OSHA’s Hazard Communication Standard came out in the 1980s with a bang. Initially, few businesses were able to avoid a citation for noncompliance to its chemical safety provisions. Hazard Communication remains one of the most frequently cited standards in the electrical construction industry and warrants a review.
The Hazard Communication Standard is often called “right-to-know,” as it covers the employees’ right to know about hazardous chemicals in the work place. The law requires employers to inform employees of these chemicals. It describes specific actions that must be taken.
The first action is an evaluation of the chemicals used or stored in the work area. Generally, determining whether or not a chemical is a hazard is the manufacturer’s or distributor’s responsibility. They must provide Material Safety Data Sheets (MSDS) to identify a chemical’s hazards. However, there are times when a hazardous chemical is generated as a by-product of the operation. For example, a contractor working on a mall renovation may be required to produce safety information for carbon monoxide produced by a forklift being used.
Once the evaluation is complete, a hazardous chemical inventory list must be prepared for each job site. Certain hazardous chemicals are exempt. Substances such as hazardous waste, tobacco, drugs in tablet or pill form and cosmetics are addressed by other standards or are considered items for personal use. Articles are also exempt. Articles are materials, like a wooden chair, that normally would not be a hazard to employees. A chair could burn, but considering the way it is used, it is not a hazard. Consumer products may be exempt depending on the way they are used. For example, furniture polish used regularly in a hotel would count. Furniture polish used by an electrician to clean a lunchroom once in a while would not make the list.
The list is part of the Written Hazard Communication Program. The law requires a Written Program that describes how an employer has complied with the standard. The employer must include a description for each action listed in the standard. These actions are: conducting an evaluation or inventory of hazardous chemicals, preparing the written program, labeling all chemicals, providing MSDSs and training. The complete program, including the list, must be made available upon request to employees or employee representatives.
All hazardous chemicals covered by the standard must be labeled. The label will include the name of the chemical and a warning. The warning should describe the hazards of the chemical using symbols or words. The name can be the actual chemical name or a common name. Any name that is used should match the name on the MSDS. If the chemical is shipped, it must also include the name and address of the distributor or manufacturer.
If a chemical is transferred from one container to another, label information must be transferred as well. The one exception is “immediate use” containers. If a chemical is transferred to a container that will be used by that individual alone and will be used up by the end of the shift, no label is required. Use caution here; if anyone else has access to or uses the container, it must be labeled.
MSDS is a complete description of a hazardous chemical. It describes the chemical’s ingredients and characteristics, hazards, precautions and first aid procedures. If an emergency were to occur, this ensures that you have access to important information found on the MSDS.
When working on a multi-employer site, all tradespeople must exchange MSDSs for hazardous chemicals that will be present during those work operations. Make sure this is covered in the pre-job meeting with the controlling contractor on the site.
Training is the final action. Each of the other actions, such as inventory, MSDSs and the written program, provide a tool for learning about the hazardous chemicals. The training should use these tools. It must include information on the standard and the written program. Operations that include hazardous chemicals must be identified. Training must show how to read MSDSs, the labeling system used, the hazards of and protection needed for the chemicals used. Whenever a non-routine task occurs, additional training must be provided. How this will be addressed must be identified in your written program.
Don’t be the next victim of an OSHA citation for this old standard. Perform a thorough inventory of the chemicals associated with each job. Remember, any amount counts, so don’t forget the small-quantity items. Look at the labels and try to determine if the materials are hazardous or not. Ensure that you have a MSDS for each product on your list. Train your employees as needed. EC
O’CONNOR is with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. Based in Waverly, Pa., he can be reached at 607.624.7159 or firstname.lastname@example.org.