osha compliance and workplace safety - carwash€¦ · · 2015-04-21presented by: max muller osha...

Presented by: Max Muller

OSHA Authorized General Industry Outreach Trainer

OSHA Compliance

and Workplace

Safety

OSHA Compliance and Workplace Safety |

© 2015 Max Muller 2

Table of Contents

Session Objectives………………………………………………… 3

The Act’s Coverage...................………………………………….. 4

General Duty Clause……………………………………….……… 5

Employees………………………………………………..………… 6

Suggested Outside Contractor Terms and Conditions………… 7

Reporting versus Recording………………………………………. 10

Written Hazard Communication Program.………………………. 11

Chemical Inventory………………………………...………………. 12

Safety Data Sheets (SDS) ………………………………………… 13

Labeling and Other Forms of Warning…....……………………… 23

Pictograms……………………………...…....……………………… 24

Employee Information and Training….…………………………… 25

Job Safety Analysis (JSA)……………………………………..…... 26

Simple Analysis Worksheet………………………………………... 27

Exercise for Your Employees……………………………………… 28

Basic Accident Types………………………………………………. 30

Exercise Sheet………………………………………………………. 31

Appendix – Sample OSHA Shipping Label………………………. 32



Session Objectives This OSHA Compliance and Workplace Safety session provides participants with an understanding of significant occupational safety and health issues (regulations) applicable to the car wash industry. Session will cover

Disclaimer: Any advice and/or suggestions made by the International Car Wash Association, Max Muller personally, Max Muller & Associates LLC or anyone representing or affiliated with them should not be construed as constituting legal advice in any manner or form. Legal information is not the same as legal advice and in no event shall the International Car Wash Association, Max Muller personally, Max Muller & Associates LLC or any of their representatives or affiliates be liable for any actual damages, lost profits or any special, incidental, or consequential damages and/or attorney’s fees arising out of or in connection with any of the information or training provided by them individually or collectively. Always seek advice on legal matters from your own attorney.

The Act's Coverage

→ Applicability of the OSH Act → Impact of the General Duty Clause → Duties in multi-employer situations → Reporting versus recording → HAZCOM transition to GHS → Job Safety Analysis (JSA)



Federal

State Twenty-six states have approved programs – everyone, including public service workers, is covered

NOTE: The Connecticut, Illinois, New Jersey, New York and Virgin Islands plans cover public sector (State & local government) employment only. Any employer employing one or more employees would be an "employer engaged in a business affecting commerce who has employees" and, therefore, he is covered by the Act as such. 29 CFR 1975.4(a)

Alaska New Mexico

Arizona New York

California North Carolina

Connecticut Oregon

Hawaii Puerto Rico

Indiana South Carolina

Illinois Tennessee

Iowa Utah

Kentucky Vermont

Maryland Virginia

Michigan Virgin Islands

Minnesota Washington

Nevada Wyoming

New Jersey

Includes:

Employers in all 50 states

District of Columbia

All territories under federal government control

All federal government worksites and military installations

All employers with one or more employees Excludes:

Self-employed individuals without employees

Family farms at which only family members work

Topic areas where other federal statutes take precedence

States and political subdivisions of a state



General Duty Clause OSH Act, Sec. 5. Duties a. Each employer --

1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

2) shall comply with occupational safety and health standards promulgated

under this Act. b. Each employee shall comply with occupational safety and health standards

and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

Impact of the General Duty Clause Sec. 5(a)(1)

“recognized hazards” OSHA inspectors may issue a citation under the General Duty Clause (GDC)

when the following criteria are met:

There is no applicable OSHA standard.

The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed.

The hazard is or should have been recognized (foreseeable) by the employer.

The hazard is causing or was likely to cause death or other serious physical harm.

There is a feasible and useful method to correct the hazard.



Employees An employee is anyone who works on behalf of the employer, whether paid or not. Employment Environments

Dual employment

Key issue: who controls the means, methods, procedures, equipment, timing, sequencing and outcome of the job on a daily basis?

Multi-Employer Worksites (CPL 2-0.124)

Creating Employer: The employer who actually creates the hazard

Exposing Employer: Employers whose employees are exposed to hazards

Correcting Employer: The employer who has the responsibility for actually correcting the hazard

Controlling Employer: The employer who is responsible, by contract or through actual practice, for safety and health conditions on the worksite, i.e., the employer who has the authority for ensuring that the hazardous condition is corrected

Protecting Your Organization

Citation will not be issued if:

The employer did not create the hazard;

The employer did not have the responsibility or the authority to have the hazard corrected;

The employer did not have the ability to correct or remove the hazard;

The employer can demonstrate that the creating, the controlling and/or the correcting employers, as appropriate, have been specifically notified of the hazards to which his/her employees are exposed;

The employer has instructed his/her employees to recognize the hazard and, where necessary, informed them how to avoid the dangers associated with it. Where feasible, an exposing employer must have taken appropriate

alternative means of protecting employees from the hazard. When extreme circumstances justify it, the exposing employer shall

have removed his/her employees from the job to avoid citation.



Suggested Outside Contractor Terms and Conditions Note: Legal information is not the same as legal advice. Please read the Disclaimer on page 3 of this Participant Guide.

Applicability The following requirements shall be fulfilled by the Contractor and any and all of its lower-tier subcontractors (for the remainder of this document referred to collectively as "Contractor" when the requirements apply to either party). Contractor shall have any and all of its lower-tier subcontractors or other lower tier individual or entity providing goods or services of any nature and type for Contractor(s) arising out of any agreement between Company and the Contractor(s) expressly agree in writing to the terms and conditions set out in these Standard Terms and Conditions. Safety Contractor expressly agrees that it shall be solely responsible for supervising its employees, that it shall comply with all rules, regulations, orders, standards and interpretations promulgated pursuant to the Occupational Safety and Health Act of 1970, [and the Occupational Safety and Health Act of the State of ________], including but not limited to training, provision of personal protective equipment, adherence to all appropriate lock out/tag out procedures, and providing all notices, safety data sheets, labels, etc. required by the right-to-know standard. The parties intend that an independent contractor relationship, and not an employer-employee relationship, will be created by this document. Company is interested only in the results to be achieved and the conduct and control of the performance of the services contemplated herein will lie solely with the Contractor. It is the Contractor's continuing and absolute responsibility for all aspects of Contractor safety on their jobsites during the execution of work. Any action or inaction by Company or any of its employees, agents and/or representatives shall in no way alleviate Contractor's responsibility or in any way create liability on the part of the Company or any such employee, agent and/or representative.



Suggested Outside Contractor Terms and Conditions, continued Insurance Contractor shall: a. Carry worker’s compensation insurance as required by state law. b. Carry commercial general liability insurance (CGL) in amounts no less than

_____________. c. Carry automobile liability insurance covering all owned, non-owned, and hired

vehicles used in connection with this Agreement, in amounts not less than _______ per person and ________ per occurrence for bodily injury and __________ per occurrence for property damage or _________ combined single limit.

d. Carry a fidelity bond in an amount of no less than ____________ e. Have Company named as an additional insured on its insurance policies; and, f. Have a notice of cancellation provision added to its insurance policies

ensuring no less than ten days prior written notice from the carrier to Company before cancellation of said policies.

The insurance coverage required shall include those classifications, as listed in standard liability insurance manuals, which most nearly reflect the operations of Contractor. All insurance policies required above shall be issued by companies authorized to do business under the laws of the State of [Insert identity of State], with the following qualification: the insurance company must be rated no less than Class [Insert Class Letter, e.g., A+, A, B, etc.] as to financial strength by the latest edition of Best’s Insurance Guide, published by A.M. Best Company, Oldwick, New Jersey, or its equivalent subject to the approval of the Company. Prior to the commencement of this Agreement, Contractor shall have its insurance carrier(s) provide an appropriate Certificate of Insurance directly to Company evidencing compliance with the terms of these insurance paragraphs.



Suggested Outside Contractor Terms and Conditions, continued Hold Harmless Contractor represents that it is an independent contractor. The Contractor agrees to indemnify, defend, and hold harmless Company, its officers, agents, servants, employees, successors and assigns, and further agrees to indemnify, hold harmless, and defend the property owner of any Company facilities, if any, and any shareholders, partners, agents, servants or employees of the owner, as well as any members, tenants, guests, invitees and licensees thereof from and against any and all claims, suits, judgments, damages, or causes of action of any kind, nature or description whatsoever, including any and all costs, reasonable attorney’s fees, costs of defense and any and all other expenses arising out of or from the Contractor's performance of this contract by Contractor or by any of Contractor's officers, shareholders, agents, servants, employees, guests, subcontractors, invitees and those doing business with contractor or any subcontractor of the Contractor. Contractor shall pay all claims and losses arising in any manner from Contractor’s performance of this contract by Contractor or by any of Contractor's officers, shareholders, agents, servants, employees, guests, subcontractors, invitees and those doing business with contractor or any subcontractor of the Contractor; and, shall investigate and defend all claims, suits or actions of any nature and kind in the name of Company and/or the property owner, where applicable, including appellate proceedings, and shall pay all costs, judgments, and reasonable attorney's fees which may issue from or arise out of any of the above. Contractor expressly understands and agrees that any insurance protection required by this agreement or otherwise provided by Contractor shall in no way limit the responsibility of the Contractor to indemnify, keep and save harmless and defend of Company and/or the property owner, or their respective officers, employees, agents and instrumentalities as herein provided.

Reporting versus Recording



What to do in case of an accident, overnight hospitalization, or fatality

Catastrophes and fatal accidents Note: The following became effective January 1, 2015

- Must report all work-related fatalities within 8 hours of learning of it/them.

- Must report the following within 24 hours of learning of learning of them: All work-related inpatient

hospitalizations of one or more employees

All work-related amputations All work-related losses of an eye

Must report using one of three options: - By telephone to the OSHA Office nearest to the site of the incident. - By telephone to the 24-hour OSHA hotline at 1-800-321-OSHA (6742). - On the OSHA website at www.osha.gov.

Information that must be reported: The establishment name; The location of the incident; The time of the incident; The number of fatalities or hospitalized employees; The names of any injured employees; Your contact person and his or her phone number; and A brief description of the incident.

Do not have to report:

Every fatality or multiple hospitalization incident resulting from a motor vehicle accident if the motor vehicle accident occurs on a public street or highway, and does not occur in a construction work zone. However, these injuries must be recorded on the employer’s OSHA injury and illness records.

A fatality or multiple hospitalization incident that occurs on a commercial or public transportation system, e.g., commercial airplane, train, subway or bus accident. However, these injuries must be recorded on the employer’s OSHA injury and illness records.29 CFR 1904.39(b)(5)

Recording - Forms 300, 300A and 301



Written Hazard Communication Program Suggested Elements of a Written Communication Program: No format or detailed table of contents is prescribed for the written plan. Some elements you will want in your plan are:

Purpose

Hazard Evaluation

Chemical Inventory

Material Safety Data Sheets

Labeling

Information and Training

Hazards of Non-routine Tasks

Contractor Employees

Information

The employer must make the written hazard communication program available, upon request, to employees, their designated representatives, and to OSHA. Also, employees must be informed of where the written program is located.



Chemical Inventory

Generally

The standard requires a list of hazardous chemicals in the workplace as part of the written hazard communication program.

You need to obtain an SDS for each chemical on the list.

The best way to prepare a comprehensive list is to survey the workplace for hazardous chemicals “known to be present” in the workplace. This includes chemicals to which employees may be exposed during normal operations or in a foreseeable emergency.

Chemical Survey The hazardous nature of the chemical and the potential for exposure are the factors which determine whether a chemical is covered. If there is no potential for exposure (e.g., the chemical is inextricably bound and cannot be released), the rule does not cover the chemical.

Review purchasing records (and ensure that future purchasing procedures result in SDSs being received before a material is used in the workplace).

Look for chemicals in all physical forms - liquids, solids, gases, vapors, fumes, and mists.

Identify chemicals in containers, including pipes.

Think about chemicals generated during work operations, e.g., welding fumes, dusts, and exhaust fumes.

Read labels provided by suppliers for hazard information. Suggested Elements of a Hazardous Chemical List Although no format for the list is set out in the standard, it is recommended that your list include:

An identifier that can be found on (a) the list, (b) the product’s SDS, and (c) the product’s label.

The location(s) where the products are used or used in the workplace.

The earliest date you began using the product. - The 30 year rule

An indication of the hazards as found on the label.

Safety Data Sheets (SDS)



The SDSs (formerly Material Safety Data Sheets [MSDS]) provide information you need to ensure proper protective measures are implemented prior to exposure. They reflect the hazards of working with the material in an occupational fashion rather than occasional use by a consumer. SDSs are meant for: Employees who may be occupationally exposed to a hazard at work. Employers who need to know the proper methods for storage etc. Emergency responders such as fire fighters, hazardous material crews,

emergency medical technicians, and emergency room personnel. Employees should not be permitted to use any hazardous chemicals for which you don’t have an SDS. SDS Defined

SDSs must be in English (although the employer may maintain copies in other languages as well).

SDSs must be readily accessible to your workers while they are in the workplace during their work shifts.

New 16 Section Format Section 1. Identification Section 2. Hazard(s) identification 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 Section 12. Ecological information Section 13. Disposal considerations Section 14. Transport information Section 15. Regulatory information Section 16. Other information, including date of preparation or last revision

NOTE: The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not enforce the content of these sections because they concern matters handled by other agencies.

Safety Data Sheets Section Explanations



Section 1: Identification This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. The required information consists of:

Product identifier used on the label and any other common names or synonyms by which the substance is known.

Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.

Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier).

Section 2: Hazard(s) Identification This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards. The required information consists of:

The hazard classification of the chemical (e.g., flammable liquid, category1).

Signal word.

Hazard statement(s).

Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions of the symbols in black and white or be a description of the name of the symbol (e.g., skull and crossbones, flame).

Precautionary statement(s).

Description of any hazards not otherwise classified.

For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please note that this is a total percentage of the mixture and not tied to the individual ingredient(s).

Safety Data Sheets Section Explanations, continued Section 3: Composition/Information on Ingredients

http://www.osha.gov/dsg/hazcom/osha-brief.html#footnote1



This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of: Substances

Chemical name.

Common name and synonyms.

Chemical Abstracts Service (CAS) number and other unique identifiers.

Impurities and stabilizing additives, which are themselves classified and which contribute to the classification of the chemical.

Mixtures

Same information required for substances.

The chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards and are:

Present above their cut-off/concentration limits or

Present a health risk below the cut-off/concentration limits.

The concentration (exact percentages) of each ingredient must be specified except concentration ranges may be used in the following situations:

A trade secret claim is made,

There is batch-to-batch variation, or

The SDS is used for a group of substantially similar mixtures. Chemicals where a trade secret is claimed

A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required.

Safety Data Sheets Section Explanations, continued Section 4: First-Aid Measures



This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. The required information consists of:

Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion).

Description of the most important symptoms or effects, and any symptoms that are acute or delayed.

Recommendations for immediate medical care and special treatment needed, when necessary.

Section 5: Fire-Fighting Measures This section provides recommendations for fighting a fire caused by the chemical. The required information consists of:

Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation.

Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns.

Recommendations on special protective equipment or precautions for firefighters.



Safety Data Sheets Section Explanations, continued Section 6: Accidental Release Measures This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. The required information may consist of recommendations for:

Use of personal precautions (such as removal of ignition sources or providing sufficient ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing.

Emergency procedures, including instructions for evacuations, consulting experts when needed, and appropriate protective clothing.

Methods and materials used for containment (e.g., covering the drains and capping procedures).

Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning or vacuuming; adsorbent materials; and/or equipment required for containment/clean up).

Section 7: Handling and Storage This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information consists of:

Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited).

Recommendations on the conditions for safe storage, including any incompatibilities. Provide advice on specific storage requirements (e.g., ventilation requirements).



Safety Data Sheets Section Explanations, continued Section 8: Exposure Controls/Personal Protection This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of:

OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available.

Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed system).

Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, skin or respiratory protection needed based on hazards and potential exposure).

Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; and breakthrough time of the glove material).

Section 9: Physical and Chemical Properties This section identifies physical and chemical properties associated with the substance or mixture. The minimum required information consists of:

Appearance (physical state, color, etc.);

Upper/lower flammability or explosive limits;

Odor; Vapor pressure;

Odor threshold; Vapor density;

pH; Relative density;

Melting point/freezing point; Solubility(ies);

Initial boiling point and boiling range; Flash point;

Evaporation rate; Flammability (solid, gas);

Upper/lower flammability or explosive limits;

Vapor pressure;

Vapor density; Relative density;

Solubility(ies); Partition coefficient: n-octanol/water;

Auto-ignition temperature; Decomposition temperature; and

Viscosity.

Safety Data Sheets Section Explanations, continued



The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust's explosive potential. Section 10: Stability and Reactivity This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other. The required information consists of: Reactivity

Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available.

Chemical stability

Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled.

Description of any stabilizers that may be needed to maintain chemical stability.

Indication of any safety issues that may arise should the product change in physical appearance.

Other

Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur.

List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions).

List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation.

List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.)

Safety Data Sheets Section Explanations, continued



Section 11: Toxicological Information This section identifies toxicological and health effects information or indicates that such data are not available. The required information consists of:

Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact). The SDS should indicate if the information is unknown.

Description of the delayed, immediate, or chronic effects from short- and long-term exposure.

The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a single dose.

Description of the symptoms. This description includes the symptoms associated with exposure to the chemical including symptoms from the lowest to the most severe exposure.

Indication of whether the chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions) or found to be a potential carcinogen by OSHA

Section 12: Ecological Information (non-mandatory) This section provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment. The information may include:

Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available (e.g., acute or chronic aquatic toxicity data for fish, algae, crustaceans, and other plants; toxicity data on birds, bees, plants).

Whether there is a potential for the chemical to persist and degrade in the environment either through biodegradation or other processes, such as oxidation or hydrolysis.

Results of tests of bioaccumulation potential, making reference to the octanol-water partition coefficient (Kow) and the bioconcentration factor (BCF), where available.

The potential for a substance to move from the soil to the groundwater (indicate results from adsorption studies or leaching studies).

Other adverse effects (e.g., environmental fate, ozone layer depletion potential, photochemical ozone creation potential, endocrine disrupting potential, and/or global warming potential).

Safety Data Sheets Section Explanations, continued Section 13: Disposal Considerations (non-mandatory)



This section provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS. The information may include:

Description of appropriate disposal containers to use.

Recommendations of appropriate disposal methods to employ.

Description of the physical and chemical properties that may affect disposal activities.

Language discouraging sewage disposal.

Any special precautions for landfills or incineration activities Section 14: Transport Information (non-mandatory) This section provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea. The information may include:

UN number (i.e., four-figure identification number of the substance).

UN proper shipping name.

Transport hazard class(es).

Packing group number, if applicable, based on the degree of hazard.

Environmental hazards (e.g., identify if it is a marine pollutant according to the International Maritime Dangerous Goods Code (IMDG Code)).

Guidance on transport in bulk (according to Annex II of MARPOL 73/78 and the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (International Bulk Chemical Code (IBC Code)).

Any special precautions which an employee should be aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises (indicate when information is not available).



Safety Data Sheets Section Explanations, continued Section 15: Regulatory Information (non-mandatory) This section identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. The information may include:

Any national and/or regional regulatory information of the chemical or mixtures (including any OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product Safety Commission regulations)

Section 16: Other Information This section indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here. References OSHA, 29 CFR 1910.1200(g) and Appendix D. United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), third revised edition, United Nations, 2009.

Obtaining SDSs Obtain SDSs from whomever you are purchasing your hazardous chemicals. Manufacturer, Importer or Wholesale Distributor

If you are obtaining hazardous chemicals from the manufacturer, importer or wholesale distributor, that entity is required to give you one copy of the relevant SDS:

1. With the first shipment of a particular chemical..

2. With the first shipment after the MSDS has been updated.

Note: As required by OSHA, SDS are dated when they are issued AND when:

1. Any significant change has been made to the chemical compound or

2. Research has revealed a health or physical hazard different from what was originally stated or

3. If the product has been listed as carcinogenic by a recognized agency. A new SDS must be issued within three months if any of these conditions are met.

Retail Distributor

Upon request if you are obtaining hazardous chemicals from a retail distributor:



Labeling and Other Forms of Warning Under the current Hazard Communication Standard (HCS), the label preparer must provide the identity of the chemical, and the appropriate hazard warnings. This may be done in a variety of ways, and the method to convey the information is left to the preparer. Under the revised HCS, once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:

Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond). There are nine pictograms under the GHS. However, only eight pictograms are required under the HCS.

Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.

Hazard Statement: 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 hazard.

Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.

Pictograms



Format

There are nine pictograms under the GHS to convey the health, physical and environmental hazards. The final Hazard Communication Standard (HCS) requires eight of these pictograms, the exception being the environmental pictogram, as environmental hazards are not within OSHA's jurisdiction. The hazard pictograms and their corresponding hazards are shown below:

Pictograms must have red borders.

All red borders printed on the label must have a symbol printed inside it. Employers The employer must ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

Employee Information and Training



Training and Information Overview

Employers must provide employees with effective information and training on hazardous chemicals in their work area:

- at the time of their initial assignment, and

- whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area.

Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals.

Chemical-specific information must always be available through labels and SDSs.

Verbal information and training must be provided in a language comprehensible to the employee being trained.

Information Employees shall be informed of:

1. The requirements of the HAZCOM standard; 2. Any operations in their work area where hazardous chemicals are present;

and, 3. The location and availability of the written hazard communication program,

including the required list(s) of hazardous chemicals, and material safety data sheets required by this standard.

Training Employee training shall include at least: Methods and observations that may be used to detect the presence or release of

a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);

The physical and health hazards of the chemicals in the work area; The measures employees can take to protect themselves from these hazards;

and The details of the hazard communication program developed by the employer.

Job Safety Analysis (JSA) Four Basic Steps 1. Select a Job to be analyzed 2. Separate the Job into its Basic Steps



3. Identify the Hazards Associated with Each Step 4. Control Each Hazard Selecting

Unstructured list Prioritizing

Accident Frequency

1. ≤ once per year 2. ≤ once per month 3. ≤ once per week

4. ≤ once per shift 5. > once per shift 6. Other

Accident Severity

1. first-aid 2. medical treatment 3. lost time

4. partial disability 5. permanent disability 6. death

Accident Potential

- Number of people - Job Stressors - Likelihood

1. extremely unlikely 2. unlikely 3. possible

4. probable 5. multiple

Risk # people x frequency x severity x potential = Risk

Job A: 2 x 3 x 2 x 1 = 12 Job C: 3 x 4 x 2 x 2 = 48 Job B: 1 x 3 x 2 x 1 = 6 Job A: 2 x 3 x 2 x 1 = 12 Job C: 3 x 4 x 2 x 2 = 48 Job B: 1 x 3 x 2 x 1 = 6

New Jobs, Non-routine Jobs, or Job Changes

Routine Jobs



Simple Analysis Worksheet

Sequence – Basic Job

Steps Potential Accidents/Hazards Recommended Procedures

1. Struck By (SB) 4. Contact With (CW) 7. Caught Between (CBT) 10. Overexertion (OE) 2. Struck Against (SA) 5. Caught On (CO) 8. Fall to Same Level (FS) 11. Exposure (E) 3. Contacted By (CB) 6. Caught In (CI) 9. Fall to Below (FB)

Select jobs with the highest risk for a workplace injury or illness.

Select an experienced employee who is willing to be observed. Involve the employee and his/her immediate supervisor in the process.

Identify and record each step necessary to accomplish the task. Use an action verb (i.e. pick up, turn on) to describe each step.

Identify all actual or potential safety and health hazards associated with each task.

1. The existing or potential safety and health hazards associated with

each step. 2. Impact with a falling or flying object. 3. Penetration of sharp objects. 4. Caught in or between a stationary/moving object. 5. Falls from an elevated work platform, ladders or stairs. 6. Excessive lifting, twisting, pushing, pulling, reaching, or bending. 7. Exposure to vibrating power tools, excessive noise, cold or heat, or

harmful levels of gases, vapors, liquids, fumes, or dusts. 8. Repetitive motion. 9. Electrical hazard. 10. Light (optical) radiation (i.e., welding operations, laser surveying,

etc.). 11. Water (potential for drowning or fungal infections caused by

wetness).

Determine and record the recommended action(s) or procedure(s) for performing each step that will eliminate or reduce the hazard (i.e. engineering changes, job rotation, PPE, etc.).



Exercise for Your Employees Instructions:

1. Break into teams of at least 3 people each 2. Find an area where you can have a discussion 3. Select a timekeeper – this exercise will consist of: 3 minutes setup

20 minutes JSA 2 minutes to return 15 minutes debrief

STEP ROUGH NOTES

Select a Job

Separate Job Into Its Basic Steps Each step or

activity should briefly describe what is done.

Each activity should be listed on the form in the order it is performed.

Avoid common errors: - making the

breakdown so detailed that a large number of steps result, or

- making the breakdown so general that basic steps are omitted.



Exercise, continued

STEP ROUGH NOTES

Identify Hazards Associated With Each Job Step 1. Struck By 2. Struck Against 3. Contacted By 4. Contact With 5. Caught On 6. Caught In 7. Caught Between 8. Fall To Same Level 9. Fall To Below 10. Overexertion 11. Exposure

Controlling Each Hazard Less hazardous way to do the job, e.g., tools Physical conditions

Change procedures Change frequency Personal protective equipment

Basic Accident Types



1 Struck Against 2 Struck By

Can the worker Strike Against anything while doing the job step? Can s/he forcefully contact anything that will cause injury? Forceful contact may be with machinery, timber or bolts, protruding objects, or sharp, jagged edges. Identify not only what the worker can strike against, but also how the contact can come about. This does not mean that every object around the worker must be listed. Can the worker be Struck By anything while doing the job? "Struck by" -- something moved and struck the worker abruptly with force. Study the work environment for what is moving near the worker, what will move, or what will move as a result of what the miner does. Is unexpected movement possible from normally stationary objects? Examples are ladders, tools, containers, supplies, and so on.

3 and 4 Contacted By and Contacted With

Can the worker be Contacted By anything while doing the job step? Is there an object or agent is capable of injuring by non-forceful contact? Examples of items capable of causing injury are chemicals, hot solutions, fire, electrical flashes, and steam.

Can the worker come in Contact With some agent that will injure by non-forceful contact? Any type of work that involves materials or equipment that may be harmful by non-forceful contact is a source of "contact with" accidents.

5, 6 and 7 Caught In, Caught On, and Caught Between

Caught In -- the person, or some part of his or her body, is caught in an enclosure or opening of some kind. Caught On -- most of these accidents involve worker's clothing being caught on some projection of a moving object. This moving object pulls the worker into an injury contact. Or, the worker may be caught on a stationary protruding object, causing a fall. Caught Between – these accidents involve having a part of the body caught between something moving and something stationary, or between two moving objects. Always look for pinch points.

8 and 9 Fall To Same Level and Fall To Below

Two hazards account for most Fall To Same Level accidents: slipping hazards and tripping hazards. The Fall To Below accidents occur in situations where employees work above ground or above floor level.

10 and 11 Overexertion and Exposure

Overexertion – injuries caused by excessive lifting, pushing, pulling, holding, or carrying of an object Exposure -- environmental conditions such as noise, extreme temperatures, poor air, toxic gases and chemicals, or harmful fumes from work operations.



Exercise Sheet Department: ________________ Job: _______________________ Item Sequence – Basic Job

Steps Potential

Accidents/Hazards Recommended

Procedures

Appendix - Sample OSHA Shipping Label

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