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OSHA HCS Fact or Fiction Game, 29 CFR 1910

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The Hazard Communication Standard (HazCom) remains among the most frequently cited OSHA violations and is the governing standard for material safety data sheets (MSDSs). With regulatory enforcement …

The Hazard Communication Standard (HazCom) remains among the most frequently cited OSHA violations and is the governing standard for material safety data sheets (MSDSs). With regulatory enforcement now being a bigger priority for OSHA, it’s more important than ever to be compliant. In this presentation, you’ll learn the facts about MSDS compliance and the benefits that electronic MSDS management technology provides as it relates to employee safety, time- and cost-savings and reducing the risk/liability associated with meeting stringent compliance standards.

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  • 1. Hazard Communication HCS Compliance Fact & Fiction 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 the HCS HCS fact & fiction Challenges related to compliance Persuade you to take steps to ensure your organization’s compliance 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. 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
  • 13. A LOT OF GREY AREA overlapping regulations and Acts “ minute or trace amounts” “ reasonable amount” “ readily-accessible” www.MSDSonline.com 1.888.362.2007
  • 14. 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 1.888.362.2007
  • 15.
    • 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
  • 16. 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”
  • 17. Written Plan 1 2 3 4 www.MSDSonline.com 1.888.362.2007
  • 18. 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
  • 19. Labels & Warnings 1 2 3 4 www.MSDSonline.com 1.888.362.2007
  • 20. Labels & Warning 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
  • 21.
      • Train your employees
    1 2 3 4 www.MSDSonline.com 1.888.362.2007 Photo: © Simon Gray from stock.xchng
  • 22. 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
  • 23. (M)SDS Documents 1 2 3 4 www.MSDSonline.com 1.888.362.2007
  • 24. 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
  • 25. www.MSDSonline.com 1.888.362.2007
  • 26. There are other ways to manage your (M)SDSs… www.MSDSonline.com 1.888.362.2007
  • 27.
    • Internet-Based
    • Software
    • (M)SDSs accessed and
    • managed through an
    • on-demand, online system
    • No software to install
    • Attributes to consider:
      • Large database
      • Updates
      • Tools to access, manage & deploy
      • Reporting
      • Customer support
      • Track record of up-time
    Fax-Back Alternative Approaches
    • (M)SDS Database stored
    • & managed on a local
    • computer or network
    • Sort, search, print, reports & archive
    • Typically no (M)SDS libraries, so you do updating yourself
    • Often have good chemical management capabilities
    • Must install software & keep up with upgrades
    • (M)SDSs requested from
    • 800# call centers & faxed
    • to customers on-demand
    • Fax-only systems can be expensive
    • Not compliant as a “stand-alone” product because it doesn’t meet OSHA’s back-up requirements
    • No transparency… only way to know if you have an MSDS is to call
    www.MSDSonline.com 1.888.362.2007
  • 28. Electronic solutions help companies go from here… www.MSDSonline.com 1.888.362.2007
      • Paper -based systems
    Photo: : © Rodrigo Comisarenco from stock.xchng
  • 29. Electronic ( M)SDS management www.MSDSonline.com to here… 1.888.362.2007
  • 30.
      • Technology
      • Computers
      • Networks
      • Internet
      • Intranets
    www.MSDSonline.com by leveraging this… 1.888.362.2007
  • 31.
    • Average (M)SDS Library Contains 2,000+ Documents @ 5-6 Pages/ MSDS
    • Management is Costly, Tedious & Often Non-Compliant
    • OSHA Studies Show That Only 70% of a Company’s Hazardous Chemical Inventory has Accurate (M)SDSs Available
    Still Want to Use Paper? www.MSDSonline.com 1.888.362.2007
  • 32. Time to play HCS Fact or Fiction www.MSDSonline.com 1.888.362.2007
  • 33. Q: Managing (M)SDS documents electronically is compliant with the OSHA standard? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 Electronic means of managing and deploying (M)SDS documents is compliant with the OSHA standard as long as there are no barriers to employee access Fact
  • 34. Additional OSHA guidelines relative to electronic (M)SDS management
    • Ensure an Adequate Back-Up System is in Place for Rapid Access in the Event of an Emergency
      • Power outages, equipment failure, online access delays, etc.
    • Ensure the Electronic System is Integrated into the Overall Hazard Communication Program of the Workplace
    • Ensure Employees and Emergency-Response Personnel Have Hardcopy-Access to the MSDSs if Needed or Desired
    www.MSDSonline.com www.MSDSonline.com 1.888.362.2007
  • 35. Q: You must have (M)SDSs in a paper format? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 “ Readily accessible” does not mean (M)SDSs have to be preprinted, however… You must be able to provide a hardcopy of an (M)SDS upon request Fiction
  • 36. Q: If you have Spanish-speaking employees, you must have an (M)SDS in Spanish? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 While it is always better to have (M)SDSs and labels written in a language that your employees can understand, there is no requirement that you have to have an (M)SDS in any other language than English. However, you must train your employees in a language they can comprehend. Fiction
  • 37. Q: All (M)SDSs must be produced in a specific format as prescribed by OSHA? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 Today, there is no specified format; only specific information requirements Fiction GHS Requires 16-Part format in a specific order
  • 38. Q: T he United States has adopted the GHS requirements for (M)SDSs and labels? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 In September of 2009, OSHA formally recommended that the HSC align with GHS, but it has not officially been adopted Fiction
  • 39. to provide an underlying infrastructure for individual countries to establish national, comprehensive chemical safety programs, with globally consistent identification and communication of hazards Spirit of GHS www.MSDSonline.com 1.888.362.2007 © 2006 GNU Free Documentation License user Jankaka
  • 40. All Existing Classifications Hazard Labeling for all Chemical Substances and Mixtures Eventually, ALL Safety Data Sheets (SDS/ MSDS) – They will Need to Reflect the New Format The Criteria for Classification of Chemical Substances and Mixtures What’s Changing? www.MSDSonline.com 1.888.362.2007
  • 41. Resellers or Distributors , Get New (M)SDSs and Labels ASAP & 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 Who’s Affected? www.MSDSonline.com 1.888.362.2007 Pretty much everyone who “uses” hazardous chemicals has some responsibility… some more than others
  • 42.
    • 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
  • 43. Q: You must keep an (M)SDS on file for 30 years after the product is no longer in use? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 Photo: :© Dominik Gwarek from stock.xchng As part of the Access to Medical Exposure Records, all (M)SDSs for chemicals must be maintained for at least 30 years following the discontinuation of their use if no other record of the chemical identity, and where and when it was used, is being maintained Fact
  • 44. Q: ( M)SDSs must be updated at least every 3 years by chemical manufacturers? Fact or Fiction?
    • In the United States, (M)SDSs must be updated only if:
    • there is a material change made to the chemical
    • there is change in the known hazards related to a chemical
    • there is a significant change made to the emergency or contact information associated with the (M)SDS
    www.MSDSonline.com 1.888.362.2007 Fiction
  • 45. Q: The EPA is responsible for the HCS Reg? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 The HCS Reg is managed by OSHA, a division of the U.S. Department of Labor Fiction
  • 46. Q: Pharmaceuticals in pill, tablet or capsule form do NOT require an (M)SDS? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 An (M)SDS is required, if… “… tablets, capsules or pills containing hazardous chemical products in solid dosage form must be dissolved or crushed by an employee prior to administration to the patient” Fact
  • 47. Q: Consumer products require an (M)SDS? Fact or Fiction? www.MSDSonline.com 1.888.362.2007 However, if duration and frequency of use by employees is greater than the intended standard consumer use, then an (M)SDS and HCS training must be provided Fiction
  • 48. A performance-based standard… … you must be able to demonstrate compliance www.MSDSonline.com 1.888.362.2007
  • 49. Q: OSHA doesn’t really do inspections to check for compliance with this regulation Fact or Fiction? www.MSDSonline.com 1.888.362.2007 Photo: :© Scott Davidson. From flickr, user “davidsonscott15” In 2008, OSHA conducted 38,591 inspections and cited 87,687 violations HCS ranks third among most violated standards Fiction
  • 50. So how do I make sure I’m compliant?… www.MSDSonline.com 1.888.362.2007
  • 51.
    • 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
  • 52.
    • Obtain a copy of the Hazard Communication Standard
    • Read and understand the requirements
    • Prepare a written program
    • Assign responsibility for tasks
    • Prepare an inventory of hazardous chemicals
    • Obtain an (M)SDS for each hazardous chemical
    • Make (M)SDSs available to workers
    • Conduct training for workers
    • Ensure containers of hazardous chemicals are labeled
    • Establish procedures to maintain current program
    • Establish procedures to evaluate effectiveness
    It’s Pretty Simple… Create a Checklist www.MSDSonline.com 1.888.362.2007
  • 53. Q: EH&S professionals spend as much as 45% of their time each day completing tedious compliance-reporting and record-management tasks Fact or Fiction? www.MSDSonline.com 1.888.362.2007 Our findings indicate that it’s closer to 75% Fiction EH&S professionals can, however, reduce this time greatly by shifting to systems that help automate and streamline compliance
  • 54.
    • SO WHAT?
    • Why should I care about the HCS Regulation?
      • … well
    www.MSDSonline.com 1.888.362.2007
  • 55. 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
  • 56. A Bronx metal fabricator faced $115 thousand in fines for new as well as uncorrected or inadequately corrected hazards including: “ failure to develop and implement a hazard communication program , train employees, label containers or have (M)SDSs” www.MSDSonline.com 1.888.362.2007
  • 57.
    • A New York waste and recycling
    • collection company faced $80
    • thousand in proposed fines for
    • violations including no hazard
    • communication program
    • or training
    www.MSDSonline.com 1.888.362.2007 Photo: :© From Wikimedia Commons. User “blahedo”
  • 58. Q: The HCS Reg only applies to large chemical and manufacturing companies Fact or Fiction? www.MSDSonline.com 1.888.362.2007 Even small businesses need to comply with the regulation if they’re “using” hazardous chemicals Fiction
  • 59. A construction company in Ohio with just 3 employees , was fined $7,500 . Citations included failing to have an ( M)SDS for each hazardous chemical, failing to train employees to recognize and avoid unsafe conditions and failing to train workers who used hazardous chemicals. www.MSDSonline.com 1.888.362.2007
  • 60. 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
  • 61. Remember it’s not just about… www.MSDSonline.com 1.888.362.2007
  • 62.
      • Avoiding citations…
    www.MSDSonline.com 1.888.362.2007
  • 63.
      • … and fines
    www.MSDSonline.com 1.888.362.2007
  • 64. it’s also about… www.MSDSonline.com 1.888.362.2007
  • 65. our employees … www.MSDSonline.com 1.888.362.2007
  • 66. our customers … www.MSDSonline.com 1.888.362.2007
  • 67. our community… www.MSDSonline.com 1.888.362.2007 Photo: © 2009 from Wikimedia Commons. User “Reck345”
  • 68. www.MSDSonline.com 1.888.362.2007
  • 69. Thank You  1.888.362.2007  www.MSDSonline.com  [email_address] www.MSDSonline.com www.MSDSonline.com 1.888.362.2007