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The first step in setting up an effective HazCom program is to determine what constitutes as a chemical hazard. OSHA defines a hazard as: “the inherent capacity of a substance to cause an adverse effect.”
This vague definition offers the average contractor little help by assuming knowledge of chemicals and their effects. Fortunately, OSHA has offered a four-step approach for making determinations: 1. chemical selection for evaluation, 2. collect information about the selected chemicals, 3. process the information, and 4. record hazard determination and the chemicals.
Since most contractors do not manufacture the chemicals they use, these steps need to be reviewed from an end-user's point of view. The following explains each step as it would apply to an electrical contractor.
Step one: Chemical selection
This is a chemical inventory. Without qualification, every substance is a chemical. All substances must be looked at closely to determine if they are hazardous. Medications, cosmetics and other personal-use items are exempt, and items that do not present a hazard by the nature of their use can also be excluded.
For example, a wooden chair is considered an article. Although it can burn and give off carbon dioxide and other hazardous fumes, it typically will not present a hazard. OSHA's “consumer product” classification also provides an exemption for substances, such as Windex and White Out.
Exercise care when evaluating the actual use by employees. A lubricant used by a contractor on a tool or to loosen a fastener is not considered “consumer” use.
Once you have identified your exemptions, refer to the Material Safety Data Sheets (MSDSs) and any labels the manufacturer supplies. They will provide detailed information on the effects of the substance. Be cautious in your reliance on the data sheets. Chemical manufacturers often generate MSDSs on substances that would normally be considered safe, such as water.
Read the MSDS. Consider how the substance is used. Gasoline, when burned in an engine, produces carbon monoxide. OSHA may require the relevant MSDS if you are running equipment in an area where exposure to carbon monoxide could occur.
Make sure all chemicals are addressed. Next, inspect all areas that may house chemicals and include these on the inventory. The inventory should record the location and quantity of all chemicals listed. This will allow easy updates.
Step two: Collect information
This process should cover what type of information needs to be collected and where it will be found. The information required to complete the hazard identification will fall into three categories: chemical identity, chemical and physical properties, and health effects.
The first step is to gather as much information as possible on the identity and properties of the chemicals in the inventory. The main source is the MSDS. To identify hazardous chemicals that are byproducts of another chemical, consult product-safety bulletins from suppliers, the OSHA Chemical Information Database, and safety articles and information provided by the National Electrical Contractors Association (NECA).
Step three: Process information
Processing of the collected data means reviewing the MSDSs and other pertinent literature. Hazard evaluations depend heavily on the expert and professional judgment of others. This does not lessen the responsibility of employers to thoroughly review and evaluate all relevant materials.
Step four: Record the chemicals
The last step is recording the process. The company's HazCom program must include a section on how the hazardous chemicals list was compiled and the inventory itself.
Although this may seem like a huge task, it can be easily tackled by breaking it down into individual steps. Once it is determined what hazards do exist in your company, the information needs to be maintained and updated. In order to minimize the time and effort needed for maintenance and updating, OSHA stresses that a computerized system for your company's HazCom program and hazard determination policy be used. This will allow for greater flexibly and use of the information.
The NECA Safety Expert System Software has a record-keeping application for compiling a company-wide list of chemicals with the ability to generate a list of chemicals for each work area. For more information on the NECA Safety Expert System call 301.657.3110. 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 [email protected].