OSHA 3 PPT

OSH 2303, Hazardous Materials Safety 1

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

2. Recognize common hazardous materials control technologies. 2.1 Summarize the requirements of the Occupational Safety and Health Administration (OSHA)

Hazardous Communication program that regulate the control of hazardous materials in the workplace.

2.2 Associate OSHA’s hierarchy of controls to the management of hazardous materials in a workplace.

Required Unit Resources Review Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 86–100 In order to access the following resources, click the links below. Review these recommended practices for safety and health programs from the U.S. Department of Labor on pp. 20–23 of the following publication. Occupational Safety and Health Administration. (2016). Recommended practices for safety and health

programs (OSHA Publication No. 3885). https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf

Learn more about the hierarchy controls by reviewing the following website. National Institute for Occupational Safety and Health. (2015). Hierarchy of controls. Centers for Disease

Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/ Review the following webpage to learn about chemical hazards and toxic substances. Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling

exposure. United States Department of Labor. https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html

Details of the Hazard Communication Standard are listed below. Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and

hazardous substances: Hazard communication (OSHA Standard No. 1910.1200). United States Department of Labor. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS

Unit Lesson

Hazardous Materials in the Workplace Hazardous materials in the workplace present some level of risk to occupants. The Occupational Safety and Health Administration (OSHA) requires employers to evaluate that level of risk using some type of risk assessment tool. When the level of risk associated with a chemical hazard is unacceptable, controls must be implemented to reduce the risk to an acceptable level. One approach to reducing the level of risk is making

UNIT III STUDY GUIDE Common Methods Used for Control of Hazardous Materials in the Workplace

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

sure that workers who have the potential for exposure are well-informed of the risk so they can take appropriate measures to protect themselves. The OSHA Hazard Communication (HazCom) Standard is designed to provide workers with the information they need to protect themselves from the risks associated with hazardous materials. The HazCom Standard was originally published in 1984 after 10 years of difficult rulemaking negotiations with industry and employee representative groups (OSHA, 2004). The original standard applied only to the manufacturing section, and in 1994, OSHA expanded the applicability of the standard to all employers. The standard remained essentially unchanged until the adoption of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in March 2012. Violations of the HazCom Standard have consistently been in the top 10 most-cited standards throughout its existence. The original standard was performance-based, meaning that many of the provisions stated the desired result but did not give details on how to get to that point. It allowed for much interpretation among employers, and OSHA compliance officers. Given the number of noncompliance citations issued over the years, it is obvious that the two groups often have different interpretations of the standard. Additional evidence of the disagreements and confusion can be found in the hundreds of letters of interpretation (LOI) that OSHA has issued about the standard. You can access the Standard Interpretations webpage to see the various interpretations. Two topics of the original standard that were performance-based and have been the source of much confusion and interpretation over the years are the sections on labeling and safety data sheets (SDSs), which were originally called material safety data sheets (MSDSs). Both have been changed to specification standards, meaning they leave less room for interpretation.

Hazardous Material Labels The HazCom Standard has always required chemical manufacturers and importers to label their hazardous material products. The first step in this process is to classify chemicals in accordance with the guidelines provided in Appendices A and B of the standard (OSHA, 1970b; OSHA, 1970c). Previously, hazard determination was left up to the manufacturer, and no specific criteria were provided. Also, prior to the 2012 revision, the requirements for labels included only the name and address of the manufacturer or importer, the identification of the chemical, and the appropriate hazard warnings (OSHA, 1970d). As one might expect, buying the same chemical from two different manufacturers would likely result in two different labels. Many employers began developing their own in-house labeling systems, or they used labels from the National Fire Protection Association (NFPA) or from the U.S. Department of Transportation (DOT). These actions helped with consistency, but whether they met the appropriate requirement was still open for interpretation. The DOT Chart 15: Hazardous Materials Markings, Labeling and Placarding Guide provides examples. The 2012 HazCom Standard resolved most of the labeling issues by prescribing specific information for all labels; these specifications have been listed below.

• Product identifier used on the SDS: The standard allows the chemical manufacturer to determine the identifier, but it must match the identifier used on the accompanying SDS.

• Signal word: Two signal words are prescribed: "Danger" is used for the most serious hazards, and "Warning" is used for less serious hazards. Only one signal word may appear on a label.

• Hazard statements: This is a brief description of the nature of the hazards of the chemical. • Precautionary statements: This is a recommended measure to minimize or prevent adverse effects.

Four types of precautionary statements are identified: prevention, response, storage, and disposal. • Pictograms: Nine graphic symbols are prescribed to identify specific hazard classes, but OSHA only

requires the use of eight of the symbols (the pictogram for an environmental hazard is not required). • Manufacturer information: Name, address, and telephone number of the chemical manufacturer or

importer must be included (OSHA, 2013a).

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

Standardized labeling requirements ensure that the same chemicals purchased from different manufacturers contain the same information in the same format, but OSHA still provides employers with some options. As noted earlier, in the 25 years since the first HazCom Standard was issued, much time and effort has been spent on developing these in-house systems, and many of them likely meet the intent of the HazCom Standard. OSHA recognizes this by allowing in-house labeling systems that meet the requirements of the 1994 HazCom Standard to remain in effect (OSHA, 2013a). That is good news for organizations that developed their own systems and those that sell OSHA-compliant labels; however, this is much like a performance standard and may be subject to interpretation.

SDSs Much has changed with MSDSs in the last 25 years. MSDSs evolved and became more standardized in format. They have been readily available in electronic versions and on the internet for more than 10 years. The OSHA HazCom Standard now prescribes a standard format of 16 sections to align with the GHS (OSHA, 2013b). The information on the SDSs, as they are now called, is essentially the same as the MSDS but is standardized across all workplaces.

• Section 1: Identification • Section 2: Hazard(s) • Section 3: Composition/Information on Ingredients • Section 4: First Aid Measures • Section 5: Fire Fighting Measures • Section 6: Accidental Release Measures • Section 7: Handling and Storage • Section 8: Exposure Controls/Personal Protection • Section 9: Physical and Chemical Properties • Section 10: Stability and Reactivity • Section 11: Toxicological Information

Sample HazCom label (OSHA, 2013a)

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

• Section 12: Ecological Information • Section 13: Disposal Considerations • Section 14: Transport Information • Section 15: Regulatory Information • Section 16: Other Information

OSHA does not require sections 13, 14, and 15 to be completed, but the Environmental Protection Agency (EPA) and the DOT regulations may require this information. The chemical manufacturer or importer preparing the SDS is required to make that determination. From a practical standpoint, the information in these sections would certainly help the employer with EPA and DOT compliance issues. The standard requires SDSs to be readily available to all employees on all work shifts. Over the years, OSHA has interpreted readily available to mean immediate and without delay (Haight, 2012). In addition, access to SDS information must not require assistance (e.g., requesting a copy from a supervisor or needing an intermediary to gain computer access for electronic versions). SDSs are required to be in English, but it makes sense to also make them, or the information they contain, available in all languages that are represented in the organization. Keep in mind that all employees have a right to know and understand the hazards of the chemicals with which they work. Even if only one employee speaks a language other than English, that one employee not understanding the hazards can create a dangerous situation for all employees. Even when all employees have been informed of the risks associated with the hazardous materials in the workplace, there may be risks associated with the hazardous materials that are unacceptable. The assessment of an unacceptable risk may come from workplace industrial hygiene sampling showing exposures exceeding the applicable OSHA permissible exposure limit (PEL) or from a workplace audit showing unacceptable risks of fire or explosion. In these cases, OSHA may require the employer to implement controls to reduce the risk(s). The National Institute for Occupational Safety and Health (NIOSH) and OSHA recommend the use of the hierarchy of controls when attempting to reduce the risks associated with hazardous materials (NIOSH, n.d.-b). One rendering of the hierarchy of controls is depicted below.

Do these workers know the hazards of the containers with which they are working? Are the containers clearly marked? Are they in compliance with the

HazCom Standard? (Henshall, 2008)

(NIOSH, n.d.-a)

OSH 2303, Hazardous Materials Safety 5

UNIT x STUDY GUIDE Title

The controls are arranged with the most effective controls at the top and the least effective controls at the bottom of the inverted pyramid. Elimination is the most effective control because it completely removes the hazardous materials from the workplace. Substitution also removes the hazardous materials from the workplace but substitutes another material that must then be evaluated for risk. Since these two controls remove the original hazardous materials from the workplace, they are often combined into one category called elimination/substitution. This control method may be the most effective, but it is also the most difficult to implement (NIOSH, n.d.-b). In many cases, a hazardous material is required to be used because of a chemical process or client specifications and no other hazardous materials will work. In those cases, elimination/substitution are not viable control methods. The next most effective control option involves the use of engineering controls. Note that engineering controls do not remove the hazardous materials from the workplace. Engineering controls reduce the potential for exposure to workers by reducing the amount (concentration) of the hazardous material that reaches the worker. Engineering controls can be very effective in reducing the risk associated with a hazardous material. One of the most important (and commonly used) engineering controls is ventilation (OSHA, 2017). The two most commonly used types of ventilation are general dilution ventilation and local exhaust ventilation systems. A general dilution ventilation system reduces the concentration of a hazardous material by introducing outside air that does not have the contaminant into the workplace air. A local exhaust ventilation system collects the air near the source and moves the contaminated air somewhere outside the work area where it may be filtered, treated, or simply released into the air outside the workplace. The type of ventilation system and the specifications for that system will vary depending on several variables including air concentrations, toxicity of the hazardous material, and physical characteristics of the workplace. Other examples of some commonly used engineering controls include the use of sound deadening materials around machines and lead-lined walls around ionizing radiation sources. Administrative controls are not as effective as engineering controls because they do not take any action to reduce the concentration of a hazardous material in the workplace. Instead, they change the way people work in order to reduce risk (NIOSH, n.d.-b). A good example of an administrative control is implementing a work/rest regimen to reduce the risks associated with heat extremes. By requiring workers in a hot environment to take periodic breaks of a specified duration and to take measures to rehydrate and cool, the risk of developing a heat illness can be reduced. The control measure that is the least effective is the use of personal protective equipment (PPE). The reason that PPE is the least effective is that it does not reduce the concentration of a hazardous material in the workplace. PPE merely blocks the hazardous material before the exposure occurs. Because of the many sources of leaks and malfunctions associated with PPE, the amount of protection claimed by PPE manufacturers may not be achieved in the actual workplace, and exposures may be higher than expected. Unfortunately, PPE is also one of the most commonly used control methods. When should PPE be used? OSHA (1970a) says PPE should be used when there is a hazard present capable of causing injury or impairment. However, OSHA requires the employer to attempt to reduce the risk to an acceptable level using more effective controls prior to using PPE as the primary control method (OSHA, n.d.). PPE can also be used to reduce risk during the time period when engineering and administrative controls are being implemented.

OSH 2303, Hazardous Materials Safety 6

UNIT x STUDY GUIDE Title

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

Safety Engineers. Henshall, G. (2008). FEMA - 39025 - EPA workers locating hazardous material moved by Ike in Texas

[Photograph]. Wikimedia Commons. http://commons.wikimedia.org/wiki/File:FEMA_-_39025_- _EPA_workers_locating_hazardous_material_moved_by_Ike_in_Texas.jpg

National Institute for Occupational Safety and Health. (n.d.-a). Hierarchy of controls [Image]. Centers for

Disease Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg

National Institute for Occupational Safety and Health. (n.d.-b). Hierarchy of controls: Overview. Centers for

Disease Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg

Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling

exposure. United States Department of Labor. https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html

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

protective equipment: General requirements (OSHA Standard No. 1910.132). United States Department of Labor. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9777&p_table=STANDARDS

Occupational Safety and Health Administration. (1970b). 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. (1970c). 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

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

hazardous substances: Allocation of label elements (OSHA Standard No. 1910.1200 App C). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.1200AppC

Occupational Safety and Health Administration. (2004). Hazard communication in the 21st century: History.

United States Department of Labor. https://www.osha.gov/dsg/hazcom/finalmsdsreport.html#history Occupational Safety and Health Administration. (2013a). Hazard Communication Standard: Labels and

pictograms (OSHA Brief No. DSG BR-3636). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3636.pdf

Occupational Safety and Health Administration. (2013b). Hazard Communication Standard: Safety data

sheets (OSHA Brief No. DSG BR-3514). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3514.pdf

Occupational Safety and Health Administration. (2017). Ventilation: Overview. United States Department of

Labor. https://www.osha.gov/SLTC/ventilation/index.html

OSH 2303, Hazardous Materials Safety 7

UNIT x STUDY GUIDE Title

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. One important task is identifying hazards in the workplace and performing a risk assessment for those hazards in order to evaluate the need for controls. The Occupational Safety and Health Administration (OSHA) has developed a tool to teach workers how to identify hazards in different workplaces. Access the website below, and use the tool to see if your skills at identifying hazards are up-to-date. Occupational Safety and Health Administration. (2017). Hazard identification training tool. United States

Department of Labor. https://www.osha.gov/hazfinder/index.html OSHA has also developed an electronic health and safety program that is accessible on their website. The program contains some good information about identifying hazards and some control methods. Access the program below, and review the material. Occupational Safety and Health Administration. (2006). OSHA e-HASP software – version 2.0 (e-HASP2).

United States Department of Labor. https://www.osha.gov/dep/etools/ehasp/index.html

OSH 2303, Hazardous Materials Safety 1

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

2. Recognize common hazardous materials control technologies. 2.1 Summarize the requirements of the Occupational Safety and Health Administration (OSHA)

Hazardous Communication program that regulate the control of hazardous materials in the workplace.

2.2 Associate OSHA’s hierarchy of controls to the management of hazardous materials in a workplace.

Required Unit Resources Review Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 86–100 In order to access the following resources, click the links below. Review these recommended practices for safety and health programs from the U.S. Department of Labor on pp. 20–23 of the following publication. Occupational Safety and Health Administration. (2016). Recommended practices for safety and health

programs (OSHA Publication No. 3885). https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf

Learn more about the hierarchy controls by reviewing the following website. National Institute for Occupational Safety and Health. (2015). Hierarchy of controls. Centers for Disease

Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/ Review the following webpage to learn about chemical hazards and toxic substances. Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling

exposure. United States Department of Labor. https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html

Details of the Hazard Communication Standard are listed below. Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and

hazardous substances: Hazard communication (OSHA Standard No. 1910.1200). United States Department of Labor. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS

Unit Lesson

Hazardous Materials in the Workplace Hazardous materials in the workplace present some level of risk to occupants. The Occupational Safety and Health Administration (OSHA) requires employers to evaluate that level of risk using some type of risk assessment tool. When the level of risk associated with a chemical hazard is unacceptable, controls must be implemented to reduce the risk to an acceptable level. One approach to reducing the level of risk is making

UNIT III STUDY GUIDE Common Methods Used for Control of Hazardous Materials in the Workplace

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

sure that workers who have the potential for exposure are well-informed of the risk so they can take appropriate measures to protect themselves. The OSHA Hazard Communication (HazCom) Standard is designed to provide workers with the information they need to protect themselves from the risks associated with hazardous materials. The HazCom Standard was originally published in 1984 after 10 years of difficult rulemaking negotiations with industry and employee representative groups (OSHA, 2004). The original standard applied only to the manufacturing section, and in 1994, OSHA expanded the applicability of the standard to all employers. The standard remained essentially unchanged until the adoption of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in March 2012. Violations of the HazCom Standard have consistently been in the top 10 most-cited standards throughout its existence. The original standard was performance-based, meaning that many of the provisions stated the desired result but did not give details on how to get to that point. It allowed for much interpretation among employers, and OSHA compliance officers. Given the number of noncompliance citations issued over the years, it is obvious that the two groups often have different interpretations of the standard. Additional evidence of the disagreements and confusion can be found in the hundreds of letters of interpretation (LOI) that OSHA has issued about the standard. You can access the Standard Interpretations webpage to see the various interpretations. Two topics of the original standard that were performance-based and have been the source of much confusion and interpretation over the years are the sections on labeling and safety data sheets (SDSs), which were originally called material safety data sheets (MSDSs). Both have been changed to specification standards, meaning they leave less room for interpretation.

Hazardous Material Labels The HazCom Standard has always required chemical manufacturers and importers to label their hazardous material products. The first step in this process is to classify chemicals in accordance with the guidelines provided in Appendices A and B of the standard (OSHA, 1970b; OSHA, 1970c). Previously, hazard determination was left up to the manufacturer, and no specific criteria were provided. Also, prior to the 2012 revision, the requirements for labels included only the name and address of the manufacturer or importer, the identification of the chemical, and the appropriate hazard warnings (OSHA, 1970d). As one might expect, buying the same chemical from two different manufacturers would likely result in two different labels. Many employers began developing their own in-house labeling systems, or they used labels from the National Fire Protection Association (NFPA) or from the U.S. Department of Transportation (DOT). These actions helped with consistency, but whether they met the appropriate requirement was still open for interpretation. The DOT Chart 15: Hazardous Materials Markings, Labeling and Placarding Guide provides examples. The 2012 HazCom Standard resolved most of the labeling issues by prescribing specific information for all labels; these specifications have been listed below.

• Product identifier used on the SDS: The standard allows the chemical manufacturer to determine the identifier, but it must match the identifier used on the accompanying SDS.

• Signal word: Two signal words are prescribed: "Danger" is used for the most serious hazards, and "Warning" is used for less serious hazards. Only one signal word may appear on a label.

• Hazard statements: This is a brief description of the nature of the hazards of the chemical. • Precautionary statements: This is a recommended measure to minimize or prevent adverse effects.

Four types of precautionary statements are identified: prevention, response, storage, and disposal. • Pictograms: Nine graphic symbols are prescribed to identify specific hazard classes, but OSHA only

requires the use of eight of the symbols (the pictogram for an environmental hazard is not required). • Manufacturer information: Name, address, and telephone number of the chemical manufacturer or

importer must be included (OSHA, 2013a).

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

Standardized labeling requirements ensure that the same chemicals purchased from different manufacturers contain the same information in the same format, but OSHA still provides employers with some options. As noted earlier, in the 25 years since the first HazCom Standard was issued, much time and effort has been spent on developing these in-house systems, and many of them likely meet the intent of the HazCom Standard. OSHA recognizes this by allowing in-house labeling systems that meet the requirements of the 1994 HazCom Standard to remain in effect (OSHA, 2013a). That is good news for organizations that developed their own systems and those that sell OSHA-compliant labels; however, this is much like a performance standard and may be subject to interpretation.

SDSs Much has changed with MSDSs in the last 25 years. MSDSs evolved and became more standardized in format. They have been readily available in electronic versions and on the internet for more than 10 years. The OSHA HazCom Standard now prescribes a standard format of 16 sections to align with the GHS (OSHA, 2013b). The information on the SDSs, as they are now called, is essentially the same as the MSDS but is standardized across all workplaces.

• Section 1: Identification • Section 2: Hazard(s) • Section 3: Composition/Information on Ingredients • Section 4: First Aid Measures • Section 5: Fire Fighting Measures • Section 6: Accidental Release Measures • Section 7: Handling and Storage • Section 8: Exposure Controls/Personal Protection • Section 9: Physical and Chemical Properties • Section 10: Stability and Reactivity • Section 11: Toxicological Information

Sample HazCom label (OSHA, 2013a)

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

• Section 12: Ecological Information • Section 13: Disposal Considerations • Section 14: Transport Information • Section 15: Regulatory Information • Section 16: Other Information

OSHA does not require sections 13, 14, and 15 to be completed, but the Environmental Protection Agency (EPA) and the DOT regulations may require this information. The chemical manufacturer or importer preparing the SDS is required to make that determination. From a practical standpoint, the information in these sections would certainly help the employer with EPA and DOT compliance issues. The standard requires SDSs to be readily available to all employees on all work shifts. Over the years, OSHA has interpreted readily available to mean immediate and without delay (Haight, 2012). In addition, access to SDS information must not require assistance (e.g., requesting a copy from a supervisor or needing an intermediary to gain computer access for electronic versions). SDSs are required to be in English, but it makes sense to also make them, or the information they contain, available in all languages that are represented in the organization. Keep in mind that all employees have a right to know and understand the hazards of the chemicals with which they work. Even if only one employee speaks a language other than English, that one employee not understanding the hazards can create a dangerous situation for all employees. Even when all employees have been informed of the risks associated with the hazardous materials in the workplace, there may be risks associated with the hazardous materials that are unacceptable. The assessment of an unacceptable risk may come from workplace industrial hygiene sampling showing exposures exceeding the applicable OSHA permissible exposure limit (PEL) or from a workplace audit showing unacceptable risks of fire or explosion. In these cases, OSHA may require the employer to implement controls to reduce the risk(s). The National Institute for Occupational Safety and Health (NIOSH) and OSHA recommend the use of the hierarchy of controls when attempting to reduce the risks associated with hazardous materials (NIOSH, n.d.-b). One rendering of the hierarchy of controls is depicted below.

Do these workers know the hazards of the containers with which they are working? Are the containers clearly marked? Are they in compliance with the

HazCom Standard? (Henshall, 2008)

(NIOSH, n.d.-a)

OSH 2303, Hazardous Materials Safety 5

UNIT x STUDY GUIDE Title

The controls are arranged with the most effective controls at the top and the least effective controls at the bottom of the inverted pyramid. Elimination is the most effective control because it completely removes the hazardous materials from the workplace. Substitution also removes the hazardous materials from the workplace but substitutes another material that must then be evaluated for risk. Since these two controls remove the original hazardous materials from the workplace, they are often combined into one category called elimination/substitution. This control method may be the most effective, but it is also the most difficult to implement (NIOSH, n.d.-b). In many cases, a hazardous material is required to be used because of a chemical process or client specifications and no other hazardous materials will work. In those cases, elimination/substitution are not viable control methods. The next most effective control option involves the use of engineering controls. Note that engineering controls do not remove the hazardous materials from the workplace. Engineering controls reduce the potential for exposure to workers by reducing the amount (concentration) of the hazardous material that reaches the worker. Engineering controls can be very effective in reducing the risk associated with a hazardous material. One of the most important (and commonly used) engineering controls is ventilation (OSHA, 2017). The two most commonly used types of ventilation are general dilution ventilation and local exhaust ventilation systems. A general dilution ventilation system reduces the concentration of a hazardous material by introducing outside air that does not have the contaminant into the workplace air. A local exhaust ventilation system collects the air near the source and moves the contaminated air somewhere outside the work area where it may be filtered, treated, or simply released into the air outside the workplace. The type of ventilation system and the specifications for that system will vary depending on several variables including air concentrations, toxicity of the hazardous material, and physical characteristics of the workplace. Other examples of some commonly used engineering controls include the use of sound deadening materials around machines and lead-lined walls around ionizing radiation sources. Administrative controls are not as effective as engineering controls because they do not take any action to reduce the concentration of a hazardous material in the workplace. Instead, they change the way people work in order to reduce risk (NIOSH, n.d.-b). A good example of an administrative control is implementing a work/rest regimen to reduce the risks associated with heat extremes. By requiring workers in a hot environment to take periodic breaks of a specified duration and to take measures to rehydrate and cool, the risk of developing a heat illness can be reduced. The control measure that is the least effective is the use of personal protective equipment (PPE). The reason that PPE is the least effective is that it does not reduce the concentration of a hazardous material in the workplace. PPE merely blocks the hazardous material before the exposure occurs. Because of the many sources of leaks and malfunctions associated with PPE, the amount of protection claimed by PPE manufacturers may not be achieved in the actual workplace, and exposures may be higher than expected. Unfortunately, PPE is also one of the most commonly used control methods. When should PPE be used? OSHA (1970a) says PPE should be used when there is a hazard present capable of causing injury or impairment. However, OSHA requires the employer to attempt to reduce the risk to an acceptable level using more effective controls prior to using PPE as the primary control method (OSHA, n.d.). PPE can also be used to reduce risk during the time period when engineering and administrative controls are being implemented.

OSH 2303, Hazardous Materials Safety 6

UNIT x STUDY GUIDE Title

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

Safety Engineers. Henshall, G. (2008). FEMA - 39025 - EPA workers locating hazardous material moved by Ike in Texas

[Photograph]. Wikimedia Commons. http://commons.wikimedia.org/wiki/File:FEMA_-_39025_- _EPA_workers_locating_hazardous_material_moved_by_Ike_in_Texas.jpg

National Institute for Occupational Safety and Health. (n.d.-a). Hierarchy of controls [Image]. Centers for

Disease Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg

National Institute for Occupational Safety and Health. (n.d.-b). Hierarchy of controls: Overview. Centers for

Disease Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg

Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling

exposure. United States Department of Labor. https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html

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

protective equipment: General requirements (OSHA Standard No. 1910.132). United States Department of Labor. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9777&p_table=STANDARDS

Occupational Safety and Health Administration. (1970b). 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. (1970c). 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

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

hazardous substances: Allocation of label elements (OSHA Standard No. 1910.1200 App C). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.1200AppC

Occupational Safety and Health Administration. (2004). Hazard communication in the 21st century: History.

United States Department of Labor. https://www.osha.gov/dsg/hazcom/finalmsdsreport.html#history Occupational Safety and Health Administration. (2013a). Hazard Communication Standard: Labels and

pictograms (OSHA Brief No. DSG BR-3636). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3636.pdf

Occupational Safety and Health Administration. (2013b). Hazard Communication Standard: Safety data

sheets (OSHA Brief No. DSG BR-3514). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3514.pdf

Occupational Safety and Health Administration. (2017). Ventilation: Overview. United States Department of

Labor. https://www.osha.gov/SLTC/ventilation/index.html

OSH 2303, Hazardous Materials Safety 7

UNIT x STUDY GUIDE Title

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. One important task is identifying hazards in the workplace and performing a risk assessment for those hazards in order to evaluate the need for controls. The Occupational Safety and Health Administration (OSHA) has developed a tool to teach workers how to identify hazards in different workplaces. Access the website below, and use the tool to see if your skills at identifying hazards are up-to-date. Occupational Safety and Health Administration. (2017). Hazard identification training tool. United States

Department of Labor. https://www.osha.gov/hazfinder/index.html OSHA has also developed an electronic health and safety program that is accessible on their website. The program contains some good information about identifying hazards and some control methods. Access the program below, and review the material. Occupational Safety and Health Administration. (2006). OSHA e-HASP software – version 2.0 (e-HASP2).

United States Department of Labor. https://www.osha.gov/dep/etools/ehasp/index.html