At #3 on OSHAs’ Top Ten Most Frequently Cited Safety Standards is Hazard Communication, also known as the “right-to-know law.”  This standard (29 CFR 1910.1200) alone accounted for 6,378 violations during 2010.   The Manufacturing sector leads the way for the most Hazard Communication penalties ($1,138,606 total penalties), followed by the Construction industrywith $731,720 in total penalties.

Working Safely with Chemicals!

The primary reasons for the citations were due to lack of chemical evaluations and identifications, insufficient labeling, not having Material Safety Data Sheets (MSDS) available for each product, and inadequate employee safety training. 

We use chemicals in the workplace all the time, and sometimes these chemicals can be hazardous to our health which can cause injuries/illness, or even death.  Short-term health symptoms could include headache, dizziness, skin irritation, while long-term symptoms could be liver or lung damage or even cancer.   A good Hazard Communication Program is designed to protect employees who may be exposed to hazardous chemicals at their worksite. 

So what can you do?

To develop and implement a Hazard Communication Program, here are some steps to take:

    1. Assign Program Responsibility. Who is going to be responsible for your company’s Hazard Communication Program?  There are many safety responsibilities for all levels of management, but someone needs to take ownership of the program, and this person should have the full support of management, supervisors, and employees.
    2. Identify all Hazardous Chemicals. Conduct a complete and thorough inventory of all chemicals found in the workplace.  Next, determine if you have MSDS’s available for each chemical found? If you are missing MSDS’s contact the supplier and ask for a copy. Prepare a master chemical listing of all the chemicals used in the workplace.  If you can, properly dispose of all chemicals that are no longer needed. You should not use any chemicals for which you do not have MSDS on hand, since you may not know what personal protection may be required or what the first-aid procedures may be appropriate for employee exposure.
    3. Develop and Implement a Hazard Communication Program. A written safety plan is required by OSHA if you use hazardous chemicals. Some of the key elements of a company’s Hazard Communication Program should include the following:  
      • Company Information
      • Hazardous Ingredients
      • Physical Data
      • Fire and Explosion Hazard Data
      • Health Hazard Data
      • Reactivity (Instability) Data
      • Spill or Leak Procedures
      • Special Protection Information
      • Personal Protective Equipment
      • Special Precautions

Employee Safety TrainingOSHA estimates 80 to 90 percent of all accidents are caused in part by unsafe acts. Training, or the lack of training, plays a role in the occurrence of unsafe actions. No employee should handle or come into contact with hazardous chemicals unless they have been properly trained with respect to potential exposures. Many times the primary cause of chemical accidents is because the employer failed to provide adequately safety training. Information and safety training is a critical part of this program. Your written program should assign someone who will be responsible to provide the training.  Next, determine what training format will be used (DVDs, Power Point slide presentations).  Finally, maintain training records and procedures to train new employees at the time of their initial assignment to work and with hazardous chemicals, and to train employee when introducing a new hazard to the workplace.

Chemical Labeling. Containers of hazardous chemicals must be labeled or marked with the identification of the material and appropriate hazard warnings. Again, someone should be responsible for this to ensue labeling of the containers is done right, and that the chemicals are safety stored when not in use.   

Material Safety Data Sheets. OSHA’s standard for Hazard Communication requires all chemical manufacturers to provide material safety data sheets for each hazardous chemical they produce. Chemical distributors are required to provide their customers a copy of these MSDS’s. Employers must have a MSDS for each hazardous chemical they have on site. Employers should designate someone to be responsible to obtain and maintain all MSDS’s, and a list of hazardous chemicals should be kept current, and be part of the written program and will service as an inventory.   Below is the information which should be provided on an MSDS?

4.   Chemical Spill Response Plan. A good chemical spill response plan needs to be quick and effective. Even during a small spill, employees need to know right away how to contain the spill before it becomes a larger spill and results in damage. There is a lot to cover when describing a Chemical Spill Response plan. For this purpose I will cover a few items I think are important and fall in line with various types of emergencies.

Pre-emergency planning – think of different types of spills that could happen, and how would you respond.

Define employee roles and responsibilities – who is really responsible for this type of incident or event?

Communication – all spills should be reported immediately. Employees should know who is responsible for this program. Employees need to report what is leaking or spilled, where the spill is, what is the size of spill, and what is the rate of flow.

Evacuation Routes – if you’re not trained to respond for the spill or emergency then you should evacuate the area.  You should be familiar of the general of emergencies,

Site Security – until the emergency spill response team arrives should you secure the area, preventing other employee from entering the site.

Emergency Medical Treatment – for 911 situations be ready to assist the arrival of the fire department and medical personnel, for non-emergencies know where your workers’ compensation medical care clinic is located, and their hour’s operation.

Planning ahead and being prepared before you have a chemical incident or emergency is important! Employees need to know the hazards associated with each chemical they come in contact with or handle, they should know what the personal protection equipment (PPE) requirements are, and when to use PPE, and should know what to do in case of first-aid incident or during and large scale chemical spill were to happen.

Check out this web link via OSHA, where you can connect to a chemical database site for chemical’s physical properties, exposure guidelines, NIOSH Pocket Guide, Emergency Response Information, and DOT  Emergency Response Guide http://www.osha.gov/web/dep/chemicaldata/#target. 

Let us also help your company by building a Hazard Communication policy that fits the operations and proceedures you need.  Contact us at riskadvisor@praxiom-rm.com for  safety or claims management consulting as well as quoting and insurance placement.

John Titus