hazard communication - frequently asked...

Guidance Document Revised 1/30/2017

Syracuse University Environmental Health and Safety Services

Hazard Communication - Frequently Asked Questions

This guidance document is designed to assist the University community in complying with the Occupational Safety & Health Administration’s (OSHA) Hazard Communication Standard as well as to identify “affected” employees covered by the Standard, EHSS is providing guidance in the form of Frequently Asked Questions. The guidance provided is based on OSHA “Letters of Interpretation” related to the Hazard Communication Standard. EHSS recognizes that OSHA does not typically exempt certain groups of employers or employees from the Standard. Ultimately, it is the employer’s responsibility to determine those employees who, in the normal course of business;

• may be “exposed” to “hazardous chemicals” under normal operating conditions (see definitions on

last page),

• may be exposed to a hazardous chemical in a reasonably “foreseeable emergency”, (see definitions),

and to ensure that those employees are trained and provided information on the hazardous chemicals in their workplace. To determine the applicability of the OSHA requirement for any given employee, the tasks performed by the employee must be evaluated and a determination made in accordance with the bulleted criteria above. Please be aware, when determining the applicability of this regulatory requirement for a group of employees, task variations between workers may not allow for a broad-based exclusion of a group. Individual employees from the group may be covered under the regulation.

It should be noted that an employee who uses a household consumer product (which could meet the definition of a “hazardous chemical”), in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience, has a right to know about the properties of the hazardous chemical and would need training.

1. Question: We only have a few hazardous chemicals in our department (e.g. kitchen countertop cleaner, glass cleaner, etc.). Do our employees need to be trained under the Hazard Communication Standard?

Answer: No, as long as the hazardous chemicals are used in a manner that results in an exposure of duration & frequency that is not greater than what a normal consumer would experience. But, if an employee uses the same material in a manner that would result in their exposure exceeding that of a normal consumer, training would be required (e.g. a custodian, a commercial kitchen food service employee, etc.).

2. Question: Is an employee in an “office” type setting required to complete Hazard Communication training?

Answer: No. The Standard does not apply to “office workers” who encounter hazardous chemicals only in non-routine, isolated instances. OSHA considers most office products (such as pens, pencils, adhesive tape, etc.) to be exempt under the provisions of the rule either as “articles” or “consumer products”. For example, intermittent or occasional use of an office copy machine does not require training. However, if




an employee handles the chemicals to service the machine, or operates it for long periods of time (e.g. copy center), employee Hazard Communication training is required.

3. Question: I have an employee that does not use hazardous chemicals, but as part of their duties must occasionally enter areas that use or store hazardous chemicals. Are they required to complete training?

Answer: Yes. An employee whose tasks require the employee to enter or work in settings in which hazardous chemicals are used or stored may be potentially exposed in an emergency or accidental chemical release.

4. Question: Do I have to determine who my “affected” employees are?

Answer: It is recommended that Supervisors make an appropriate determination. If you are a Supervisor and are unable to make a determination as to which employees are affected by the Hazard Communication Standard, please require all of your employees to complete “Basic” training to help ensure University compliance with the OSHA Standard.

5. Question: Do employees who recently attended Basic Hazard Communication training have to complete it again?

Answer: Employees trained after January 1, 2013 have received the updated training and do not need to complete it again. Basic Hazard Communication training status of individual employees can be accessed online at: http://ehosu.syr.edu/data/HazComComplianceStatus.asp

6. Question: What will my employee(s) learn in the Basic Hazard Communication training? They took the training years ago, why do they need to do it again?

Answer Part I: Employees will be educated on the concepts regarding hazardous chemical identification, labeling, use, exposure prevention, safety data sheets, and access to chemical information in the workplace.

Answer Part II: Recently, the United States Occupational Safety and Health Administration (OSHA) revised its Hazard Communication Standard to align with the United Nations Globally Harmonized System (GHS) of chemical classification and labeling of hazardous chemicals. The updated training incorporates the new GHS container labeling elements and Safety Data Sheet format. Employers must have their employees trained by December 1, 2013.

7. Question: How long will Basic Hazard Communication training take to complete?

Answer: Online training takes approximately 30 minutes to complete. Classroom training duration is approximately 30-45 minutes. Employees can sign up for classroom training at EHSS’s website:

http://ehosu.syr.edu/data/HazComComplianceStatus.asp




8. Question: I supervise employees covered by the Hazard Communication Standard. Do I need to complete training?

Answer: It is recommended that Supervisors of affected employees complete the Basic Hazard Communication Training. As a Supervisor you may have duties related to ensuring University compliance with the OSHA Hazard Communication Standard, such as providing affected employees with “Workplace Specific” Hazard Communication training, assuring assess to chemical safety data sheets, maintaining a chemical inventory, etc.

9. Question: How often is Hazard Communication training required?

Answer: Updated Basic Hazard Communication training is required to be completed once by all “affected” employees. Employees that have received Basic Hazard Communication training or Chemical Hygiene Plan training for laboratories after January 1, 2013 have already received the training update. However, “Workplace Specific” Hazard Communication training is required for:

• each instance a hazardous chemical is being introduced into a work area where the health and physical hazards for that chemical hazard class have not been presented to an employee in a previous workplace specific training

• each instance where a manufacturer provides an updated Safety Data Sheet which indicates a new or increased health or physical hazard

• each instance where a process/task involving a chemical has changed and the risk of exposure has increased.

Definitions

Exposure or Exposed Exposure or Exposed means that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential (e.g. accidental or possible) exposure. "Subjected" in terms of health hazards includes any route of entry (e.g. inhalation, ingestion, skin contact or absorption).

Foreseeable Emergency

Any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.

Hazardous chemical Any chemical alone or as a component of a mixture, which is classified as a physical hazard, health hazard, simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.




Health Hazard A chemical which is 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 (single or repeated exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A of OSHA’s Standard 29 CFR 1910.1200 - Health Hazard Criteria.

Physical Hazard

A chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas. (See 29 CFR 1910.1200 – Appendix A - Physical Hazard Criteria)

For more information please contact EHSS at 315-443-4132.

hazard communication - frequently asked...

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