistent with HCS, no conflicting hazard information Employer must ensure each container of hazardous chemicals is labeled

Workplace Labeling Must include: Product identifier – must match SDS and chemical inventory Words, pictures, symbols or combination of these that will provide employees with specific information regarding the physical and health hazards Allowed labeling must be consistent with HCS, no conflicting hazard information Employer must ensure each container of hazardous chemicals is labeled

Workplace Labeling Ensure labels are not removed, defaced, or unreadable For hard to label containers use: Signs or placards Process sheets or batch tickets

Safety Data Sheets (SDSs) Formerly referred to as Material Safety Data Sheets (MSDSs) SDSs provide detailed health and safety information and precautions for handling hazardous substances, including emergency and first aid procedures Employer must have a SDS for each hazardous chemical in the workplace and ensure SDSs are accessible to all employees

SDS Requirements HCS requires a standardized 16 section format 1. Identification 2. Hazard(s) Identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls/personal protection 9. Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12. Ecological information 13. Disposal considerations 14. Transport information 15. Regulatory information 16. Other information All sections are required for SDS to be consistent with GHS but OSHA will not enforce content of sections 12-15 since they are not under jurisdiction Sigma aldrich SDS example: http://www.sigmaaldrich.com/MSDS/MSDS/DisplayMSDSPage.do?country=US&language=en&productNumber=414689&brand=FLUKA&PageToGoToURL=http%3A%2F%2Fwww.sigmaaldrich.com%2Fcatalog%2Fsearch%3Finterface%3DAll%26term%3Dacetone%26lang%3Den%26region%3DUS%26focus%3Dproduct%26N%3D0%2B220003048%2B219853269%2B219853286

PADs – Alaska Requirement Cold Stress Hand-Arm Vibration Heat Stress Ionizing Radiation Lasers Noise Radio Frequency/Microwave Radiation Ultraviolet Radiation PADs are available on the AKOSH website

OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories 29 CFR 1910.1450

Key Elements of the Lab Standard Scope – laboratory use of chemicals; supersedes other subpart Z requirements except: PEL limitations Skin and eye contact prohibition Monitoring/medical surveillance requirements Written chemical hygiene plan – defines how employees will be protected and exposures will be kept below PELs Training – all employees must be trained on chemical hazards Medical consultation and examinations – provided free to employee by licensed physician under certain circumstances Hazard identification – labels and SDSs

What is “laboratory use” of chemicals? Chemical manipulations are carried out on a “laboratory scale”; Multiple chemical procedures or chemicals are used; Procedures involved are not part of a production process, nor in any way simulate a production process; and “Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals. Laboratory scale = work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safety manipulated by one person. Excludes those workplaces whose function is to produce commercial quantities of materials. Protective laboratory practices and equipment = procedures, practices and equipment accepted by laboratory health and safety experts as effective, or that the employer can show to be effective, in minimizing the potential for employee exposure to hazardous chemicals.

Written Chemical Hygiene Plan (CHP) Must be: Capable of protecting employees from health hazards associated with hazardous chemicals in laboratory Capable of keeping exposures below PELs Readily available to all employees

Required CHP Elements SOPs for work involving use of hazardous chemicals Criteria to determine and implement control measures to reduce employee exposure Requirement that fume hoods and other protective equipment are functioning properly and measures taken to ensure adequate performance of such equipment

Required CHP Elements Provisions for training and information Procedures requiring prior approval Provisions for medical consultation and examination Responsible personnel – Chemical Hygiene Officer Provisions for additional employee protection when working with particularly hazardous substances

Lab Standard Information and Training Requirements Employees must be apprised of hazards of chemicals present in their work areas Must be provided at time of initial assignment and prior to assignment involving new exposure situation

Lab Standard Information and Training Requirements Employees must be informed of: Contents of 1910.1450 and appendices Location of employer’s CHP PELs Signs and symptoms of exposure to chemicals in the laboratory Location of reference materials such as SDSs

Lab Standard Information and Training Requirements Employee training must include: Methods and observations that may be used to detect presence or release of hazardous chemical Physical and health hazards of chemicals in the work area Measures employees can take to protect themselves such as appropriate work practices, emergency procedures, and personal protective equipment (PPE)

Medical Consultation and Examinations Opportunity shall be provided when: Signs/symptoms shown Monitoring indicates need An “event” results in likelihood of exposure Shall be followed by Dr’s written opinion Requires the employer provide info to Dr Shall be: At no cost to employee Provided by a licensed physician Must be provided by a licensed physician, be free or charge, without loss of pay and at a reasonable time and place. Physician should be informed of chemical exposed to, conditions under which the exposure occurred, and the signs and symptoms the employee is experiencing. Physician will provide employer with written opinion with recommendations for follow-up exams, results of the exam and any tests, medical conditions revealed that may place the employee at increased risk as a result of chemical exposure. The written opinion will not disclose any findings unrelated to the occupational exposure.

Hazard Identification Labels on incoming containers shall not be removed or defaced SDSs received with incoming shipments of hazardous chemicals must be maintained and be made readily accessible

Hazard Identification Chemicals developed in lab: If composition is known, employer must determine if it is hazardous and provide appropriate training If composition is unknown (e.g. a byproduct) employer will assume it is hazardous If produced for outside user, employer must comply with HCS – SDS and labeling requirements

Differences from HCS SDS requirements Chemical inventory requirement Lab Standard supersedes other regs Annual review of CHP Medical evaluations Chemical Hygiene Officer Monitoring requirements

Similarities to HCS Same objective Same definitions Written program Training and information requirements

Questions?