HAZARD COMMUNICATION TRAINING FOR SMACNA MEMBER COMPANIES

Who Must Comply with the OSHA HAZCOM Standard This section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. Does not apply to: Hazardous Waste – SWD Act. Substance Defined by CERCLA Tobacco, Food and Alcohol Products Untreated Wood Products Consumer Products used in such a way. Nuisance Particulates that are harmless. Ionizing and Non Ionizing Radiation Biological Hazards

Scope of Responsibilities Chemical Manufacturers and Importers. Labeling MSDS SMACNA Member Companies that have employees who use potentially hazardous materials… Main Parts of HAZCOM Program Written Program Chemical List (Inventory) MSDS for Each Chemical in the Inventory Labeled Containers Training (All Employees)

Definitions Hazardous Chemical Any chemical which has a physical or health hazard effect. Container A ny bag, barrel, box, can, cylinder, drum, vessel, storage tank or the likes that contain a hazardous chemical. Use Package, handle, react, emit, extract or generate as a byproduct or transfer.

STEP 2 LABELS ON ALL CONTAINERS STEP 3 MSDS: COMPLETE HAZARD ANALYSIS STEP 4 INFORMATION AND TRAINING STEP 5 WRITTEN PROGRAM STEP 1 WRITTEN HAZCOM POLICY

Labeling Information Manufacturers Requirements Chemical Name Manufacturer Name Manufacturer Address Appropriate Hazard Warning Employer’s Responsibility Chemical Name Appropriate Hazard Warning (such as “flammable” or “toxic”)

Employers’ Labeling Requirements  All containers of chemicals are labeled. The words ‘container’ and ‘label’ have broad meaning in  Exception: immediate use of employee  Do not remove or deface labels  Change labels as hazard information changes (within 3 months)

Information on an MSDS Identity What’s in it? Physical/Chemical Properties Health Hazards Route of Entry PEL – TLV - Limits Listed Under NTP, IARC or NIOSH Safe Handling / Use Controls – Work Practices – PPE Emergency and 1 st Aid Requirements

Form MSDS  Non-Mandatory Form with Twelve (12) Mandatory Spaces  Blank spaces are not permitted. Use NA  Produced by chemical manufacturers and distributors and accepted in good faith by employers  Blank 174s are available from  Trade Secrets  Manufacturer can withhold information from MSDS  Nurse or physician can request proprietary information in writing  OSHA makes final decision if information is denied to nurse or physician

Employee Exposure & MSDS Your employee Your temporary employee Visitors and other contractors Your supervisor

Employee Access to MSDS The employer shall maintain in the workplace copies of the required material safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and other alternatives to maintaining paper copies of the MSDS are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)

Information and Training Requirements of Operations where hazardous chemicals are used Information about labeling systems, the written program and MSDS Physical and chemical hazards Methods to detect the presence or release of the chemical Protective measures Review your Company’s Written Hazard Communication Program and MSDS for information specific to the chemicals you use!