Study guide due sunday price is firm

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 3 criteria for a confined space

 Large enough for an employee

 Limited entry or exit

 Not designed for continuous occupancy

 Examples of confined spaces

 Hazards in confined spaces

 Atmospheric

 Engulfment

 Entrapment/ asphyxiation

 Other serious

 NIOSH FACE cases

 Confined space safety

 Confined space hazard analysis

 Confined space entry procedures

 Work permit

 Entrant training

 Confined space rescue

 Hierarchy of rescue

 Hazard control options

 Ventilation

 Atmospheric testing

 Respiratory protection

EHST 3900:

Introduction to

Occupational Health

 To discuss the role of hazard

communication in a workplace safety and

health program

 To describe the three major components

of a hazard communication program

 Role of Hazard Communication in the

Workplace

 History of the Development of Legal

Requirements for Hazard Communication

 Federal Hazard Communication Standard No adequate information about hazards

Impossible for OH professionals to design or

implement an appropriate protective program

for exposed employees

Effective hazard communication is

a cornerstone of a comprehensive

safety and health management.

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Providing information to

employees and OHS

professionals

Empowerment of employees

to be active participants in an

employer’s safety and health

program

Information about the

chemicals in their workplaces

Actions of informed

employers and employees

Reducing the potential for illnesses and

injuries

Accomplishing the underlying purpose of

the federal hazard communication

standard (HCS)

 Before the 1980s: Considerable amount of

time spent researching the hazards of the

chemicals in the workplaces

 Some chemical manufacturers voluntarily

transmitted information about their products

through labels and material safety data

sheets.

 More often, OHS professionals had to obtain

the most basic information about products of

concern (e.g. proprietary mixtures).

 1980s: Worker right-to-know movement

 Worker representatives successfully lobbied

state and federal government authorities.

 Workers: apprised of their potential

hazards and appropriate precautionary

measures

 OHS professionals: aware of hazardous

chemicals in the workplaces  easier task

of improving overall protection

 19th century: Chemists often provided users

with notes regarding chemical properties and

safety considerations.

 Early 20th century: Labels have been

accepted business practice in the chemical

industry for many years

 1949: Manufacturing Chemists’ Association

made MSDSs available.

 Prior to 1960s: Providing information about

hazardous chemicals were voluntary on the

part of manufacturers.

 Late 1960s: Bureau of Labor Standards

adopted requirements for MSDSs in the

maritime industries.

 Early 1970s

 Standards were adopted by OSHA

 Developed a two-page format (OSHA Form

20) that was used for many years to provide

MSDS information in the maritime

industries

MSDS

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 OSH Act of 1970  Section 6(b)(7)

 Inclusion of any substance-specific

standard addressing toxic substances

provisions

 To prescribe “the use of labels or other

appropriate forms of warning as are

necessary to insure that employees are

apprised of all hazards to which they are

exposed, relevant symptoms and

appropriate emergency treatment, and

proper conditions and precautions of safe

use.”

 addressed labeling of chemicals in the

rulemaking authority for the agency. Under

Section 6(b)(7) OSHA was required to include

in any substance-specific standard addressing

toxic substances provisions to prescribe “the

use of labels or other appropriate forms of

warning as are necessary to insure that

employees are apprised of all hazards to

which they are exposed, relevant symptoms

and appropriate emergency treatment, and

proper conditions and precautions of safe

use.”

 1975: OSHA-formed Standards Advisory

Committee completed their report

 Suggested a standard with requirements for

classifying chemicals as to their hazards,

labels, MSDSs, and training

 1975: NIOSH provided a criteria document

with similar recommendations: a standard

including

 Hazard classification

 Labels

 MSDSs

 Training

 1977: Published advance notice of

proposed rulemaking to elicit public

comments

 January 1981: Published a proposed

standard titled Hazards Identification

(Carter administration)

 Diverged from original OSHA

recommendations

 Addressed only hazard classification and

labeling

 No MSDSs or training requirements

 February 1981: The chemical industry

objected to many of the proposed

requirements

 New Reagan administration withdrew

the proposal for further consideration of

regulatory alternatives.

 State standards covered:

 Different chemicals

 Different employers

 Requirements for disclosing information

Employee representatives

lobbying state governments for

standards

Requirements for shipping

chemicals around the US

 March 1982: OSHA introduced a new proposed

standard.

 November 1983: OSHA completed rulemaking by

issuing a final standard.

 Comprehensive in its coverage of chemicals and hazards

 Limited to the manufacturing sector

 1987: OSHA was ordered to expand the scope of

the standard to cover all employers.

 August 1987: OSHA published a 2nd final rule to

comply with this order.

 February 1994: 3rd final rule with relatively

minor modifications was published.

 March 2012: 4th final rule on adapting GHS

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 General industry standard

 29 CFR 1910.1200

 Construction industry

 29 CFR 1926.59

 Agriculture industry

 29 CFR 1928.21

 Maritime industries

 29 CFR 1915.1200

 29 CFR 1917.28

 29 CFR 1918.90

http://www.osha.gov/dsg/hazcom/index.html

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 Paragraph (a): Purpose

 Paragraph (b): Scope and Application

 Paragraph (c): Definitions

 Paragraph (d): Hazard Classification

 Paragraph (e): Written Hazard Communication

Program

 Paragraph (f): Labels and Other Forms of Warning

 Paragraph (g): Safety data sheets

 Paragraph (h): Employee Information and Training

 Paragraph (i): Trade Secrets

 Paragraph (j): Effective dates

 Revised to comply with the Globally

Harmonized System of Classification and

Labeling of Chemicals (GHS)

 To provide a more unified international

harmonized system of standards to:

 Inform people about chemicals present in

their workplace and other environments

 Classify chemicals according to their hazard

 Create a labeling system based on

pictograms that are more universally

understood

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 International approach to hazard

communication, providing:

 Agreed criteria for classification of

chemical hazards

 Standardized approach to label elements

and safety data sheets

 Based on major existing systems around the

world (e.g. OSHA's Hazard Communication

Standard)

 Chemical manufacturers and importers

are responsible for evaluating the hazards

of the chemicals they produce or import.

 What is in the product

 Characteristics of the product

 Hazards associated with it

 Precautionary measures for hazards

 Chemical hazards will be determined by

chemical manufacturers and importers.

 Standard updates:

 Provided specific criteria for health and

physical hazards

 Provided classification of chemical mixtures

• Health hazard

• Physical hazard

• *Environmental hazard

 Health hazard

 Chemical classified as posing one of the

following hazardous effects

 Acute Toxicity (any route of exposure)

 Skin corrosion or irritation

 Serious eye damage or eye irritation

 Respiratory or skin sensitization

 Germ cell mutagenicity

 Carcinogenicity

 Reproductive toxicity

 Specific target organ toxicity

 Aspiration hazard

 Physical hazard

 Chemical classified as posing one of the

following hazardous effects:

 Explosive

 Flammable

 Oxidizer

 Self-reactive

 Pyrophoric

 Self-heating

 Organic peroxide

 Corrosive to metal

 Gas under pressure

 In contact with water emit flammable gas

 Purposes: To coordinate the hazard communication

activities in the workplace and ensure that they

are addressed in a comprehensive and consistent

manner

 What is covered?

 How are activities implemented?

 Who is responsible for the various components?

Employers with hazardous chemicals in

their workplaces are required to

develop, implement, and maintain a

written hazard communication program.

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1. Labels

2. Safety data sheets (SDSs)

3. Employee training

 HCS requires chemical manufacturers, importers, and distributors to ensure that shipped containers of hazardous chemicals are labeled with the  Identity of the material

 Appropriate hazard warnings

 Name and address of the chemical manufacturer, importer, or other responsible party

 Label must contain the identity of the

chemical and the appropriate hazard warning

 Old HCS: No specified method of displaying

information

 Revised HCS: Specifies what information to

provide

 Pictogram

 Signal words

 Hazard statement

 Precautionary statement

 A symbol plus other graphic elements (e.g.

border, background pattern, color) intended

to both alert people to and convey specific

information about the hazards of the

chemical

 Consists of a symbol of a white background

with a red square frame set on a point

 Carcinogen

 Mutagenicity

 Reproductive toxicity

 Respiratory sensitizer

 Target organ toxicity

 Aspiration toxicity

 Flammables

 Pyrophorics

 Self-heating

 Emits flammable gas

 Self-reactives

 Organic peroxides

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 Irritant (skin and eye)

 Skin sensitizer

 Acute toxicity

 Narcotic effects

 Respiratory tract irritant

 Hazardous to ozone layer

 Skin corrosion/ burns

 Eye damage

 Corrosive to metals

 Acute toxicity

(fatal or toxic)

 Gases under pressure

 Oxidizers

 Explosives

 Self-reactives

 Organic peroxides

 Aquatic toxicity

 Non-mandatory

 A single word used on the label to alert

people to the relative level of severity of the

hazard

 Danger

 Warning

 A statement assigned to a hazard class and

category that describes the nature of the

hazard(s) of a chemical, including, where

appropriate, the degree of the hazard

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 A phrase that indicates recommended

measures to be taken to minimize or prevent

adverse effects resulting from

 Exposure to a hazardous chemical

 Improper storage or handling of a

hazardous chemical

Pictogram

Signal words

Hazard

statement

Precautionary

statement

Health Hazard Physical Hazard Environmental

Hazard  HNOC – Hazards Not Otherwise Classified

 Not required to be disclosed on the label

 Required to be disclosed on Section 2 of the

Safety Data Sheets (SDS)

Chemical manufacturers

Chemical importers

Chemical distributors

Employers

Significant information regarding the

hazard of a chemical

Required to revise the label for the

chemical within 6 months of becoming

aware of the new information

 Labels can convey only a limited amount of

information due to space considerations.

 The more information there is on a label, the

less likely it is that people will read and act

on it.

 Labels do not function well in most situations

as the only source of information.

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 Labels are an abbreviated source of

information about hazards.

 More information is available through

SDSs.

 Both label and SDS information are

reinforced by training.

 HCS allows alternative forms of warning to

suffice in lieu of an actual label for

stationary process containers.

 As long as the information is readily

accessible and clearly identifies the

containers to which it applies.

 Include signs, placards, batch tickets, and

similar means of conveying the information

in writing

 Detailed reference source that includes all

pertinent information on a chemical, its

characteristics, and ways to handle it safely

 Referred to by exposed employees when they

need additional information

 Reference documents for the employer and

OHS professionals who provide services to

the employee and the employer

 Used by emergency responders, physicians,

occupational health nurses, safety engineers,

and industrial hygienists to perform their

work

 Chemical manufacturers and importers 

primarily responsible for the development

and dissemination of SDSs

 Employers  required to have one for each

hazardous chemical in the workplace

 HCS design: downstream flow of information

Producers of

the chemical

Distributors

Ultimate user

 For consistency, the revised SDSs include 16 specific sections that must

be completed.

 Gradually replace the current MSDS based format

1. Identification

2. Hazard(s) identification

3. Composition / information on ingredients

4. First aid measures

5. Fire-fighting measures

6. Accidental release measures

7. Handling and storage

8. Exposure controls/ personal protection

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological information

12. Ecological information

13. Disposal considerations

14. Transport information

15. Regulatory information

16. Other information (including date of preparation or last revision)

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 Employees must be able to consult the SDS

for necessary information at any time during

the workday.

 Electronic access is permitted as long as

there is no barrier to obtaining the

information.

SDSs are to be readily accessible to

employees when they are in their

work areas during the work shift.

 Important in communication of the

information via labels and SDSs

 Ensures that employees

 Understand the information presented

to them in written form

 Have an opportunity to clarify it

 Know where they can obtain additional

information if necessary

 Performance-oriented

 Employer is free to choose the method of

delivery (e.g. lecture, interactive

computer, or videotape)

 Purchased program + site-specific info

 No training records are required to

document individual employee

participation in training

 Documentation is encouraged.

1. Simple presentation of information

(passive)

2. Training (active)

1. Simple presentation of information

 Requirements of the HCS

 Location of hazardous chemicals in their

work areas

 Location and availability of the written

hazard communication program

 Location and availability of the SDSs

2. Training

 A more active process designed to

ensure that the employee knows and

understands the information being

transmitted

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2. Training

 Employees must be trained on

 How they can detect the presence of

hazardous chemicals in their workplace

 The physical and health hazards of the

chemicals

 The measures they can take to protect

themselves

 The details of the employer’s hazard

communication program

 Required on the

 New label elements

 Safety data sheet format

 by December 1, 2013

 Specific chemical identity of a chemical may

be withheld if it is a bona fide trade secret.

 HCS appendix providing the types of

characteristics that qualify a hazardous

chemical identity as a trade secret

 Research or extensive developmental processes

were required to discover the product or its uses

 Extraordinary means have been undertaken to

keep the identity secret

 Analytical process not simple for someone

wishing to reverse engineer the product and

determine the secret

 Identity maintained as a trade secret if it

meets the tests for establishing a trade

secret

 Protection of exposed workers must be the

ultimate concern even for a trade secret.

 HCS requires disclosure of the identity when

there is an occupational health need for the

information.

 Holder of the secret may require the

requester to sign a confidentiality

agreement.

 Dec. 1, 2013  Employers must train employees on the new label

elements and SDSs format

 June 1, 2015  Chemical manufacturers, importers, distributors and

employers must comply with all modified provisions of the final rule.

 Dec. 1, 2015  Chemical distributors must begin shipping containers

labeled by the chemical manufacturer or importer with a revised hazcom label.

 June 1, 2016

 Employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional employee training for newly identified physical or health hazards.

 A properly implemented hazard communication

program can form the basis for a comprehensive

safety and health program in the workplace.

 It provides the information needed to design

appropriate protective measures.

 Each employer with hazardous chemicals in the

workplace must have a written hazard

communication program.

 Chemical containers must be labeled, SDSs must

be available for each hazardous chemical in the

workplace, and employees must be trained

about the hazards and how to obtain and use the

hazard information.