ISCOSA TRAINING CENTER

OCCUPATIONAL SAFETY AND HEALTH

MANAGEMENT - OSHA

LESSON 12
HAZARD COMMUNICATION
Chemical in the Workplace

About 32 million workers are potentially exposed to one or more chemical hazards.
There are an estimated 575,000 existing chemical products, and hundreds of new ones
being introduced annually. This poses a serious problem for exposed workers and
their employers.

Chemical exposure may cause or contribute to many serious health effects such as
heart ailments, kidney and lung damage, sterility, cancer, burns, and rashes. Some
chemicals may also be safety hazards and have the potential to cause fires and
explosions and other serious accidents.

Because of the seriousness of these safety and health problems, and because many
employers and employees know little or nothing about them, the Occupational Safety
and Health Administration (OSHA) has issued a rule called "Hazard Communication."
The basic goal of the standard is to be sure employers and employees know about
work hazards and how to protect themselves; this should help to reduce the incidence
of chemical source illness and injuries.

The Hazard Communication Standard establishes uniform requirements to make sure

that the hazards of all chemicals imported into, produced, or used in U.S. workplaces
are evaluated, and that this hazard information is transmitted to affected employers
and exposed employees.

Hazard Evaluation

The quality of the hazard communication program depends on the adequacy and
accuracy of the hazard assessment. Chemical manufacturers and importers are
required to review available scientific evidence concerning the hazards of the
chemicals they produce or import, and to report the information they find to their
employees and to employers who distribute or use their products. Downstream
employers can rely on the evaluations performed by the chemical manufactures or
importers to establish the hazards of the chemicals they use.
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The chemical manufacturers, importers, and any employers who choose to evaluate
hazards are responsible for the quality of the hazard determinations they perform.
Each chemical must be evaluated for its potential to cause adverse health effects and
its potential to pose physical hazards such as flammability. (Definitions of hazards
covered are included in the standard.) Chemicals that are listed in one of the
following sources are to be considered hazardous in all cases:

! 29 CFR 1910, Subpart Z, Toxic and Hazardous Substances, Occupational

Safety and Health Administration, (OSHA) and
! Threshold Limit Values for Chemical Substances and Physical Agents in the
Work Environment, American Conference of Governmental Industrial
Hygienists (ACGIH).

In addition, chemicals that have been evaluated and found to be a suspect or confirmed
carcinogen in the following sources must be reported as such:
! National Toxicology Program (NTP), Annual Report on Carcinogens,
! International Agency for Research on Cancer (IARC), Monographs, and
! Regulated by OSHA as a carcinogen.

Written Hazard Communication Program

Employers must develop, implement, and maintain at the workplace a written,

comprehensive hazard communication program that includes provisions for container
labeling, collection and availability of material safety data sheets, and an employee
training program. It also must contain a list of the hazardous chemicals in each work
area, the means the employer will use to inform employees of the hazards of non-
routine tasks (for example, the cleaning of reactor vessels), and the hazards associated
with chemicals in unlabeled pipes. If the workplace has multiple employers on-site
(for example, a construction site), the rule requires these employers to ensure that
information regarding hazards and protective measures be made available to the other
employers on-site, where appropriate.

The written program does not have to be lengthy or complicated, and some employers
may be able to rely on existing hazard communication programs to comply with the
above requirements. The written program must be available to employees, their

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designated representatives, the Assistant Secretary of Labor for Occupational Safety
and Health, and the Director of the National Institute for Occupational Safety and
Health (NIOSH).

Labels and Others Forms of Warning

Chemical manufacturers, importers, and distributors must be sure that containers of

hazardous chemicals leaving the workplace are labeled, tagged or marked with the
identity of the chemicals, appropriate hazard warnings, and the name and address of
the manufacturer or other responsible party.

In the workplace, each container must be labeled, tagged or marked with the identity
of hazardous chemicals contained therein, and must show hazard warnings appropriate
for employee protection. The hazard warning can be any type of message, words,
pictures, or symbols that convey the hazards of the chemical(s) in the container.
Labels must be legible, in English (plus other languages, if desired), and prominently
displayed.

Exemptions to the requirement for in-plant individual container labels are as follows:
! Employers can post signs or placards that convey the hazard information if
there are a number of stationary containers within a work area that have
similar contents and hazards.
! Employers can substitute various types of standard operating procedures,
process sheets, batch tickets, blend tickets, and similar written materials for
container labels on stationary process equipment if they contain the same
information and are readily available to employees in the work area.
! Employers are not required to label portable containers into which hazardous
chemicals are transferred from labeled containers and that are intended only
for the immediate use of the employee who makes the transfer.
! Employers are not required to label pipes or piping systems.

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Fig. 12-1.

Other Warning Signs

Fig. 12-2.

Material Safety Data Sheets

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Chemical manufacturers and importers must develop an MSDS for each hazardous
chemical they produce or import, and must provide the MSDS automatically at the
time of the initial shipment of a hazardous chemical to a downstream distributor or
user. Distributors must also ensure that downstream employers are similarly provided
an MSDS.

Each MSDS must be in English and include information regarding the specific
chemical identity of the hazardous chemical(s) involved and the common names. In
addition, information must be provided on the physical and chemical characteristics of
the hazardous chemical; known acute and chronic health effects and related health
information; exposure limits; whether the chemical is considered to be a carcinogen by
NTP, IARC, or OSHA; precautionary measures; emergency and first-aid procedures;
and the identification of the organization responsible for preparing the sheet.

Copies of the MSDS for hazardous chemicals in a given work site are to be readily
accessible to employees in that area. As a source of detailed information on hazards,
they must be located close to workers, and readily available to them during each
workshift.

A copy of the non-mandatory MSDS form (OSHA 174) can be obtained from OSHA
field offices.

List of Hazardous Chemicals

Employers must prepare a list of all hazardous chemicals in the workplace. When the
list is complete, it should be checked against the collected MSDS's that the employer
has been sent. If there are hazardous chemicals used for which no MSDS has been
received, the employer must write to the supplier, manufacturer, or importer to obtain
the missing MSDS. If employers do not receive the MSDS within a reasonable period
of time, they should contact the nearest OSHA office.

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Employee Information and Training

Employers must establish a training and information program for employees exposed
to hazardous chemicals in their work area at the time of initial assignment and
whenever a new hazard is introduced into their work area.

Information
At a minimum, the discussion topics must include the following:

! The existence of the hazard communication standard and the requirements of

the standard.
! The components of the hazard communication program in the employees'
workplaces.
! Operations in work areas where hazardous chemicals are present.
! Where the employer will keep the written hazard evaluation procedures,
communications program, lists of hazardous chemicals, and the required
MSDS forms.
Training
The employee training plan must consist of the following elements:

! How the hazard communication program is implemented in that workplace,

how to read and interpret information on labels and the MSDS, and how
employees can obtain and use the available hazard information.
! The hazards of the chemicals in the work area. (The hazards may be
discussed by individual chemical or by hazard categories such as
flammability.)
! Measures employees can take to protect themselves from the hazards.
! Specific procedures put into effect by the employer to provide protection
such as engineering controls, work practices, and the use of personal
protective equipment (PPE).
! Methods and observations--such as visual appearance or smell--workers can
use to detect the presence of a hazardous chemical to which they may be
exposed.

Trade Secrets

A "trade secret" is something that gives an employer an opportunity to obtain an

advantage over competitors who do not know about the trade secret or who do not use
it. For example, a trade secret may be a confidential device, pattern, information, or
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chemical make-up. Chemical industry trade secrets are generally formulas, process
data, or a "specific chemical identity." The latter is the type of trade secret
information referred to in the hazard communication standard. The term includes the
chemical name, the Chemical Abstracts Services (CAS) Registry Number, or any
other specific information that reveals the precise designation. It does not include
common names.

The standard strikes a balance between the need to protect exposed employees and the
employer's need to maintain the confidentiality of a bona fide trade secret. This is
achieved by providing for limited disclosure to health professionals who are furnishing
medical or other occupational health services to exposed employees, employees and
their designated representatives, under specified conditions of need and
confidentiality.

Medical Emergency

The chemical manufacturer, importer, or employer must immediately disclose the

specific chemical identity of a hazardous chemical to a treating physician or nurse
when the information is needed for proper emergency or first-aid treatment. As soon
as circumstances permit, the chemical manufacturer, importer, or employer may obtain
a written statement of need and a confidentiality agreement.

Under the contingency described here, the treating physician or nurse has the ultimate
responsibility for determining that a medical emergency exists. At the time of the
emergency, the professional judgement of the physician or nurse regarding the
situation must form the basis for triggering the immediate disclosure requirement.
Because the chemical manufacturer, importer, or employer can demand a written
statement of need and a confidentiality agreement to be completed after the emergency
is abated, further disclosure of the trade secret can be effectively controlled.

Non-Emergency Situation

In non-emergency situations, chemical manufacturers, importers, or employers must

disclose the withheld specific chemical identity to health professionals providing
medical or other occupational health services to exposed employees, and to employees
and their designated representatives, if certain conditions are met. In this context,

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"health professionals" include physicians, occupational health nurses, industrial
hygienists, toxicologists, or epidemiologists.
The request for information must be in writing and must describe with reasonable
detail the medical or occupational health need for the information. The request will be
considered if the information will be used for one or more of the following activities:

 To assess the hazards of the chemicals to which employees will be exposed.

 To conduct or assess sampling of the workplace atmosphere to determine employee
exposure levels.
 To conduct pre-assignment or periodic medical surveillance of exposed employees.
 To provide medical treatment to exposed employees.
 To select or assess appropriate personal protective equipment for exposed
employees.
 To design or assess engineering controls or other protective measures for exposed
employees.
 To conduct studies to determine the health effects of exposure.

The health professional, employee, or designated representative must also specify why
alternative information is insufficient. The request for information must explain in
detail why disclosure of the specific chemical identity is essential, and include the
procedures to be used to protect the confidentiality of the information. It must include
an agreement not to use the information for any purpose other than the health need
stated or to release it under any circumstances, except to OSHA.

The standard further describes in detail the steps that will be followed in the event that
an employer decides not to disclose the specific chemical identity requested by the
health professional, employee, or designated representative.

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