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HAZCOM Hazardous Communication 29 CFR 1910.1200 “Right To Know”
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Purpose The purpose of the Hazard Communication Standard (HCS) is to ensure that the hazards of all chemicals produced or imported are evaluated and their hazards communicated to employees.
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Fiscal 2005 Penalties HAZCOM is OSHA’s second most cited standard. 7,267 citations written $1.4 million in fines
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Primary Fines No MSDS for product No written Hazcom program Lack of training Labeling
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2004 Most Cited Violations 1. Scaffolding, general requirements, construction (29 CFR 1926.451)29 CFR 1926.451 2. Hazard communication standard, general industry (29 CFR 1910.1200)29 CFR 1910.1200 3. Fall protection, construction (29 CFR 1926.501)29 CFR 1926.501 4. Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147)29 CFR 1910.147 5. Respiratory protection, general industry (29 CFR 1910.134)29 CFR 1910.134 6. Machines, general requirements, general industry (29 CFR 1910.212)29 CFR 1910.212 7. Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305)29 CFR 1910.305 8. Powered industrial trucks, general industry (29 CFR 1910.178)29 CFR 1910.178 9. Electrical systems design, general requirements, general industry (29 CFR 1910.303)29 CFR 1910.303 10. Mechanical power-transmission apparatus, general industry (29 CFR 1910.219)29 CFR 1910.219
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Basics of a HAZCOM Program Inventory all chemicals in the facility Keep a list of all hazardous chemicals Have a written HAZCOM program Ensure all containers are labeled Keep MSDS current Train your employees Allow access to your HAZCOM information to your associates
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Labels NFPA – National Fire Protection Association HMIS – Hazardous Material Identification System
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NFPA and HMIS Labels PHYSICAL HAZARD
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NFPA labels were designed by the fire fighters to aid emergency services to determine the extent of a chemical hazard. HMIS labels were designed by the National Paint & Coatings Association (NPCA) to help employers comply with OSHA’s 1910.1200 standard.
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NFPA Special Symbols: OXY = oxidizer ACID = acid ALK = alkaliCOR = corrosive W = keep away from water
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PHYSICAL HAZARD
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Original HMIS Label
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HMIS III Label
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HMIS PPE symbols: A = Safety glasses B = Safety glasses, gloves C = Safety glasses, gloves, chemical apron D = Face shield, gloves, chemical apron E = Safety glasses, gloves, dust respirator F = safety glasses, gloves, chemical apron, dust respirator G = Safety glasses, gloves, vapor respirator H = Splash goggles, gloves, chemical apron, vapor respirator I = Safety glasses, gloves, dust and vapor respirator J = Splash goggles, gloves, chemical apron, dust and vapor respirator K = Air line hood or mask, gloves, full chemical suit, boots X = Ask Supervisor Note: before using any respirator contact EH&S for assistance.
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NFPA v’s HMIS Labels Which labeling system is right for you? This is up to you. Which system fits your operation best. Highly recommended that you pick one and use only one due to the confusion that may arise in the differences in wording.
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WHMIS The Workplace Hazardous Materials Information System (WHMIS) is Canada's hazard communication standard.
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Are there different types of WHMIS labels? Yes. A WHMIS label can be a mark, sign, stamp, sticker, seal, ticket, tag or wrapper. It can be attached, imprinted, stenciled or embossed on the controlled product or its container.
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MSDS Material Safety Data Sheets
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What Is A Hazardous Chemical? Hazardous Chemical: Defined by OSHA as any chemical that is a health hazard or a physical hazard.
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MSDS Structure In 1984 OSHA established a voluntary format for MSDS containing 8 sections. There could be up to 16 sections.
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MSDS Structure Manufactures Name Hazardous Ingredients Physical/Chemical Characteristics Fire and Explosion Hazard Data Reactivity Data Health Hazard Data Precautions For Safe Handling Control Measures
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MSDS Structure OSHA specifies the information to be included on an MSDS, but does not prescribe the precise format for an MSDS. The MSDS must be in English but you may have other languages as well.
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Training Requirements Associates must be informed of the following: The requirements of 29 CFR 1910.1200 Any operations in their work area where hazardous chemicals are present
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The location and availability of the written hazardous communication program including the location of MSDS in your facility.
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Associates training shall include at least: Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area The physical and health hazards of the chemicals in the work area
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The measures associates can take to protect themselves from hazards including procedures the employer has implemented to protect associates from exposure The details of the hazardous communication program developed by the employer including an explanation of the labeling system and MSDS and how they can obtain and use hazard information
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Off-Site Access MSDS may be kept at the primary work place. The MSDS information must be immediately obtainable for off-site associates.
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MSDS Some have NFPA hazard info, some have HMIS info some have both, some have none. Important that you understand both.
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MSDS Retention 29 CFR 1910.1020 Access to Employee Exposure and Medical Records, defines “employee exposure records” to include MSDS. The standard requires all employee exposure records to be maintained for at least 30 years.
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Websites HMIS www.ilpi.com/msds/ref/hmis.html www.paint.org/hmis/hmis_faq3.cfm
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NFPA www.ilpi.com/msds/ref/nfpa.html OSHA Website www.osha.gov/SLTC/hazardcommunica tions/index.html
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