Hazard Communication Emergency Response

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Hazard CommunicationEmergency Response

• WSHSC
• July 31, 2009

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Employer Chemical Hazard Communication

• WAC 296-800-170 HazCom
• Four Major Parts
• MSDS
• Labeling
• Training
• Written Program

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Hazard Communication

• Employees have the right to know about hazardous
  chemicals at their worksite
• What the chemicals are,
• What are the hazards,
• How to protect themselves.

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This training will cover

• What are hazardous chemicals
• Exemptions
• MSDSs
• Labeling
• Training
• Written Program

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What are hazardous chemicals?

• "Hazardous Chemical" is a term that is broadly
  used in the hazard communication rule.
• A hazardous chemical includes
• solvents
• glues
• paints
• products that may release a hazardous chemical.

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What are hazardous chemicals?

• Flammables cause thermal burns or death
• Corrosives cause chemical burns to skin, eyes or
  lungs
• Toxics cause reversible or permanent effects to
  internal organs or whole body

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What are hazardous chemicals?

• Sensitizers cause allergic response from repeated
  doses.
• Irritants cause reversible effects.
• Carcinogens cause cancer usually over a long
  time.

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What are hazardous chemicals?

• Generally if an item is regulated by another
  federal rule it is not covered by hazard
  communication.
• The following slides present items that may be
  exempted from the rule please see WAC
  296-800-17055 for the specific exemptions.

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Exempted items not covered

• Hazardous waste
• Articles (solid objects)
• Most drugs
• Food and alcoholic beverages

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Exempted items not covered
Cosmetics Consumer products (most of the
time) Tobacco tobacco products
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Articles when they are are not covered

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HazCom Breakdown

• Four Major Parts to the Standard
• Material Safety Data Sheets (MSDSs)
• Labeling Chemical Containers
• Employee Training
• Written Program

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MSDSs what information do they have?

• Names of hazardous chemicals in a product,
• Physical and chemical properties of the product,
• Physical hazards of working with the product,
• Short and long term health hazards of working
  with the product (including signs and symptoms of
  overexposures),

Acetone
Flammable highly volatile
Burns
Headaches, eye irritation
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Material Safety Data Sheet

• The main way the chemical enters the body,
• The legal limit allowed in the air
• If the chemical is a carcinogen
• Precautions for safe use of the hazardous
  chemical,

Inhalation
750 ppm
No
Adequate ventilation, keep away from open flame
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Material Safety Data Sheet

• Exposure control methods, including personal
  protective equipment,
• Emergency and first aid procedures,
• The date the MSDS was prepared or revised,
• Name, address and phone number of the person
  responsible for the information in the MSDS.

Wear respirator, rubber gloves
Eyes flush with water for 15 minutes
1996
John Doe 1234 Maple St. Anywhere, USA
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Trade Secrets

• Manufacturer can withhold name of specific
  chemicals in a product
• Hazard information must still be disclosed in
  MSDS
• In emergencies name of chemical must be disclosed
  for medical treatment
• Disclosure also required if written request made
  for certain purposes

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Labels

• Chemicals Labeled with the Following
• Identity of hazardous chemical
• Hazard warnings including health effects

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Labels

• Labels NOT required if the product
• Will be used in same work shift
• Is used by person who did the transfer
• Is under the control of the person who did the
  transfer

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Training

• What hazardous chemicals are used in the work
  area
• How to work safely with these chemicals
• How the employee can tell if he or she is being
  overexposed
• What information is available in a material
  safety data sheet (MSDS)
• Where to find MSDSs in the work area
• Information on the requirements of the Employer
  Chemical Hazard Communication Rule

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• Training and Information

• Employees must be trained on how to work safely
  with hazardous chemicals.
• This includes the things you have done to protect
  employees including
• Engineering controls,
• Work practices
• Emergency Procedures
• Personal Protective equipment
• The labeling system you use
• How to find information on the hazards in the
  material safety data sheet or label.

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Employees must be trained on the methods used
to detect the presence or release of hazardous
chemicals in the work area.

• Air monitoring
• Continuous monitoring devices
• The visual appearance or odor of the chemical
• The physical and health hazards of the hazardous
  chemical

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Hazard Communication Program

• Identify hazardous chemicals and make a list
• Obtain MSDSs for each product
• Make MSDSs easily accessible
• Ensure containers are labeled
• Develop a written program
• Ensure effective training

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Hazard Communication - Special Situation

• If only sealed containers are handled
• No written program required
• Keep MSDSs if received
• Existing labels must be intact
• Spill or leak response training required

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Hazard Communication - Written program

• Tailored to the worksite
• List of hazardous chemicals
• Labeling
• MSDSs
• Training
• Non-routine tasks
• Multi-employer worksites (if needed)

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HazCom Multi-employer Worksites

• Several employers at one site
• More than one employers employees are
  visiting/working
• Mutual responsibility to share information
• Not just construction sites (janitorial, pest
  control, maintenance contractors)

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Emergency Response (WAC 296-824)
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Emergency Response

• A response to an anticipated release of a
  hazardous substance that is, or could become, an
  uncontrolled release

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Hazardous Substance

• Any biological, radiological, or chemical
  substance that can have adverse effects on humans
  (see WAC 296-824-800 for a more specific
  definition).

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Uncontrolled Release

• A release where significant safety and health
  risks could be created. Releases of hazardous
  substances that are either incidental or couldn't
  create a safety or health hazard (i.e., fire,
  explosion, or chemical exposure) aren't
  considered to be uncontrolled releases.

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Incidental Release

• A release that can be safely controlled at the
  time of the release and does not have the
  potential to become an uncontrolled release.

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Danger Area

• Areas where conditions pose a serious danger to
  employees, such as areas where
• Immediately dangerous to life or health (IDLH)
  conditions could exist
• High levels of exposure to toxic substances could
  exist
• There is a potential for exceeding the lower
  explosive limit (LEL), also known as the lower
  flammability limit (LFL), of a substance.

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IDLH

• Any atmospheric condition that would
• Cause an immediate threat to life
• Cause permanent or delayed adverse health effects
  
• Interfere with an employee's ability to escape

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Limited Action

• Action necessary to
• Secure an operation during emergency responsesor
  
• Prevent an incident from increasing in severity.
• Examples include shutting down processes and
  closing emergency valves.

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NIOSH Pocket Guide to Chemical Hazards

• IDLH of Formaldehyde is 20 ppm
• Formaldehyde has a low vapor pressure
• Dependant on size of room, ventilation rate, and
  surface area of the spill

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Basic Requirements

• Written Emergency Response Plan
• Training Responders
• Medical Surveillance
• Recordkeeping
• Management of Emergency Operations
• Incident Command
• Personnel Briefing

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Basic Requirements, Cont..

• Buddy System 2 In and 2 Out
• Rescue and Medical Assistance
• Personal Protective Equipment
• Post Emergency Response Operations

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Common Findings

• No plans
• There doesnt appear to be any clear roles or
  assigned duties.
• Responders have not received adequate training
• No procedures for limited actions
• Personal Protective Equipment
• No Command Structure

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Key Questions

• Are employees expected to participate in an
  emergency response?
• Is the facility covered by community emergency
  response plan?

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Key Points

• Emergency response is not defined by the quantity
  of hazardous substance or the level of PPE. It
  depends on the danger and the safety and health
  risk the release may pose to employees.

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Key Points

• The level of training depends on the role
  employees will be expected to play in the event
  of an emergency response.

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Key Points

• All emergency response personnel must receive
  annual refresher training.

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Key Points

• The emergency response planning and procedures is
  to be based on the worst case scenarios.

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Key Points

• Selection of PPE is to be based on the worst case
  scenarios.

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Key Points

• The emergency response plan and procedures is to
  be site specific.

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Compliance Issues/Recommendations

• Use Small Containers of Formaldehyde
• Prefilled containers for Specimens
• Proper Amount of Absorbent
• MSDS for concentration used
• Clearly Define Roles for a Spill
• Who responds, who evacuates

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Compliance Issues/Recommendations

• Badge Sampling
• Methanol Mixed with Formaldehyde
• Methanol Interferes with Sample
• 35 Below Actual Exposure

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Directives and Other Assistance

• WRD 12.75 Emergency Response to Hazardous
  Substance Releases
• WRD 10.6 1994 NIOSH Pocket Guide IDLH Values
• WRD 32.99 Post Emergency Oil Spill Response
  Operations
• The United States Department of Transportation's
  Emergency Response Guidebook (search at
  http//www.dot.gov).

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Directives and Other Assistance, Cont.

• WISHA Helpful Tools Developing Emergency
  Response Plans
• National Fire Protection Association (NFPA) A
  variety of standards and guides for emergency
  response activities.