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Organization of 30 CFR The Mine Health and Safety Act A Look at General Provisions HAZCOM (Part 47) ©Feb 2003 Dr. Bradley C Paul
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CFR Structure Coal MinesMetal-Non MetalQuarry/Gravel Subchapter H Education And Training Part 48 Miner Training Part 49 Mine Rescue Teams Part 48 Hazard Communications (HAZCOM) (June 2002) Part 46 Miner Training Subchapter M Uniform Mine Health Regs Part 62 Occupation Noise Exposure
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Part 47 Hazcom Regulation Principle is two pronged –Your employees have the right to know about the risks and characteristics of chemicals they work with Part of rationale is that many chemical effects may not show- up for years after exposure –The mine operator should know about the risks at his/her own operation Regs went in Aug. 2002 for mines with 6 or more –March 21, 2003 for those 5 and under
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Why MSHA Intervened Over 2500 chemical burns a year Over 1200 Lost Time Accidents Over 400 Cases of Poisoning Cases were over all types of mines and job classifications
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Goal of Your Hazcom Training Recognize the chemical hazards that exist Know how to understand a Material Safety Data Sheet Know where to get the information Know what protective gear and procedures will keep them safe
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Setting Up a Hazcom Compliant System Start by Inventorying your chemicals –Chemicals you bring into your site –Chemicals you produce at your site You will be trying to find those that are –Exempt –Non-Hazardous –Are Hazardous and demand a response
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What is Exempt Consumer Items –Common store products when used as common consumers would use them Cleaners would be example Key is also when used as common consumer –Regular workers probably have no Hazcom chemical issues –Janitors may Packaged break cleaner from Auto Zone –Gasoline is not a packaged consumer item
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More Exemptions Articles –Manufactured item that releases no more than incidental hazardous chemical + posed no special health risk to miners Examples Conveyor Belting, Pipes, Truck tires –Articles can become a raw material for producing something else Example galvanized pipe being welded releases zinc fume
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Personal Items Things like food, make-up, tooth paste, soap, tobacco products Also Excluded are things pose no hazard –Most materials have Material Safety Data Sheets that discuss risks –Example – some greases are not considered hazardous in normal use
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What Makes a Hazard Physical Hazard –Flammable –Explosive –Chemically active (corrosive for example) –Water reactive Chemical Hazard –Creates illness Acute (ie it zaps you down now) Chronic (ie. Long term of persistent long term duration)
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Mines Must Have Written Hazcom Plans Now that you have the list of materials Develop a plan that includes –Your list of Hazardous Materials –How you will tell miners about unlabeled hazards Things in pipes Things where risk appears only under special circumstance –The labeling system you will use on your containers –Where you will keep Materials Safety Data Sheets for different substances –What Training Program you will give to your miners Can and should be integrated with part 46 or 48 training –How you will inform contractors and others on the property of hazards and protective measures
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Things Must Be Labeled A Label will disclose –Name of Chemical so it can be cross referenced to your chemicals list and MSDSs –Flammability or Reactivity issues (if any) –Other Chemical and Physical Hazards or Risks Ie. Carcinogen, skin irritant etc. List risks in approximate order of severity being as specific as possible about target organs effected –Personal Protective Gear that should be used in handling –Special precautions when working around the chemical
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Labels Labels can be in any system as long as it is –Obvious –Legible –Accurate in its information –In English This does not prohibit posting in another language also
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Things Exempt from Labeling Items that are Exempt from part 47 as discussed before and kept in original containers Wood and wood products The raw material mined or processed at your facility –Unless put in a mixture in a container and the mixture is hazardous A RCRA Hazardous Waste labeled in accordance with EPA A Hazardous Chemical regulated under the Toxic Substances Control Act and labeled as required Any Hazardous material involved in a superfund clean-up being processed as part of the clean-up
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Must Have a Bank of MSDS Each Hazardous Chemical Must Have One –Many Chemicals brought in have them from the manufacture Must update when you receive an update from manufacture You are not responsible for defects in MSDS received from outside You must keep the sheet as long as the chemical is at the mine –Must inform the miners 3 months before you can dispose –Must have MSDS on any hazardous chemical you produce at the mine Must update the sheet within 3 months on any new information you maintain
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What Kind of MSDS Bank is Allowed Can be any format – not just paper –Can even be a fax on demand service off the property Can it be a computer –Yes but it must be accessible to miners Often a condition that you don’t want to meet
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Whats on an MSDS ? Identity of Chemical or ingredients if a mixture –Needs to Cross-Reference for the Chemical Inventory List, the Labels, and the MSDS Properties –Boiling, Melting –Vapor Pressure and Evaporation Rate –Solubility in Water –pH –Appearance and Odor –Flash Point –Flammability Limits Some of these Properties may not apply –Flammability Limits on Aggregate –Solubility of Gasoline that floats on water
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Good Grief – Where Do I Get That Stuff A lot of the MSDSs come from your chemical suppliers Your trade association probably already has this stuff because they need to supply it to buyers MSHA’s web site has information for many commonly mined materials
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More MSDS Stuff Physical Hazards –Fire –Explosion –Reactivity Health Hazards –Acute and Chronic Effects –Signs and Symptoms of Exposure –Medical Conditions Aggravated by Chemical –Method of entering the body
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More MSDS Stuff Carcinogenic Status –Not, Possible, Probable, Known Carcinogen Exposure Limits set by organizations such as MSHA or OSHA Safe Use –Instruction on good hygiene practice –Protection during repair or maintenance around contaminated equipment –Procedure for clean-up of spills and leaks
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More MSDS Stuff Control Measures –What is needed for Ventilation –Process Controls –Restricted Access –Protective Clothing –Respirators –Goggles Emergency Information –First Aide –Special Instruction to Firefighters Date Prepared
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Hazcom Training Requirements Hazcom Training must cover –Physical and Health Hazards of Chemicals in their area –Protective Measures that Can be Taken –An explanation of your Mine’s Hazcom Program Special Hazcom Training had to be given before effective dates Now Hazcom is included specifically in –All new miner training –All new task training or when a new chemical is introduced into an existing work environment
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