HAZARD COMMUNICATION

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HAZARD COMMUNICATION
Safe Use, Handling Storage of Chemicals and
Other Affected Materials

• The Engineering Program
• Texas AM University

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Topics to Review

• The Texas Hazard Communication Act
• The TAMU HazCom Program
• Requirements for Laboratory Departments
• HazCom Implementation Plans
• Supervisor Responsibility for Compliance
• HazCom in
• Research Labs
• Teaching Labs
• Chemical Storerooms

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What is HazCom?
The Texas Hazard Communication Act is a
state law that requires public employers
to provide employees with
specific information on the
hazards of chemicals to which they
may be exposed in the
workplace.
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HazCom Requirements

• Written Program (EHSD)
• Duties Responsibilities
• Non-Routine Release
• Training
• Inventory
• Labeling
• MSDS
• Supervision
• Notice to Employees
• Records
• Reports

• Implementation Plans
• Workplace - Dept
• Work Area - Supervisor
• Optional

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HazCom Facts

• Texas is not an OSHA State.
• HazCom for state agencies is under TDH.
• Private employers are regulated by OSHA.
• The Texas HazCom Act and TDH Rules are similar,
  but not identical with the OSHA Standard.
• Texas does not have a Lab Standard.
• TDH does recognize that research labs are
  different from other work places.

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Definitions
Employee anyone (including students) who is on
the payroll of TAMU or a TAMUS Agency and who may
be exposed to hazardous chemicals in the
workplace under normal working conditions or
foreseeable emergency. Facility Geographical
location of one or more workplaces. TAMU and the
Riverside Campus are facilities. Workplace
Usually a single building (BioBio) or complex of
buildings (Chemistry) where similar work
activities are conducted. Work Area Room, lab
or defined space within a workplace where
hazardous chemicals are present, produced, used,
or stored and where employees are present.
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HazCom at TAMU
Texas Hazard Communication Act Enforced by
TDH TAMU HazCom Program Administered by
EHSD Workplace Implementation Plan Dept. or
Administrative Unit Work Area
Implementation Plan Room, lab or space
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HazCom in Research Departments

• Appoint Hazard Communication Coordinator
• Prepare a Workplace Implementation Plan
• Post official TDH NOTICE TO EMPLOYEES
• Urge supervisors to complete a Work Area
  Implementation Plan
• Require supervisors to certify (at least
  annually) that all required training is complete
  and current.

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Workplace Implementation Plan

• Name of Department or Unit
• Responsible Person or Position
• Location of Training Records
• Location of MSDSs
• Notice to Employees Location
• Person Responsible for Inventory
• Location of Inventory File
• See Fill-in-the-Blank Form

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SPECIAL WORK AREAS

• Teaching Labs
• Chemical Stockrooms
• Research Labs

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Hazardous Chemical Inventory
Workplace quantities gt 50 gal. or 500
lbs Listed Extremely Hazardous
Substances Controlled Substances
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LABELS

• PRIMARY CONTAINERS
• Original label
• Intact
• Good condition
• Not removed or defaced

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Labeling Requirements
Primary Containers

• identity of material as on MSDS
• health and physical hazards (including target
  organs.)
• manufacturers name and address

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LABELING Secondary Containers

• Other Work Places
• Full label required on EVERY CONTAINER
• Identity of material as on MSDS
• Written hazard warnings
• Target organs

• Research Labs
• Full label NOT required
• Identify contents

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TEACHING LABS

• Container Labels
• Primary containers must have Full Labels
• Small 20containers may be labeled on rack or
  holder
• Chemical Inventory
• Incorporate into the Workplace Inventory.
• Workplace must report gt 50 gal or gt 500 lb. (or
  gt TPQ) for the Tier II Report

• Primary container labels must include
• identity of contents..same as on MSDS
• hazard warnings (including target organs or
  systems)
• Mfgr. name address

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CHEMICAL STOCK ROOMS

• Label all containers (unless for immediate use).
• Include in Workplace Inventory. Workplace must
  report gt 50 gal or 500 lb. or gt TRQ.
• NOTE
• A room or area that is connected to, and
  accessible ONLY through a research lab, is
  considered to be part of the lab.

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MSDS REQUIREMENTS

• READILY ACCESSIBLE - within one work shift
• CURRENT - most recent
• EHSD Recommendation
• Maintain printed copy for
• hazardous materials in use
• reasonable likelihood of exposure
• highly hazardous substances present in the work
  area
• Train employees on how to access MSDS
• http//ehsd.tamu.edu--MSDS Search
• Call EHSD 845-2132
• Call manufacturer request copy

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Required Training
General lab safety Chemical safety training Work
site specific training
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Changes in Training Requirements

• New employee video (aka Category I Training)
  DOES NOT satisfy training requirements.
• Training ONLY for employees who have routine
  exposure to hazardous chemicals.
• Category II Training now called
  Hazard-Specific Training.
• There is no requirement to repeat training.

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TRAINING RECORDS
Date Training Provided Name(s) of
Instructors Attendance List - Names MUST be
legible Subjects Covered
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GENERAL TRAINING

• General Lab Safety
• General Chemical Safety by Hazard Class
• Labeling Requirements
• General Ways to Access MSDS Information
• Interpretation and Relationship of Labels MSDS
• Safe Handling Procedures
• Proper Storage Separation of Incompatible
  Chemicals
• Minimizing Exposure -- PPE Safety Equipment
• General Emergency Procedures
• Spill Response Cleanup
• Management Disposal of Hazardous Chemical Waste
• Can be provided by EHSD

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SPECIFIC TRAINING
Site-Specific Chemical-Specific Hazard-Specific
Supervisor Responsibility
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Specific Information and Training

• Provide appropriate information and training to
  new or newly assigned employees before he/she
  work with or handles hazardous chemicals.
• Additional training is required when
• a new or significantly increased hazard is
  introduced into the work area,
• if the potential for exposure is significantly
  increased

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SITE-SPECIFIC TRAINING

• Where hazardous materials are located and used.
• Unusual or particularly hazardous materials or
  procedures
• Location and access to MSDS other safety
  information.
• Location and use of safety equipment (including
  PPE)
• Storage labeling procedures in the lab
• Emergency equipment procedures, first aid
• Exposure prevention and recognition
• Proper storage of hazardous materials
• Location and use of spill equipment
• Specific hazard information on the chemicals in
  the lab

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MSDS INFORMATION

• Chemical and Common Names
• Hazardous Ingredients
• Physical and Chemical Characteristics
• Physical Hazards
• Health Hazards
• Primary Routes of Entry
• Exposure Limits
• Confirmed or Potential Carcinogen
• Proper Handling and Storage
• Control Measures
• Emergency and First Aid Procedures
• Date of Preparation or Latest Revision
• Name, Address, Phone of Mfgr. or Responsible
  Party

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Hazard Communication Compliance in
Research Laboratories
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CHARACTERISTICS OF A RESEARCH LABORATORY(Accordin
g to TDH OSHA)

• Relatively small quantities of hazardous
  chemicals present and/or used.
• Not for production
• Containers, etc are designed for one person to
  easily and safely manipulate.
• Multiple chemicals and procedures used.
• Protective lab practices and equipment available
  and in common use.

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HazCom Requirements for RESEARCH LABS

• Technically qualified SUPERVISION
• Ready access to Material Safety Data Sheets
• LABELING on primary containers
• Employee TRAINING prior to potential exposure

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CONSEQUENCES of NON-COMPLIANCE
Loss of Research Lab Exemption Fines Personal
Employer Liability Personal Employer
Aggravation Paperwork
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WORK AREA IMPLEMENTATION PLAN

• Not required,but HIGHLY RECOMMENDED
• ADVANTAGES
• Minimal effort
• Proof of Training Compliance
• Customized Lab Safety Manual
• Reduction of Legal and Regulatory Liability

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OPTIONS FOR WORK AREA PLAN

• Do nothing or Do it yourself.
• Basic Plan
• Basic Plan plus Lab-Specific Protocols

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OPTION IBASIC IMPLEMENTATION PLAN

• Commitment to Safety Health
• Lab location
• Responsible persons
• Training documentation
• Sketch of lab
• MSDS Access - specific information
• Hazard warnings
• Hazard identification labeling
• Chemical inventory

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OPTION IILABORATORY SAFETY PLAN

• Basic Plan plus
• Principles of Laboratory Safety
• Strategies for Minimizing Exposure
• Engineering controls
• Administrative controls
• Protective equipment
• Laboratory Safety Rules and Procedures

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Laboratory Safety Rules Procedures

• Prudent practices
• Personal hygiene
• Food drinks in the lab
• Personal protective equipment
• Chemical fume hoods
• Chemical storage
• Hazardous waste
• Housekeeping
• Facility equipment maintenance
• Guards shields
• Glassware

• Fire prevention
• Cold traps cryogenic hazards
• Pressurized systems
• Unattended operations
• Working alone
• Prior approval
• Vigilance
• Everyday hazards
• Regulated/restricted areas or procedures
• Accident reporting
• Emergency information

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Working With Hazardous Chemicals

• Toxic Chemicals
• High acute or unknown toxicity
• High chronic toxicity
• High chronic toxicity - animal use
• Reproductive toxins
• Chemicals produced in the lab
• Physical hazards
• Flammable solvents
• Corrosive chemicals