1. Hazard Communication (Right To Know)
Clark Safety
&
Loss Control

2. Introduction
About 32 million workers, work with & are potentially exposed to one or more chemical hazards.
There are approximately 650,000 existing chemical products, & hundreds of new ones being introduced annually.
Chemical exposure may cause or contribute to many serious health effects, such as heart ailments, central nervous system damage, kidney and lung damage, sterility, cancer, burns, & rashes.
Some chemicals may also be safety hazards & have the potential to cause fires, explosions & other serious accidents.
This is one of the most frequently cited OSHA standards.
This program is intended for workplaces that do not manufacture, import, or distribute hazardous chemicals. Notes have been provided that highlight some of the requirements for these employers. For complete requirements, consult 29 CFR

3. 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.

4. Purpose of OSHA’s Hazard Communication Standard
To ensure that employers & employees know about work hazards, & how to protect themselves so that the incidence of illnesses and injuries due to hazardous chemicals is reduced.
Hazard Communication
Program
Container
Labeling
Material Safety
Data Sheet
29 CFR
The Hazard Communication (HazCom) standard establishes uniform requirements to make sure that the hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated, and that this hazard information is transmitted to affected employers and exposed employees.
The HazCom standard is different from other OSHA health rules because it covers all hazardous chemicals. The rule also incorporates a “downstream flow of information,” which means that producers of chemicals have the primary responsibility for generating and disseminating information, whereas users of chemicals must obtain the information and transmit it to their employees.
Program
MSDS
Label

5. Scope and Application Who and 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.

6. Employer Responsibilities
Identify and list hazardous chemicals in their workplaces.
Obtain Material Safety Data Sheets (MSDSs) and labels for each hazardous chemical, if not provided by the manufacturer, importer, or distributor.
Implement a written Haz-Com program, including labels, MSDSs, and employee training.
Communicate hazard information to employees through labels, MSDSs, and formal training programs.

7. 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

8. 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

9. 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)

10. 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)

11. Why is a written program required ?
Ensures that all employers receive the information they need to inform and train their employees.
Provides necessary hazard information to employees.
(f) "Labels and other forms of warning."
(g) "Material safety data sheets."
(h) "Employee information and training."
HazCom Program
(e)

12. Written Haz-Com Program Requirements
Describes container labeling, MSDSs, and employee training for each workplace.
List of the hazardous chemicals.
Make information regarding hazards and protective measures available to other employers onsite.
Employer also required to describe how they will inform employees of the hazards of non-routine tasks (for example, cleaning reactor vessels), and the hazards associated with chemicals in unlabeled pipes.

13. Written Program Blueprint for action; Elements;
What’s covered, how and who is responsible.
Elements;
List of Hazardous Chemicals in workplace.
Same identity or name on list/ label/ MSDS
Container labeling procedures.
Material Safety Data Sheets.
Employee Information &Training Program.

14. Written Program
Methods employers will use to inform employees of hazards of non-routine tasks (e.g.. the cleaning of reactor vessels).
Hazards of chemicals in unlabeled pipes.

15. Written Program
Multi-employer worksites- employers must make available information regarding hazards and protective measures to other employees on site.
Employees travel between worksites, the program may be kept at primary workplace.
Written Program must be available to employees, their representatives, OSHA or NIOSH.

16. How must chemicals be labeled ?
Each container of hazardous chemicals entering the workplace must be labeled or marked with:
Identity of the chemical.
Appropriate hazard warnings.
Name and address of the responsible party.
(f)
Chemical manufacturers and importers must convey the hazard information to downstream employers by means of labels on containers and Material Safety Data Sheets (MSDSs). Language used on the warning label does not have to be identical to that on the MSDS.
Chemical manufacturers, importers, and distributors must be sure that containers of hazardous chemicals leaving the workplace are labeled, tagged, or marked with:
- the identity of the chemical,
- appropriate hazard warnings, and
- the name and address of the chemical manufacturer, importer, or other responsible party
Consumer products having labels meeting requirements of the Consumer Product Safety Act do not have to have additional labeling under the HazCom Standard.
Various other chemical products (for example, pesticides, foods, drugs, cosmetics, beverage alcohols) that are subject to labeling laws administered by other Federal agencies are also exempt from the labeling requirements of the HazCom Standard.

17. Container Labeling in the Workplace
The hazard warning can be any type of message, picture, or symbol that provides information on the hazards of the chemical(s) and the targeted organs affected, if applicable
Labels must be legible, in English (plus other languages, if desired), and prominently displayed
Exemptions to the requirement for container labeling:
- Can post signs/placards that convey hazard information if there are a number of stationary containers within a work area with similar contents and hazards
- Can substitute various types of standard operating procedures, process sheets, and similar written materials for container labels on stationary process equipment if they contain the same information and are readily accessible to employees in the work area
- Not required to label portable containers into which hazardous chemicals are transferred from labeled containers and are intended only for the immediate use of the employee who makes the transfer
- Pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers

18. Labels and Warning Signs
Primary Containers
Secondary Containers
Stationary Containers
Transfer Containers

19. Primary Container Labels
Identity of the product
Hazard warnings
Name and address of the chemical manufacturer, importer or other responsible party

21. Labels and Warning Signs
Identity- can be chemical or common name as long as it is the same term on the label, chemical list and MSDS.
Hazard Warning- convey physical or health effects of a chemical; e.g. “potential carcinogen” or “causes lung damage or “flammable”. If available, must convey target organ effect.

22. Secondary Container Labels
May use label provided by supplier
Must contain chemical identity and hazard warning
May use numerical rating systems, colors, symbols etc.
Must be prominently displayed, legible and in English (may also be in other languages).
Generally, your employer must make sure that each secondary container of hazardous chemicals in the workplace is labeled, tagged or marked with at least the following information:
Identity of the hazardous chemical(s) contained therein; and,
Appropriate hazard warnings, or words, pictures, and/or symbols which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information (an MSDS) will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

23. Stationary Process Containers
Storage tanks, pipes
May use signs, placards, process sheets, batch tickets, operating procedures or other written materials
Must identify the containers to which the label is applicable and convey the information required on secondary containers
The written materials must be readily accessible
Stationary process containers are...well...stationary! Storage tanks are good examples. The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required on secondary containers. The written materials must be readily accessible to the employees in their work area throughout each work shift.

24. Transfer Container Labels
All portable containers must be labeled except those intended only for the immediate use of the employee who performs the transfer (used by one person during one shift).

25. Containers

26. Containers

27. NFPA Labels

28. HMIS Label

29. Labels

30. Material Safety Data Sheets
Prepared by the chemical manufacturer or importer and describe:
Physical hazards, such as fire and explosion
Health hazards, such as signs of exposure
Routes of exposure
Precautions for safe handling and use
Emergency and first-aid procedures
Control measures
(g)
Chemical manufacturers and importers must develop an MSDS for each hazardous chemical they produce or import, and must provide the MSDS at the time of the initial shipment to a downstream distributor or user. Distributors also must ensure that downstream employers are similarly provided an MSDS.
The MSDSs must be updated by the chemical manufacturer or importer within three months of learning of "new or significant information" regarding the chemical's hazard potential.
OSHA does not require that MSDSs be provided to purchasers of household consumer products (such as "windex" and "white‑out“) when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. Employees who are required to work with hazardous chemicals in a greater duration and frequency of exposure than a normal consumer have a right to know about the properties of those hazardous chemicals.

31. Material Safety Data Sheets (cont’d)
Must be in English and include information regarding the specific chemical identity and common names
Must provide information about the:
Physical and chemical characteristics
Health effects
Exposure limits
Carcinogenicity (cancer-causing)
Identification (name, address, and telephone number) of the organization responsible for preparing the sheet
Must be readily accessible to employees in their work area
In the absence of other employee exposure records, MSDSs that indicate a health hazard are considered employee exposure records under the Access to Employee Medical Records standard, 29 CFR and must be preserved and maintained for at least thirty years, with some exceptions. [See 29 CFR (d)]
Electronic access is acceptable provided:
- A back-up procedure is available if the electronic system fails
It can be accessed in the employee’s work area
The telephone number provided must be that of a person who can provide additional information about the hazardous chemical and appropriate emergency procedures.

32. Material Safety Data Sheets (cont’d)
MSDSs have no prescribed format
If no MSDS has been received for a hazardous chemical, employer must contact the supplier, manufacturer, or importer to obtain one and maintain a record of the contact
One MSDS may apply to multiple complex mixtures having similar contents and hazards.
For information regarding the preparation of MSDSs, see ANSI Z400.1, Hazardous Industrial Chemicals – Material Safety Data Sheets – Preparation.

33. Material Safety Data Sheets
Chemical manufacturer information
Identity Information; chemical and common names of hazard ingredients
Physical and Chemical Characteristics
Physical Hazards
Health Hazards; signs and symptoms of exposure
Primary Routes of Entry
Exposure Limits (PELs, TLVs)
The identity used on the label;
If the hazardous chemical is a single substance, its chemical and common name(s);
If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself; or,
If the hazardous chemical is a mixture which has not been tested as a whole, 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 (0.1% for carcinogens);

34. Material Safety Data Sheets
Emergency and first aid procedures
Precautions for Safe Handling and Use
Spills and leak procedures
Appropriate Control Measures
Engineering Controls/ PPE/ Work Practices
Date of preparation or revision, name, address, telephone of chemical manufacturer

35. Material Safety Data Sheets
Must be readily accessible to employees in their work areas during their work shifts.
Employees must have access
May be computerized (electronic access).
If employees travel between worksites, MSDS must be at primary worksite.

36. Material Safety Data Sheets
Chemical manufacturers and importers have responsibility for development of MSDS.
Employers must have MSDS for each hazardous chemical on site.
Format may vary, specific information is required.
Must be in English

37. MSDS Helpful Hints A glossary of MSDS terms is useful
Ensure that someone is responsible for obtaining and maintaining the MSDSs
Ensure that the identity noted on the chemical label, chemical list and MSDS are the same-- this link between the three sources is important.
Household chemicals?

38. Training
Training is required for employees who are exposed to hazardous chemicals in their work area:
At the time of initial assignment
Whenever a new hazard is introduced into their work area
(h)
Training is not satisfied solely by giving the employee the data sheets to read. An employer's training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them. Training must be carried out in a language that is comprehensible to the employees.
Training need not be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents, irritants, flammables) that are or may be encountered by an employee during the course of his duties.
Employees who have been previously trained by another employer, union, or other entity, do not have to be retrained if the previous training is sufficient to meet the standard’s training requirements for the current work being performed. However, employees must have information about where to find MSDSs in the workplace, who in the company is responsible for the HazCom program, and where to get copies.

39. What training is needed to protect workers?
Explanation of the HazCom program, including information on labels, MSDSs, and how to obtain and use available hazard information
Hazards of chemicals
Protective measures such as engineering controls, work practices, and the use of PPE
How to detect the presence or release of a hazardous chemical (using monitoring devices, observation, or smell)

40. What information must be provided to workers?
Employees must be informed of:
The HazCom standard and its requirements
Operations in their work areas where hazardous chemicals are present
Location and availability of the written hazard evaluation procedures, communications program, lists of hazardous chemicals, and the required MSDSs

41. Employee Information/Training
Who - each employee who may be “exposed” to hazardous chemicals
When - prior to initial assignment to work with hazardous chemicals, and whenever the hazard changes or a new hazard is introduced.
Method - performance oriented (lecture, interactive or videotape);
individual chemicals or by
categories of hazards (e.g. corrosives)

42. Employee Training
Must be trained on the methods and observations used to detect the presence or release of hazardous chemicals in their work area.
physical and health hazards of chemicals;
air monitoring or continuous monitoring devices;
visual appearance or odors of hazardous chemicals; some have no odor, little odor or may cause olfactory fatigue.

43. Employee Training
Methods to prevent or minimize exposures/ protect themselves
Administrative Controls - training
Engineering Controls - ventilation, isolation
Use of Personal Protective Equipment
Safe Work Practices
Substitution; use of less hazardous chemicals.

44. Handling Chemical Emergencies
Know emergency phone numbers
Know how to control the spill
Know proper equipment shutdown procedure
Know proper evacuation routes and assembly areas
I. Background for the Trainer:
If your company has existing emergency procedures for dealing with chemicals, show it to the class at this time.
II. Speaker’s Notes:
If employees are uncertain how to handle the emergency, they should evacuate the area and let someone else handle it.
Information on this slide is contained in our Emergency Action Plan. It’s covered by a different OSHA standard, 29 CFR

45. What Emergency Personnel Should Know
Emergency cleanup and disposal measures
Required protective equipment
Use of cleanup equipment
Firefighting and other emergency measures (i.e., first aid)
Use of other emergency equipment
I. Speaker’s Notes:
Even if outside personnel perform emergency services relative to a chemical spill, the owner of the company must ensure that proper emergency procedures are followed.
All nontrained personnel should stay away from the emergency area.

46. Recordkeeping No Long Term Recordkeeping Requirements
Keep Written Program Current
Access to Employee Exposure and Medical Records Regulation
if employer has exposure monitoring, lists of chemicals, locations etc., outdated MSDS need not be maintained.

47. Hazard Communication Violations
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

48. Summary
OSHA’s Hazard Communication Standard 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
Employees also need to know what protective measures are available to prevent adverse effects from occurring
See for more information on hazard communication, including the following publications:
Hazard Communication Guidelines for Compliance – OSHA 3111
(This is the same information that is contained in Appendix E to and is also available in Spanish.)
Chemical Hazard Communication – OSHA 3084
(This is also available in Spanish.)

49. Questions?