Hazard CommunicationEmergency ResponseWSHSC

July 31, 2009

Employer Chemical Hazard Communication

WAC 296-800-170 “HazCom”

Four Major Parts:

1.MSDS

2.Labeling

3.Training

4.Written Program

Hazard Communication

Employees have the right to know about hazardous chemicals at their worksite:

What the chemicals are,

What are the hazards,

How to protect themselves.

This training will cover

What are hazardous chemicals

Exemptions

MSDSs

Labeling

Training

Written Program

What are hazardous chemicals? "Hazardous Chemical" is a term that is

broadly used in the hazard communication rule.

A hazardous chemical includes:– solvents – glues – paints – products that may release a hazardous

chemical.

What are hazardous chemicals? Flammables cause thermal burns or

death

Corrosives cause chemical burns to skin, eyes or lungs

Toxics cause reversible or permanent effects to internal organs or whole body

What are hazardous chemicals?

Sensitizers cause allergic response from repeated doses.

Irritants cause reversible effects.

Carcinogens cause cancer usually

over a long time.

What are hazardous chemicals?

Generally if an item is regulated by another federal rule it is not covered by hazard communication.

The following slides present items that may be exempted from the rule; please see WAC 296-800-17055 for the specific exemptions.

Exempted items – not covered

Hazardous waste

Articles (solid objects)

Most drugs

Food and alcoholic beverages

Exempted items – not covered

Cosmetics

Consumer products (most of the time)

Tobacco & tobacco products

Articles – when they are & are not covered

Article Not Covered

Covered

Brick used whole or intact

sawed or cut in half

Pipe bent with a tube bender

cut by a torch

Nylon rope

tying a knot burning the ends

HazCom Breakdown

Four Major Parts to the Standard:

•Material Safety Data Sheets (MSDSs)

•Labeling Chemical Containers

•Employee Training

•Written Program

Names of hazardous chemicals in a product,

Physical and chemical properties of the product,

Physical hazards of working with the product,

Short and long term health hazards of working with the product (including signs and symptoms of overexposures),

MSDSs – what information do they have?

Acetone

Flammable & highly volatile

Burns

Headaches, eye irritation

42

Material Safety Data Sheet• The main way the chemical enters the body,

• The legal limit allowed in the air

• If the chemical is a carcinogen

• Precautions for safe use of the hazardous chemical,

Inhalation

750 ppm

No

Adequate ventilation, keep away from open

flame

Material Safety Data Sheet• Exposure control methods, including personal protective equipment,

• Emergency and first aid procedures,

• The date the MSDS was prepared or revised,

• Name, address and phone number of the person responsible for the information in the MSDS.

Wear respirator, rubber gloves

Eyes: flush with water for 15 minutes

1996

John Doe 1234 Maple St.

Anywhere, USA

Trade Secrets Manufacturer can withhold name of

specific chemicals in a product

Hazard information must still be disclosed in MSDS

In emergencies name of chemical must be disclosed for medical treatment

Disclosure also required if written request made for certain purposes

Labels Chemicals Labeled with the

Following:

– Identity of hazardous chemical

– Hazard warnings including health effects

Labels

Labels NOT required if the product:

– Will be used in same work shift

– Is used by person who did the transfer

– Is under the control of the person who did the transfer

Training What hazardous chemicals are used in the work

area How to work safely with these chemicals How the employee can tell if he or she is being

overexposed What information is available in a material safety

data sheet (MSDS) Where to find MSDSs in the work area Information on the requirements of the Employer

Chemical Hazard Communication Rule

Training and InformationEmployees must be trained on how to work safely with hazardous chemicals. This includes the things you have done to protect employees including:

•Engineering controls, •Work practices •Emergency Procedures •Personal Protective equipment•The labeling system you use •How to find information on the hazards in the material safety data sheet or label.

Employees must be trained on the methods used to detect the presence or release of hazardous chemicals in the work area. Air monitoring Continuous monitoring devices The visual appearance or odor of the

chemical The physical and health hazards of the

hazardous chemical

Hazard Communication Program

– Identify hazardous chemicals and make a list

– Obtain MSDSs for each product

– Make MSDSs easily accessible

– Ensure containers are labeled

– Develop a written program

– Ensure effective training

Hazard Communication - Special Situation

If only sealed containers are handled:

No written program required

Keep MSDSs if received

Existing labels must be intact

Spill or leak response training required

Hazard Communication - Written program

Tailored to the worksiteList of hazardous chemicalsLabelingMSDSsTrainingNon-routine tasksMulti-employer worksites (if needed)

HazCom – Multi-employer Worksites– Several employers at one site

– More than one employers’ employees are visiting/working

– Mutual responsibility to share information

– Not just construction sites (janitorial, pest control, maintenance contractors)

Emergency Response (WAC 296-824)

Emergency Response

A response to an anticipated release of a hazardous substance that is, or could become, an uncontrolled release

Hazardous Substance

Any biological, radiological, or chemical substance that can have adverse effects on humans (see WAC 296-824-800 for a more specific definition).

Uncontrolled Release A release where significant safety

and health risks could be created. Releases of hazardous substances that are either incidental or couldn't create a safety or health hazard (i.e., fire, explosion, or chemical exposure) aren't considered to be uncontrolled releases.

Incidental Release

A release that can be safely controlled at the time of the release and does not have the potential to become an uncontrolled release.

Danger Area Areas where conditions pose a serious danger to

employees, such as areas where: Immediately dangerous to life or health (IDLH)

conditions could exist High levels of exposure to toxic substances could exist There is a potential for exceeding the lower explosive

limit (LEL), also known as the lower flammability limit (LFL), of a substance.

IDLH

Any atmospheric condition that would:

Cause an immediate threat to life Cause permanent or delayed

adverse health effects Interfere with an employee's ability

to escape

Limited Action Action necessary to: Secure an operation during emergency

responsesor

Prevent an incident from increasing in severity. Examples include shutting down processes

and closing emergency valves.

NIOSH Pocket Guide to Chemical Hazards

IDLH of Formaldehyde is 20 ppm Formaldehyde has a low vapor

pressure Dependant on size of room,

ventilation rate, and surface area of the spill

Basic Requirements

Written Emergency Response Plan Training Responders Medical Surveillance Recordkeeping Management of Emergency Operations Incident Command Personnel Briefing

Basic Requirements, Cont..

Buddy System = 2 In and 2 Out Rescue and Medical Assistance Personal Protective Equipment Post Emergency Response

Operations

Common Findings No plans There doesn’t appear to be any clear

roles or assigned duties. Responders have not received adequate

training No procedures for limited actions Personal Protective Equipment No Command Structure

Key Questions

Are employees expected to participate in an emergency response?

Is the facility covered by community emergency response plan?

Key Points

Emergency response is not defined by the quantity of hazardous substance or the level of PPE. It depends on the danger and the safety and health risk the release may pose to employees.

Key Points

The level of training depends on the role employees will be expected to play in the event of an emergency response.

Key Points

All emergency response personnel must receive annual refresher training.

Key Points

The emergency response planning and procedures is to be based on the worst case scenarios.

Key Points

Selection of PPE is to be based on the worst case scenarios.

Key Points

The emergency response plan and procedures is to be site specific.

Compliance Issues/Recommendations

Use Small Containers of Formaldehyde– Prefilled containers for Specimens

Proper Amount of Absorbent MSDS for concentration used Clearly Define Roles for a Spill

– Who responds, who evacuates

Compliance Issues/Recommendations

Badge Sampling– Methanol Mixed with Formaldehyde– Methanol Interferes with Sample– 35% Below Actual Exposure

Directives and Other Assistance WRD 12.75 – Emergency Response to Hazardous

Substance Releases WRD 10.6 – 1994 NIOSH Pocket Guide IDLH Values WRD 32.99 – Post Emergency Oil Spill Response

Operations The United States Department of Transportation's

Emergency Response Guidebook (search at: http://www.dot.gov).

Directives and Other Assistance, Cont. WISHA Helpful Tools – Developing

Emergency Response Plans National Fire Protection Association

(NFPA) – A variety of standards and guides for emergency response activities.