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OSHA HCS Best Practices from MSDSonline

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Hazard Communication is one of the most frequently violated OSHA standards and with the agency getting tougher on enforcement, compliance is crucial. This presentation provides a brief overview of the …

Hazard Communication is one of the most frequently violated OSHA standards and with the agency getting tougher on enforcement, compliance is crucial. This presentation provides a brief overview of the regulation, touches on the impact of the proposed alignment with GHS and shares some easy-to-implement best practices for helping your organization meet OSHA's HazCom requirements, including best practices for managing your written plan, providing proper employee training and utilizing efficient MSDS management systems.

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  • 1. Hazard Communication HCS Compliance Best Practices www.MSDSonline.com 1.888.362.2007
  • 2.  1.888.362.2007  www.MSDSonline.com  [email_address] www.MSDSonline.com 1.888.362.2007
  • 3. Goals for this Presentation Review HCS HCS Alignment with GHS Challenges Related to Compliance Recommend Best Practices www.MSDSonline.com 1.888.362.2007
  • 4. HCS What is it? www.MSDSonline.com 1.888.362.2007
  • 5. An OSHA Regulation What is HCS? Also known as… www.MSDSonline.com 1.888.362.2007
  • 6.
    • Hazard Communication
    1910.1200 HCS The Reg HazCom Standard HazCom The HazCom Reg 29 CFR 1910.1200 www.MSDSonline.com 1.888.362.2007
  • 7. Adopted in 1983 Covers 100+ Million Workers 7+ Million American Workplaces What is HCS? An OSHA Regulation www.MSDSonline.com 1.888.362.2007
  • 8. Purpose of HCS “… to ensure hazards of all chemicals produced or imported are evaluated and details regarding their hazards are transmitted to employers and employees” “ Ensure requirements are consistent nationwide” www.MSDSonline.com 1.888.362.2007 Photo from www.clker.com by user “OCAL”
  • 9. Chemicals Covered
    • Physical Hazards
      • Combustible liquids
      • Compressed gases
      • Explosives
      • Flammables
      • Organic peroxides
      • Oxidizers
      • Pyrophorics
      • Unstable (reactive) materials
      • Water-reactives
    www.MSDSonline.com 1.888.362.2007
  • 10.
      • Carcinogens
      • Toxic agents
      • Reproductive toxins
      • Irritants
      • Corrosives
      • Sensitizers
      • Hepatotoxins
      • Nephrotoxins
      • Neurotoxins
      • Agents which act on the hematopoietic system
      • Agents which damage the lungs, skin, eyes or mucous membranes
    • Health Hazards
    • Chemicals that may produce acute or chronic health effects in exposed employees
    Chemicals Covered www.MSDSonline.com 1.888.362.2007
  • 11.
    • Chemical Manufacturers
    • Evaluate hazards of chemicals
    • Provide labels & (M)SDSs to employers to which they ship chemicals
    • Importers & Distributors
    • Provide labels & (M)SDSs to employers to which they ship chemicals
    • Employers Who “Use” Chemicals
    • Inventory hazardous chemicals
    • Prepare and implement written program
    • Ensure that all in-plant containers are properly labeled
    • Ensure that (M)SDSs are obtained for all hazardous chemicals
    • Train employees
    Who has Responsibilities? www.MSDSonline.com 1.888.362.2007
  • 12. A LOT OF GREY AREA overlapping regulations and Acts “ minute or trace amounts” “ reasonable amount” “ readily-accessible” www.MSDSonline.com 1.888.362.2007
  • 13. Letters of Interpretation Mostly Situation- Specific Questions Questions around Applicability, Defining Terms, etc. Most are Simply Trying to Ensure They’re Compliant… Some are Looking for Technicalities www.MSDSonline.com 1.888.362.2007
  • 14.
    • The Compass of Common Sense Will Get You Through Most Interpretation
    “ A Common Sense Reg” Check the OSHA Web Site for Letters of Interpretation Related to Your Question(s) Largely Dependent on Your Environment www.MSDSonline.com 1.888.362.2007
  • 15. HCS Main Requirements Written Plan Labels & Warnings (M)SDS Documents Training Specific criteria and requirements for the HCS Regulation are available on OSHA’s Web site www.osha.gov 1 2 3 4 www.MSDSonline.com 1.888.362.2007 © Photo from stock.xchng.. User “andreyutzu”
  • 16. Written Plan 1 2 3 4 www.MSDSonline.com 1.888.362.2007
  • 17. Written HCS Program
    • Must Include All of the Following :
      • List of present chemicals ( entire workplace/ individual work area )
      • Identify employee(s) who are responsible for components of the plan
      • Explain where written materials are available
      • Describe how the facility will meet the requirements for
        • Labels and other forms of warning (what to look for, etc…)
        • Safety Data Sheets “(M)SDSs” (how to read them, etc…)
        • Employee information and training
    Reflective of Your Workplace and Specific Conditions at Your Facility 1 www.MSDSonline.com 1.888.362.2007
  • 18. Include All Chemicals that Are Hazardous and Have the Potential for Employee Exposure Inventory of Chemicals
    • Consider Chemicals in All Physical Forms
      • Liquids, solids, gases, vapors, dust, etc.
    • Identify Chemicals in Containers, Including Pipes
      • Inventory hazardous chemicals
    • Consider Chemicals Generated in Work Operations
      • Welding fumes, dusts, exhaust fumes, etc.
    www.MSDSonline.com 1.888.362.2007
  • 19. Best Practice Takeaways www.MSDSonline.com 1.888.362.2007
    • Have an HCS plan!
      • Generic plans available
      • Adapt to your facility and environment
    • Maintain a checklist of key plan components
    • Review it annually
    • Update as needed
      • New materials
      • Process changes that may create new hazards
    • Designate an HCS coordinator
      • Ensure plan is imple-mented & maintained
      • Document changes (when and by whom)
    • Develop written pro- cedures on what to do if OSHA knocks
      • Practice with mock inspections
    • Ensure employees have a clear mechanism to raise safety concerns
      • Make sure they know their rights
    • Stay current on OSHA
      • Federal
      • State & local
    • Keep an eye on GHS
      • Key dates
      • Impact on your plan
  • 20. Labels & Warnings 1 2 3 4 www.MSDSonline.com 1.888.362.2007
  • 21. Labels & Warnings 2 English Required… Other Languages Optional
    • Labels on Products Shipped by Manufacturers,
    • Importers and Distributors:
      • Must identify hazardous chemicals and associated hazard warnings
      • Name and address of manufacturer, importer, etc.
    • Labels on In-Plant/On-site Containers of Hazardous
    • Chemicals:
      • Identity of the material (links the label, (M)SDS and inventory)
      • Appropriate hazard warnings (e.g., “flammable,” “skin irritant”)
    • Must be Legible and Prominently Displayed:
      • Words, pictures, symbols
      • Labels cannot be removed or defaced
    www.MSDSonline.com 1.888.362.2007
  • 22. Best Practice Takeaways www.MSDSonline.com 1.888.362.2007
    • Make sure ALL con-tainers are properly labeled!
      • Primary & secondary
      • Stationary/ tanks
      • Pipes
    • Labels must include:
      • Name of chemical
      • Manufacturer/distributor
      • Hazard warnings
      • Affected body parts/ organs
      • Proper handling
    • Get ahead of GHS now
      • Understand new labeling rules
      • Make sure your labeling systems can reformat labels to meet GHS requirements
  • 23. Product/Chemical Identifier GHS Labeling Requirements www.MSDSonline.com 1.888.362.2007
  • 24. Supplier Identifier GHS Labeling Requirements Product/Chemical Identifier www.MSDSonline.com 1.888.362.2007
  • 25. Hazard Pictograms* * Standardized under GHS GHS Labeling Requirements Supplier Identifier Product/Chemical Identifier www.MSDSonline.com 1.888.362.2007
  • 26. Signal Words* * Standardized under GHS GHS Labeling Requirements Hazard Pictograms* Supplier Identifier Product/Chemical Identifier www.MSDSonline.com 1.888.362.2007
  • 27. Hazard Statements* * Standardized under GHS GHS Labeling Requirements Signal Words* Hazard Pictograms* Supplier Identifier Product/Chemical Identifier www.MSDSonline.com 1.888.362.2007
  • 28. Precautionary Information * Standardized under GHS GHS Labeling Requirements Hazard Statements* Signal Words* Hazard Pictograms* Supplier Identifier Product/Chemical Identifier www.MSDSonline.com 1.888.362.2007
  • 29.
      • Train your employees
    1 2 3 4 www.MSDSonline.com 1.888.362.2007 Photo: © Simon Gray from stock.xchng
  • 30. Before Assigning Work with Hazardous Chemicals By Individual Chemicals or Categories of Hazards 3 Employee Training
    • Employee Training Must Include :
      • Requirements of HCS
      • Operations within work areas where hazardous chemicals are present
      • Location and availability of the written HCS program, hazardous chemical inventory and (M)SDSs
      • Methods to detect presence or release of hazardous chemicals
      • Physical and health hazards of chemicals in work area
      • Measures to protect themselves from the hazards
      • Details of employer’s hazard communication program
    www.MSDSonline.com 1.888.362.2007
  • 31. Best Practice Takeaways
      • Blended training that’s specific to your work environment
    www.MSDSonline.com 1.888.362.2007
    • Include emergency procedures in your training
      • Spill procedures
      • Uncontrollable releases
      • Location and operation of
      • safety showers/ eye wash
      • equipment, etc.
      • When to seek medical attention
    • When to train
      • New hires
      • New materials
      • Process changes that may create new hazards
      • When you have reason to believe employees don’t understand
      • Annual reviews
    • Other items to cover
      • Safe handling procedures and proper PPE usage
      • Proper storage procedures
      • Use of and interpretation of labels and warnings
      • How to read (M)SDSs
      • Non-routine tasks
      • Communication with outside vendors and contractors
  • 32. (M)SDS Documents 1 2 3 4 www.MSDSonline.com 1.888.362.2007
  • 33. Provided by Chemical Manufacturer, Importer or Distributor with First Shipment and Anytime the Information Changes
    • Must Be Readily Accessible to Employees When They Are in Their Work Areas During Their Work Shifts
      • Paper copies may be kept in a central location
      • Computerized access may be available through terminals
      • Receiving the information over the phone is not acceptable (except under the mobile worksite provision)
    Safety Data Sheets 4
    • Provide Detailed Information on Each Hazardous Chemical :
      • Potential hazardous effects
      • Physical and chemical characteristics
      • Recommendations for appropriate protective measures
    Must Be Obtained for All Hazardous Chemicals in the Workplace Before Those Chemicals Are Used www.MSDSonline.com 1.888.362.2007
  • 34. Best Practice Takeaways www.MSDSonline.com 1.888.362.2007
    • Have an (M)SDS for all chemicals/ products currently in use
      • MROs, raw materials, finished goods
      • Do an annual review – in conjunction with annual inventory
      • Make sure they’re readily accessible
      • Make sure employees know where to find them
      • And how to read them
      • Have a process flow approving new incoming products
  • 35. Best Practice Takeaways www.MSDSonline.com 1.888.362.2007
    • Manage (M)SDSs electronically
      • Reduces paper
      • Streamlines reporting
        • Tier I and Tier II data
      • Easier to archive and manage versions
      • Faster (M)SDS retrieval
    • Have adequate backup
      • Maintain 1 master set of paper copies
      • Consider a fax on-demand system
      • Make sure your electronic system is integrated into your overall HCS plan
  • 36. Best Practice Takeaways www.MSDSonline.com 1.888.362.2007
    • Language?
      • Best to have (M)SDSs in native language
      • English-only is ok
        • Train in native language
        • Ensure all employees are fully aware of hazards and safe handling procedures
    • Keep an eye on GHS milestones
      • What’s changing
        • Going to SDS
        • Adopting 16-part format in specific order
        • Section 2 hazard classifications
    • Maintain (M)SDSs for discontinued materials
      • Better safe than sorry
      • Part of employee Access to Medical and Exposure Records (1910.1020)
        • 30 years from date of discontinuation
  • 37.
    • Revise HCS to Align with GHS
      • Maintain HCS framework
      • Enhance protection
      • Based on GHS Rev 3 (2009)
    • Proposed Rulemaking in Review
      • Public hearings, 2010
      • Final ruling (2010?)
      • Adoption possible in 2011
    • Compliance Enforcement
      • Training within 2 years of final rule
      • Full compliance expected with 3 years
      • Transitional period
    OSHA Alignment with GHS www.MSDSonline.com 1.888.362.2007
  • 38. Resellers or distributors , get new MSDSs and labels ASAP and distribute to customers If you’re an importer …ditto If you’re an employer , make sure you have the latest (M)SDSs and labels and train your employees on their use Chemical manufacturers have some work to do around re-authoring (M)SDSs, labels and warnings to make them GHS compliant What You Can Expect… www.MSDSonline.com 1.888.362.2007
  • 39. Best Practices – Final Thoughts Chemical Hazard Control Strategies www.MSDSonline.com 1.888.362.2007
    • Engineering Controls
      • Redesign, replace, substitute chemicals, machinery, equipment to eliminate or reduce the chemical hazard itself
      • This strategy seeks to control the hazard at the source by using such methods as total enclosure or substitution of a safer chemical
    • Administrative Controls
      • Change work procedures to reduce the duration, frequency, and severity of exposure to the chemical hazard
      • The primary focus is to incorporate safer work practices through written safety policies, rules, supervision and training
    • Personal Protective Equipment Controls
      • The use of PPE is probably the most common strategy, and in many cases is a mandatory requirement when working with hazardous chemicals
      • Once again, the chemical hazard is neither eliminated nor reduced, and a high reliance is placed on appropriate use of PPE for this strategy to be successful
  • 40. So how do I make sure I’m compliant?… www.MSDSonline.com 1.888.362.2007
  • 41.
    • A list of chemicals used in the workplace
    • Proper labeling of those chemicals
    • Written HCS plan
    • (M)SDS documents (and a system for accessing, managing and deploying them)
    • Self inspection checklists available at OSHA.gov
    Some of what inspectors or safety officials will be looking for www.MSDSonline.com 1.888.362.2007
  • 42. Penalties for non-compliance are very real
    • In 2007-2008, OSHA cited nearly 5,000 instances of HCS violations in workplaces across the United States
    • #3 on OSHA's top 10 list of most frequently violated compliance standards
    www.MSDSonline.com 1.888.362.2007
  • 43. The costs of non-compliance can add up quickly
    • Fines
    • Potential risk & liability
    • Downtime & internal disruption
    • Negative press & impact to corporate image
    • Lost revenues
    www.MSDSonline.com 1.888.362.2007
  • 44. Remember it’s not just about… www.MSDSonline.com 1.888.362.2007
  • 45.
      • Avoiding citations…
    www.MSDSonline.com 1.888.362.2007
  • 46.
      • … and fines
    www.MSDSonline.com 1.888.362.2007
  • 47. it’s also about… www.MSDSonline.com 1.888.362.2007
  • 48. our employees … www.MSDSonline.com 1.888.362.2007
  • 49. our customers … www.MSDSonline.com 1.888.362.2007
  • 50. our community… www.MSDSonline.com 1.888.362.2007 Photo: © 2009 from Wikimedia Commons. User “Reck345”
  • 51. www.MSDSonline.com 1.888.362.2007
  • 52. Thank You  1.888.362.2007  www.MSDSonline.com  [email_address] www.MSDSonline.com 1.888.362.2007