DB1 OSHA 3

OSH 2303, Hazardous Materials Safety 1

Course Learning Outcomes for Unit I Upon completion of this unit, students should be able to:

1. Summarize the requirements governing the management of hazardous substances. 1.1 Explain how the Occupational Safety and Health Administration (OSHA) Hazard

Communication regulation is used to manage hazardous substances. 1.2 Develop a method to implement a hazardous communications program for a company.

Required Unit Resources Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 81–137 In order to access the following resources, click the links below. Learn more about the health hazard and physical criteria that the Occupational Safety and Health Administration (OSHA) uses to determine if a substance is hazardous by reviewing the resources below. Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and

hazardous substances: Health hazard criteria (OSHA Standard No. 1910.1200 App A). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.1200AppA

Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and

hazardous substances: Physical criteria (OSHA Standard No. 1910.1200 App B). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.1200AppB

Unit Lesson

Global Harmonization The course textbook was published in 2012, a few months before the Occupational Safety and Health Administration (OSHA) Hazard Communication (HazCom) Standard was updated to be consistent with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). In addition to aligning the United States with the HazCom system used by many of its trade partners, the standardization of the safety data sheet format and the standardized classification and labeling of chemicals improves the quality and consistency of health hazard information in American workplaces. Adoption of GHS changed many of the definitions related to hazardous materials in the HazCom Standard and other OSHA standards related to hazardous materials. For example, in the 2012 HazCom Standard, a flammable liquid is now defined as a liquid having a flash point of no more than 93°C (199.4°F). Flammable liquids are then further divided into four subcategories based on the flash points (OSHA, 2013a). Combustible liquid as a category no longer appears in the standard. These same changes were also made in 29 Code of Federal Regulations (CFR) §1910.106, Flammable Liquids, which used to be titled “Flammable and Combustible Liquids.” Another significant change is the replacement of the term material safety data sheet (MSDS) with safety data sheet (SDS). MSDS is used in the course textbook, but all other course documents, including the lessons, assessments, and assignments will refer only to SDS. The 2012 HazCom revision was implemented in phases. Employee training on the new labels and SDS format was to be completed by December 1, 2013. Full compliance with new labeling requirements by June 1,

UNIT I STUDY GUIDE Introduction to the Laws, Regulations, and Standards That Apply to Hazardous Materials Management

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

2015, was required for chemical manufacturers and importers. Compliance with all provisions of the revised standard, including replacement of alternate labeling systems, was required by June 1, 2016 (OSHA, 2013a). Although some of the information in Chapter 3 is based on the OSHA HazCom Standard prior to 2012, it still contains a significant amount of best practice information. For specific OSHA compliance requirements, accessing the standard through the OSHA website is recommended. If you want to use a printed version of the OSHA standards, be sure it was published after March 2012. OSHA has a webpage showing a side-by- side comparison of the 1994 and 2012 HazCom Standards that you can use to determine what has or has not changed.

Hazardous Materials in the Workplace Workers have a right to know what chemicals are used in their workplaces, what risks these chemical hazards present, and how to protect themselves against the hazards. These are the values that form the foundation of OSHA’s HazCom Standard (Haight, 2012). While these principles of worker protection may appear self- evident, it was not until 1983 that they became codified in an OSHA standard. After more than 30 years, violations of the HazCom Standard are still among the most frequent citations issued by OSHA and among the top 10 in highest penalties assessed (Haight, 2012; OSHA, n.d.). In this unit, we review the regulations that govern the rights to know issues and examine the complexities involved with the effective implementation of the rules. Along the way, we may gain some insight into why there are so many violations and fines involved. OSHA (1998) estimates that there are 32 million workers exposed daily to one or more of the 650,000 chemicals and chemical products in use today. In addition, new chemicals are continually being developed and introduced into the workplace. While some of these chemicals, such as ammonia, are easy to detect and the effects of exposure are obvious, many other chemicals, such as lead, cause no immediate worker distress upon exposure but can result in serious chronic illness, even at low-level exposure. The HazCom Standard is designed to provide a methodology to ensure that workers are not adversely affected by hazardous substances in the workplace. Effective control of hazardous materials in the workplace starts with chemical manufacturers and importers. The HazCom Standard requires them to analyze their chemicals and chemical compounds for hazards. They must then compile information about the hazards and provide this information to their employees and to anyone who buys or uses the substances. Employers who distribute, buy, or use the substances must pass the safety information on to their employees, and all employees must comply with the requirements for safe storage, handling, and use. It is a simple concept, but it is difficult to implement, as indicated by the number of violations documented annually. Haight (2012) suggests that employers complete five tasks to ensure effective implementation.

• Develop a written HazCom program. • Create an up-to-date hazardous chemical inventory. • Have all hazardous materials properly labeled. • Make accessible to all employees an SDS for every chemical that is covered by the standard. • Properly instruct, train, and provide required information to all affected employees.

OSHA (2014) recommends following the seven steps in order to implement an effective HazCom program.

• Learn the standard, and identify responsible staff. • Prepare and implement a written HazCom program.

HazCom wallet card (OSHA, 2013b)

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

• Ensure containers are labeled. • Maintain SDSs. • Inform and train employees. • Evaluate and reassess your program.

While the lists are similar, it should be noted that OSHA starts with learning the standard. Haight (2012) implies that learning the standard is a part of developing the written program. Similarly, Haight (2012) includes creating a hazardous material inventory as a separate task, while OSHA embeds the inventory in the written program step. Perhaps the most significant difference in the two approaches is OSHA’s inclusion of evaluating and reassessing the program as the final step. Evaluating the program means measuring compliance with the requirements of the OSHA standard as well as the effectiveness of the program. Program updates are needed if new chemicals are introduced into the workplace or if processes are changed. Inspections should be conducted to ensure labels on containers are intact and SDSs are kept current.

Written HazCom Programs Many of the OSHA standards contain a requirement for a written program. In addition to the HazCom Standard, written programs are required in the OSHA standards for respiratory protection, hearing conservation, confined space entry, and others. Written programs ensure systematic development of compliance measures and ensure all elements are adequately addressed (OSHA, 2014). A cornerstone of the written program for HazCom is the hazardous materials inventory. Developing a comprehensive inventory may seem like an insurmountable task, but keep in mind that chemical manufacturers and importers are the ones required to prepare and provide SDSs. If your organization is not a chemical manufacturer or importer, then you should have already received an SDS for every hazardous chemical you purchased. This is a good place to start. If you do not have an SDS for a chemical, you can refer to the product label, which must include the name and address of the manufacturer from whom you can request the SDS. In some cases, a process may result in the creation of a hazardous substance. Since there is no manufacturer or importer, it is incumbent on the employer to develop or hire someone to develop the required SDS. The Appendix A: Health Hazard Criteria webpage and the Appendix B: Physical Criteria webpage provide guidelines for evaluating the health and physical hazards of substances but require significant expertise to be used effectively. Remember that if your organization, for whatever reason, develops its own SDS, it is responsible and liable for the accuracy of the information. The written program must also include procedures to ensure the hazardous materials inventory is kept current; new chemicals must be identified and added as they arrive, and chemicals no longer used must be deleted. An accurate, current inventory provides the basis for most of the other requirements of the standard. The good news is that there are numerous resources available to help you develop a written HazCom program. Free materials are available from OSHA and many state occupational safety and health offices. The HazCom Standard has also spawned a cottage industry of consultants who will be happy to help you for a price. Try entering "OSHA HazCom Standard" into your favorite internet search engine. The course textbook also offers a sample written program. When using any third-party resources, be sure they are based on the 2012 changes to the HazCom Standard. The next unit will cover the regulations that apply to hazardous wastes. Subsequent units will provide information about control methods, hazardous spill response, U.S. Department of Transportation (DOT) requirements for the transport of hazardous materials and wastes, and the benchmarking of programs.

References Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of

Safety Engineers. Occupational Safety and Health Administration. (n.d.). Top 10 most frequently cited standards for fiscal year

2018 (Oct. 1, 2017, to Sept. 30, 2018). United States Department of Labor. https://www.osha.gov/Top_Ten_Standards.html

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

Occupational Safety and Health Administration. (1998). Chemical hazard communication (OSHA Document No. 3084). U.S. Department of Labor. https://www.osha.gov/Publications/osha3084.pdf

Occupational Safety and Health Administration. (2013a). Foundation of workplace chemical safety programs:

The globally harmonized system for hazard communication. United States Department of Labor. https://www.osha.gov/dsg/hazcom/global.html

Occupational Safety and Health Administration. (2013b). Hazard communication OSHA 3658 [Image].

https://www.osha.gov/Publications/OSHA3658.pdf Occupational Safety and Health Administration. (2014). Steps to an effective hazard communication program

for employers that use hazardous chemicals [Fact sheet]. U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3696.pdf

Suggested Unit Resources In order to access the following resource, click the link below. Read about the United Nations Global Harmonization System, which was the basis for the 2012 revisions to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard. United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th

Rev. ed.). United Nations Economic Commission for Europe. http://www.unece.org/trans/danger/publi/ghs/ghs_rev04/04files_e.html

Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information.

State Requirements If your state has a state plan approved by the Occupational Safety and Health Administration (OSHA), research the hazard communication (HazCom) requirements of the plan, and compare and contrast them with the OSHA HazCom Standard. If your state does not have its own plan, research the HazCom requirements for California. Do you have any recommendations for improvements to your state’s or California’s plan? Note your thoughts in a personal journal that you can refer back to throughout the course.

Is Hazard Communication Up to Par? Review the written HazCom program for your current organization. Does it contain all of the required information? If it does not, explain what is missing. Would you recommend any changes to the existing content of the program? What improvements can you recommend? Explain your ideas. Note your thoughts in a personal journal that you can refer back to throughout the course.

OSH 2303, Hazardous Materials Safety 1

Course Learning Outcomes for Unit I Upon completion of this unit, students should be able to:

1. Summarize the requirements governing the management of hazardous substances. 1.1 Explain how the Occupational Safety and Health Administration (OSHA) Hazard

Communication regulation is used to manage hazardous substances. 1.2 Develop a method to implement a hazardous communications program for a company.

Required Unit Resources Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 81–137 In order to access the following resources, click the links below. Learn more about the health hazard and physical criteria that the Occupational Safety and Health Administration (OSHA) uses to determine if a substance is hazardous by reviewing the resources below. Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and

hazardous substances: Health hazard criteria (OSHA Standard No. 1910.1200 App A). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.1200AppA

Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and

hazardous substances: Physical criteria (OSHA Standard No. 1910.1200 App B). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.1200AppB

Unit Lesson

Global Harmonization The course textbook was published in 2012, a few months before the Occupational Safety and Health Administration (OSHA) Hazard Communication (HazCom) Standard was updated to be consistent with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). In addition to aligning the United States with the HazCom system used by many of its trade partners, the standardization of the safety data sheet format and the standardized classification and labeling of chemicals improves the quality and consistency of health hazard information in American workplaces. Adoption of GHS changed many of the definitions related to hazardous materials in the HazCom Standard and other OSHA standards related to hazardous materials. For example, in the 2012 HazCom Standard, a flammable liquid is now defined as a liquid having a flash point of no more than 93°C (199.4°F). Flammable liquids are then further divided into four subcategories based on the flash points (OSHA, 2013a). Combustible liquid as a category no longer appears in the standard. These same changes were also made in 29 Code of Federal Regulations (CFR) §1910.106, Flammable Liquids, which used to be titled “Flammable and Combustible Liquids.” Another significant change is the replacement of the term material safety data sheet (MSDS) with safety data sheet (SDS). MSDS is used in the course textbook, but all other course documents, including the lessons, assessments, and assignments will refer only to SDS. The 2012 HazCom revision was implemented in phases. Employee training on the new labels and SDS format was to be completed by December 1, 2013. Full compliance with new labeling requirements by June 1,

UNIT I STUDY GUIDE Introduction to the Laws, Regulations, and Standards That Apply to Hazardous Materials Management

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

2015, was required for chemical manufacturers and importers. Compliance with all provisions of the revised standard, including replacement of alternate labeling systems, was required by June 1, 2016 (OSHA, 2013a). Although some of the information in Chapter 3 is based on the OSHA HazCom Standard prior to 2012, it still contains a significant amount of best practice information. For specific OSHA compliance requirements, accessing the standard through the OSHA website is recommended. If you want to use a printed version of the OSHA standards, be sure it was published after March 2012. OSHA has a webpage showing a side-by- side comparison of the 1994 and 2012 HazCom Standards that you can use to determine what has or has not changed.

Hazardous Materials in the Workplace Workers have a right to know what chemicals are used in their workplaces, what risks these chemical hazards present, and how to protect themselves against the hazards. These are the values that form the foundation of OSHA’s HazCom Standard (Haight, 2012). While these principles of worker protection may appear self- evident, it was not until 1983 that they became codified in an OSHA standard. After more than 30 years, violations of the HazCom Standard are still among the most frequent citations issued by OSHA and among the top 10 in highest penalties assessed (Haight, 2012; OSHA, n.d.). In this unit, we review the regulations that govern the rights to know issues and examine the complexities involved with the effective implementation of the rules. Along the way, we may gain some insight into why there are so many violations and fines involved. OSHA (1998) estimates that there are 32 million workers exposed daily to one or more of the 650,000 chemicals and chemical products in use today. In addition, new chemicals are continually being developed and introduced into the workplace. While some of these chemicals, such as ammonia, are easy to detect and the effects of exposure are obvious, many other chemicals, such as lead, cause no immediate worker distress upon exposure but can result in serious chronic illness, even at low-level exposure. The HazCom Standard is designed to provide a methodology to ensure that workers are not adversely affected by hazardous substances in the workplace. Effective control of hazardous materials in the workplace starts with chemical manufacturers and importers. The HazCom Standard requires them to analyze their chemicals and chemical compounds for hazards. They must then compile information about the hazards and provide this information to their employees and to anyone who buys or uses the substances. Employers who distribute, buy, or use the substances must pass the safety information on to their employees, and all employees must comply with the requirements for safe storage, handling, and use. It is a simple concept, but it is difficult to implement, as indicated by the number of violations documented annually. Haight (2012) suggests that employers complete five tasks to ensure effective implementation.

• Develop a written HazCom program. • Create an up-to-date hazardous chemical inventory. • Have all hazardous materials properly labeled. • Make accessible to all employees an SDS for every chemical that is covered by the standard. • Properly instruct, train, and provide required information to all affected employees.

OSHA (2014) recommends following the seven steps in order to implement an effective HazCom program.

• Learn the standard, and identify responsible staff. • Prepare and implement a written HazCom program.

HazCom wallet card (OSHA, 2013b)

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

• Ensure containers are labeled. • Maintain SDSs. • Inform and train employees. • Evaluate and reassess your program.

While the lists are similar, it should be noted that OSHA starts with learning the standard. Haight (2012) implies that learning the standard is a part of developing the written program. Similarly, Haight (2012) includes creating a hazardous material inventory as a separate task, while OSHA embeds the inventory in the written program step. Perhaps the most significant difference in the two approaches is OSHA’s inclusion of evaluating and reassessing the program as the final step. Evaluating the program means measuring compliance with the requirements of the OSHA standard as well as the effectiveness of the program. Program updates are needed if new chemicals are introduced into the workplace or if processes are changed. Inspections should be conducted to ensure labels on containers are intact and SDSs are kept current.

Written HazCom Programs Many of the OSHA standards contain a requirement for a written program. In addition to the HazCom Standard, written programs are required in the OSHA standards for respiratory protection, hearing conservation, confined space entry, and others. Written programs ensure systematic development of compliance measures and ensure all elements are adequately addressed (OSHA, 2014). A cornerstone of the written program for HazCom is the hazardous materials inventory. Developing a comprehensive inventory may seem like an insurmountable task, but keep in mind that chemical manufacturers and importers are the ones required to prepare and provide SDSs. If your organization is not a chemical manufacturer or importer, then you should have already received an SDS for every hazardous chemical you purchased. This is a good place to start. If you do not have an SDS for a chemical, you can refer to the product label, which must include the name and address of the manufacturer from whom you can request the SDS. In some cases, a process may result in the creation of a hazardous substance. Since there is no manufacturer or importer, it is incumbent on the employer to develop or hire someone to develop the required SDS. The Appendix A: Health Hazard Criteria webpage and the Appendix B: Physical Criteria webpage provide guidelines for evaluating the health and physical hazards of substances but require significant expertise to be used effectively. Remember that if your organization, for whatever reason, develops its own SDS, it is responsible and liable for the accuracy of the information. The written program must also include procedures to ensure the hazardous materials inventory is kept current; new chemicals must be identified and added as they arrive, and chemicals no longer used must be deleted. An accurate, current inventory provides the basis for most of the other requirements of the standard. The good news is that there are numerous resources available to help you develop a written HazCom program. Free materials are available from OSHA and many state occupational safety and health offices. The HazCom Standard has also spawned a cottage industry of consultants who will be happy to help you for a price. Try entering "OSHA HazCom Standard" into your favorite internet search engine. The course textbook also offers a sample written program. When using any third-party resources, be sure they are based on the 2012 changes to the HazCom Standard. The next unit will cover the regulations that apply to hazardous wastes. Subsequent units will provide information about control methods, hazardous spill response, U.S. Department of Transportation (DOT) requirements for the transport of hazardous materials and wastes, and the benchmarking of programs.

References Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of

Safety Engineers. Occupational Safety and Health Administration. (n.d.). Top 10 most frequently cited standards for fiscal year

2018 (Oct. 1, 2017, to Sept. 30, 2018). United States Department of Labor. https://www.osha.gov/Top_Ten_Standards.html

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

Occupational Safety and Health Administration. (1998). Chemical hazard communication (OSHA Document No. 3084). U.S. Department of Labor. https://www.osha.gov/Publications/osha3084.pdf

Occupational Safety and Health Administration. (2013a). Foundation of workplace chemical safety programs:

The globally harmonized system for hazard communication. United States Department of Labor. https://www.osha.gov/dsg/hazcom/global.html

Occupational Safety and Health Administration. (2013b). Hazard communication OSHA 3658 [Image].

https://www.osha.gov/Publications/OSHA3658.pdf Occupational Safety and Health Administration. (2014). Steps to an effective hazard communication program

for employers that use hazardous chemicals [Fact sheet]. U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3696.pdf

Suggested Unit Resources In order to access the following resource, click the link below. Read about the United Nations Global Harmonization System, which was the basis for the 2012 revisions to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard. United Nations. (2011). Globally harmonized system of classification and labelling of chemicals (GHS) (4th

Rev. ed.). United Nations Economic Commission for Europe. http://www.unece.org/trans/danger/publi/ghs/ghs_rev04/04files_e.html

Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information.

State Requirements If your state has a state plan approved by the Occupational Safety and Health Administration (OSHA), research the hazard communication (HazCom) requirements of the plan, and compare and contrast them with the OSHA HazCom Standard. If your state does not have its own plan, research the HazCom requirements for California. Do you have any recommendations for improvements to your state’s or California’s plan? Note your thoughts in a personal journal that you can refer back to throughout the course.

Is Hazard Communication Up to Par? Review the written HazCom program for your current organization. Does it contain all of the required information? If it does not, explain what is missing. Would you recommend any changes to the existing content of the program? What improvements can you recommend? Explain your ideas. Note your thoughts in a personal journal that you can refer back to throughout the course.