TDI Brooks

HAZCOM Program(includes GHS & Final Rule 2012 updates)

SOP-GEN-013B

Prepared by Shannon Smith Last Revision October 2013

OSHA’s HAZCOM Regulation

The OSHA Hazard Communication Regulation was passed in 1983 to protect workers from hazardous chemicals in the workplace. It established the worker’s “Right to Know” what he or she was exposed to at work.

OSHA’s HAZCOM Regulation

In 2012, the regulation was updated to include the United Nations’ GHS system. This revision emphasized the worker’s “Right to Understand” the hazards of the chemicals and how to protect themselves.

HAZCOM final rule and GHS

The Globally Harmonized System of Classification and Labeling of Chemicals, also know as GHS, is a document created by the United Nations to standardize how to classify and label hazardous chemicals among participating countries.

What is GHS?

The goal of the GHS was for workers of any nationality to easily recognize and understand the hazards of the chemicals they handle- regardless of language or literacy.

Why HazCom?

The HAZCOM Regulation, “ requires … all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training.”

OSHA 29 CFR 1910.1200(b)(1) is the regulation number of this standard.

TDI’s HAZCOM Program

TDI’s HAZCOM program is contained in the Safety Management Manual as SOP-GEN-013B

When is HAZCOM training required?

1910.1200(h)(1) Employers shall 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 chemical hazard the employees have not previously been trained about is introduced into their work area.

Safety Data Sheets (formerly MSDS)

A Safety Data Sheet (SDS) is prepared by the manufacturer or importer to give information about a chemical or substance.

After Dec 2015, all Safety Data Sheets must present this information in a standard format.

Until then, SDSs may be in multiple formats.

SDS Binder

An SDS binder containing SDSs for all chemicals in the area should be in a centrally located, easily accessible area at all TDI Brooks facilities and on all vessels.

It should contain: TDI Hazcom Program A list of chemicals in at the site and An SDS sheet for each chemical on the list.

?????????????????? Where is the nearest SDS binder?

Does it contain the policy and chemical list?

SDS Page on TDI Ship Web Pages

TDI Brooks has a ship based set of web pages that includes an SDS page.

The SDS page contains: The TDI HazCom Program A blank chemicals list form in Excel SDSs for commonly used chemicals Links to search engines to finds SDSs

SDSs can be downloaded and printed as needed

The SDS page is organized by types and departments.

SDS- New 16 Section Format

Section 1- Identifies product and manufacturer Section 2- Identifies Hazards Section 3- Composition Information Section 4- First Aid Measures Section 5- Fire Fighting measures Section 6- Accidental Release/ Containment Section 7- Handling and Storage Section 8- Exposure Control/ PPE

SDS- New 16 Section Format

Section 9- Physical and Chemical Properties Section 10- Stability and Reactivity Section 11- Toxicology Sections 12 through16- Ecology, disposal,

transport, etc. Not regulated by OSHA

Identification, Manufacturer

Section 1 identifies the chemical and gives contact information- including emergency phone number- for the manufacturer.

Hazards Section 2 lists all hazards

and required label elements.

First Aid

Section 4 of the new SDS format contains first aid measures.

Handling and Storage

Section 7- Pay attention to this- it will tell you recommended temperature, ventilation and what NOT to store it with. (This one is for household bleach)

Exposure Control/ PPE

Section 8- will state recommended PPE.

Stability and Reactivity

Section 10- warns of any strong reactions with incompatible substances.

?????????????????? This SDS section is for acetone. Should it be stored

with bleach? Why?

?????????????????? No. But why?

?????????????????? No. But why?

Labels

Manufacturer labels will be required to include four elements: Pictogram representing the hazard Signal Word indicating hazard level

“Warning” – less severe “Danger” – more severe

Hazard Statement describing type and degree of hazard

Precautionary Statement of recommended measures to protect the worker

Sample of new label elements from SDS

Labeling Secondary Containers

You may transfer a product into a smaller container or spray/ squirt bottle for easier use.

But- you must label it with at least: Product name Words or pictograms to convey the general

physical or chemical hazards

?????????????????? Is this secondary

container labeled correctly?

?????????????????? Is this secondary

container labeled correctly?

No. The product is identified, but there is no indication of the hazards.

?????????????????? This secondary

container lists a description of how the worker should protect him or herself.

Is it labeled correctly?

?????????????????? This secondary

container lists a description of how the worker should protect him or herself.

Yes. It indicates the hazards by telling the worker what personal protective equipment is needed

?????????????????? What about

this one?

?????????????????? What about

this one?

Yes. The pictures indicate there are hazards to the skin and eyes and recommend protective equipment.

Some Exceptions for Labeling

GHS Labeling of secondary containers according to OSHA regulations does not apply to the following (1910.1200(b)(5-6)):

Chemicals that are specifically regulated by other agencies (medical, biological, radioactive, agricultural, cosmetic)

Tobacco or tobacco products Food or alcohol intended for consumer use

Other exceptions

Wood or wood products that only present flammability hazards. (not chemically treated)

Over the counter drugs, first aid supplies Cosmetics Any consumer product used for its intended

purpose that does not present exposure greater than reasonably expected for its intended use (hand soap)

Memory is the first thing to go…

If this looks familiar, you need some practice making labels….

GHS Pictograms- why we need them

GHS Pictograms

The real reason we need pictograms is that hazardous materials are shipped around the world and are handled daily by people from many countries and levels of education. An SDS may give all the important information about the hazards of a substance, but that is useless if the worker handling it cannot read or understand it.

What do these signs mean to you?

A warning you can’t understand is no warning at all.

What you don’t know really can hurt you…

A picture is more effective and communicates across language and literacy barriers.

GHS Pictograms

There are nine pictograms adopted by the GHS to identify chemical hazards.

Irritant

Acutely toxic

Skin sensitizer

Skin corrosion, burns

Eye damage

Corrosive to metals

Explosives

Self-Reactives

Organic Peroxides

Aquatic Toxicity

GHS Pictograms

Gas under pressure

•Flammable

•Pyrophoric - ignites when exposed to air

•Self Reactive – produces heat by itself

•Respiratory Sensitizer – causes nose and throat to become hypersensitive

•Target Organ Toxicity – harmful to organs

•Aspiration Toxicity – harmful when inhaled

Acute Toxicity

(fatal or toxic)

Health Hazard

•Carcinogen

•Mutagenicity

•Reproductive Toxicity

•Respiratory Sensitizer

•Target Organ Toxicity

•Aspiration Toxicity

Technical Terms

Mean the substance causes the following problems:

•Cancer

•Genetic mutation

•Birth defects or infertility

•Hypersensitive nose, mouth, throat

•Organ damage

•Lung, nose and throat damage

Oxidizers

This symbol represents Oxidizers.

Oxidizers are chemicals that release large amounts of oxygen into the air.

Oxidizers tend to be corrosive– so wear PPE

They are also reactive– they react strongly with other products

Organic Peroxides

You may have noticed that the Exploding Bomb pictogram uses the term “Organic Peroxides”.

•Explosives•Self-Reactives•Organic Peroxides

They are hazardous because they are:

•Thermally unstable – (self heating)

•Liable to explode

•Burn rapidly

•Are sensitive to impact or friction (think nitro glycerin explosives)

•React dangerously with other substances

Oxidizers and Organic Peroxides

L VE to BURN!!

They love starting fires and making them BIGGER…

•Keep them away from flammables

•Store them by themselves

GHS Pictograms Posters

Every TDI-Brooks vessel or facility should have a poster of the GHS pictograms posted in a central area near the SDS Binder. If your area does not have a poster, email a request for one to shannonsmith@tdi-bi.com.

There is a printable GHS symbols poster on the SDS page of the ship web pages

GHS symbols can also easily be found online with a simple search

How to detect a chemical

Smell is one of the main ways to detect if a chemical is present or is leaking from a container.

Most of you have found a broken bottle or spilled substance by smell before.

How to detect a chemical

Sometimes, detecting a spill is more obvious.

Sight is another way to detect if a chemical is present or is leaking from a container.

How to detect a chemical

Other dangerous chemicals have no smell. Carbon monoxide can’t be seen or smelled, but can be fatal.

Detectors can be used to monitor these types of chemicals.

How to Protect Yourself

TDI has created PPE Matrices as a quick reference for what PPE is required to protect you from routine tasks.

The Environmental laboratory has a specific matrix to address standard operating procedures which expose the worker to chemicals.

When exposed to chemicals on the vessels, consult the PPE matrix , product label and the SDS before using it.

?????????????????? Where is the nearest PPE Matrix that applies to your work?

OSPHO- hazards

Vessels frequently have OSPHO metal treatment on board. This is a solution of 75% phosphoric acid.

This acid is highly corrosive and produces very flammable gas when applied to metal.

Make sure the SDS is in the binder and review it before use.

OSPHO- hazards

PPE- Keep area ventilated and wear chemical/ acid resistant gloves and eye protection (face shield, safety glasses or goggles)

Unidentified Chemical????

SOP-GEN-013B Sec 4.4 If the label has worn off or

can’t be read, and you don’t know what it is, give it to the Party Chief or Chief Mate for storage and proper disposal at shore.

Accidental Exposure Procedure

SOP-GEN-013B Sec 5.0TDI-Brooks will follow Accidental Exposure

Procedures when a worker has been accidentally exposed to a chemical through skin contact, inhalation or ingestion. The primary focus is to provide first aid to the worker and record the incident. If accidental exposure occurs, follow these steps:

Accidental Exposure Procedure

Stop or minimize exposure. Remove contaminated clothing. If inhalation exposure, move the person to a well ventilated area

Identify the chemical Find the first aid measures on the container or SDS

and provide first aid if appropriate. (Section 4 on new SDS)

Notify the supervisor as soon as possible Complete the Employee Incident Report Form.

Even if there seems to be no harm done, some reactions are delayed and may not show up for hours.

Informing Contractors

SOG-GEN-013B Sec 4.7 Aboard vessels, it is the Master’s

responsibility to provide contractors coming on board with the information below. At the offices and on shore facilities, it is the responsibility of the person who hired the contractor to provide that contractor with the following information:

Informing Contractors

Any hazardous chemicals to which contractors may be exposed while on site

The location of the safety data sheets Location and use of the PPE Matrix, which

describes precautions and controls to lessen or prevent possible exposure by use of the appropriate personal protective equipment (PPE).

Non-Routine Tasks

SOP-GEN-013B Sec 4.6 Periodically, employees may be required to perform

non-routine work or tasks requiring the use of hazardous chemicals, materials or work in associated hazardous locations. The supervisor of the workers who will perform the work is responsible for conducting a Job Safety Analysis (JSA) of the task and ensuring that each impacted employee is provided information concerning the chemicals, materials, or exposure potential of activity.

Non-Routine Tasks

The JSA will examine risks and hazards of the task and provide information concerning:

Specific hazards that may be associated with the chemical or material

Protective and other safety measures to be taken Measures that will be taken to minimize or prevent

hazard exposure including ventilation, respirators, storage, postings, and Personal Protective Equipment (PPE)

Review of the chemical or material SDS or other applicable technical information

Review any emergency procedures to be taken **If the addition of the new chemical is a result of a

change in procedures, a Management of Change may be required first.

Review

You should now be able to…

Locate the nearest SDS Binder

Find PPE, storage and first aid info on an MSDS or SDS

Know how to properly label a secondary container

Recognize the hazards of the GHS pictograms and know where to find that information

Know where to find a copy of the TDI HazCom Program

Know what to do in case of accidental chemical exposure

Know where chemicals in your work are stored