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OSHA HAZARD COMMUNICATION HAZCOM STANDARD 29 CFR 1910'1200

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Title: OSHA HAZARD COMMUNICATION HAZCOM STANDARD 29 CFR 1910'1200


1
OSHA HAZARD COMMUNICATION (HAZCOM) STANDARD29
CFR 1910.1200
  • FOR TULANE LABORATORY OR FACILITY EMPLOYEES WHO
    WORK WITH OR AROUND CHEMICALS
  • January, 2005

2
OBJECTIVES
  • Employees shall learn about Tulanes written
    Hazard Communication Plan
  • Employees shall learn how to report and the
    reasons for reporting their chemical inventory
  • Employees shall learn about proper container
    labeling
  • Employees shall learn about Material Safety Data
    Sheets (MSDSs) and how to obtain them
  • Employees shall learn how to find information on
    chemicals they may encounter on the job and how
    to protect themselves

3
OSHA HAZARD COMMUNICATION STANDARD
  • States You Have a Right to Know about Chemical
    Hazards in the Workplace and How to Protect
    Yourself
  • Tulane has a Written Hazard Communication Plan
    located in the OEHS Policies and Procedures
    Manual (see the OEHS website www.som.tulane.edu/oe
    hs)
  • A Supervisors Guide to the OSHA Hazard
    Communication (HAZCOM) Standard is available on
    the OEHS Website under the Chemical Safety Link

4
OSHA HAZARD COMMUNICATION STANDARD
  • Under the OSHA HAZCOM standard, manufacturers of
    chemicals are required to evaluate the hazards of
    the chemicals they produce and transmit that
    information to customers on labels and Material
    Safety Data Sheets (MSDSs)

5
EXEMPTIONS FROM HAZCOMOSHA HAZCOM deals with
chemical hazards. Other agencies such as the EPA
or the FDA cover some of these other products.
  • RADIATION
  • BIOHAZARDS
  • HAZARDOUS WASTE
  • OVER-THE-COUNTER DRUGS
  • DRUGS IN SOLID FORM
  • FIRST AID SUPPLIES
  • COSMETICS
  • FOOD AND BEVERAGES
  • WOOD PRODUCTS
  • CONSUMER PRODUCTS (Depending on quantity or
    frequency of use such as cleansers)
  • ARTICLES (such as clothing)

6
SUBMITTING ANNUAL CHEMICAL INVENTORIES
  • Electronic submission (Excel, Paradox, Access or
    other delimited format) of your annual chemical
    inventory database/spreadsheet to OEHS is
    preferred, although OEHS does accept paper
    copies.
  • A sample chemical inventory form is available on
    the OEHS website www.som.tulane.edu/oehs under
    the Chemical Safety link. Submit your database
    or spreadsheet annually to pfatlan_at_tulane.edu
    or jfolse_at_tulane.edu.

7
SUBMITTING ANNUAL CHEMICAL INVENTORIES
  • The Operations Committee is looking into
    alternative methods of reporting Chemical
    Inventory
  • (such as BarCoding, Radio-Frequency Tagging,
    etc.)
  • OEHS will keep you informed of any changes.

8
CHEMICAL INVENTORY FORM(Form available at
www.som.tulane.edu/oehs under Chemical Safety
link) Required Information
  • CAS (Chemical Abstract Service) Number
  • Product or Catalog Number
  • Number of Containers
  • Total amount of material units (ml, g, lb)
  • Container Type/Size (glass, plastic/ml, g, lb)
  • Supervisor/PI
  • Department
  • Campus/Bldg/Rm
  • Date of Inventory
  • Product/Chemical Name
  • Manufacturer
  • Have MSDS? (Y/N)

9
CHEMICAL INVENTORY FORM(Form available at
www.som.tulane.edu/oehs under the Chemical Safety
link)
  • All information is important for regulatory
    reporting and must be submitted.
  • If amounts vary on any given day, simply indicate
    the amount of each material that is available on
    the day the inventory is taken.
  • Each chemical has a unique CAS number. Mixtures
    will have a CAS number for each chemical in the
    mixture. Some materials are trade secrets and
    will not list the CAS numbers.
  • Submit as much information as you can.
  • Previously submitted inventories can be obtained
    from OEHS for updating. Contact Pam Fatland.

10
PURPOSE OF UPDATING CHEMICAL INVENTORY
  • To verify that you have the Material Safety Data
    Sheets (MSDSs) you need in the work area and so
    the OEHS library of MSDSs is complete
  • Emergency Responders need inventory for
    emergencies, such as fires and spills, and for
    planning purposes
  • To perform a hazard evaluation of the area,
    obtain appropriate PPE, verify proper storage and
    that containers are in good condition and not
    expired

11
PURPOSE OF UPDATING CHEMICAL INVENTORY
  • Tulane is required to report inventory to local,
    state, and federal agencies such as the EPA, the
    State Police, and the Fire Department
  • Fees based on the inventory must be paid to
    regulatory agencies (Example City of New Orleans
    Hazardous Materials Tax which helps to support
    the Fire Depts HAZMAT unit)

12
CHEMICAL LABELS Required Information
  • Full Chemical Name
  • Physical and Health Hazards (Flammable,
    Corrosive, Toxic)
  • Manufacturer Name/Address/Phone Number (on
    incoming containers)

13
CHEMICAL LABELS Required Information
  • Labels are required on all incoming containers,
    all transfer containers that will be left for a
    period of time, and on all containers that will
    be used by more than one person
  • You can label an entire shelf instead of each
    individual container if all containers on the
    shelf contain the same thing (Ex. specimen
    containers of ethanol)
  • Labels must be legible, in English, and have the
    full name of the chemical spelled out (no symbols
    or abbreviations)

14
CHEMICAL LABELS Required Information
  • The purpose of labeling is to identify the
    material and to become aware of the hazards and
    the methods of protection
  • Sometimes OSHA requires special wording to appear
    on the label of certain chemicals or at the
    entrance to a regulated area (Ex. Formaldehyde
    containers must say Irritant and Potential
    Cancer Hazard)

15
More Chemical Label InformationSometimes labels
contain other information that serve to enhance
the hazard warnings and identify means of
protection, such as
  • Signal Word (e.g., Danger, Warning, Caution)
  • First Aid Procedures
  • Handling Storage (e.g., Avoid contact with
    Acids)
  • Special Instructions (e.g., Keep out of reach of
    children, Use with adequate ventilation)

16
Chemical Labeling SystemsOptional information
which may be found on a container label
  • The National Fire Protection Association (NFPA)
    uses a color-coded diamond with a numerical
    rating system to identify the degree of health
    (blue), fire (red), or reactivity (yellow)
    hazards associated with a chemical in a fire
    situation. A zero means minimal hazards whereas
    a four indicates severe hazards.

17
Chemical Labeling SystemsOptional information
which may be found on a container label
  • The National Paint and Coatings Association uses
    the Hazardous Materials Identification System
    (HMIS), a similar system of labeling which rates
    chemicals from zero to four on their health
    (blue), flammability (red), reactivity (yellow),
    and also gives personal protective equipment
    designations.

18
Chemical Labels
  • OEHS has labels available for portable containers
    where you can write in the full name of the
    chemical and check off the physical and health
    hazards, as well as personal protective
    equipment. Use of these is optional. Contact
    Jay Folse of OEHS to request these labels
    jfolse_at_tulane.edu.

19
LABORATORY DOOR SIGNSSignage for laboratory
doors stating the hazards found in the lab and
emergency contact information are available from
OEHS
  • Door sign request forms available on OEHS website
    www.som.tulane.edu/oehs under the Chemical Safety
    link form can also be used for updates of
    current signs
  • Signs contain stickers relating to hazards found
    in that laboratory (Example Flammable,
    Corrosive, Water Reactive)
  • Signs also contain authorized admittance/emergency
    contact information which should be used before
    entering a lab or during an emergency to contact
    appropriate personnel
  • Copies of signage forms are kept in OEHS for
    emergency response purposes

20
DEFINITIONSFamiliarize yourself with terms found
on chemical labels/MSDSs
  • Under MSDS link of OEHS Website
    www.som.tulane.edu/oehs see
  • MSDS HyperGlossary - http//www.ilpi.com/msds/re
    f/

21
DEFINITIONS
  • CARCINOGEN - Can cause cancer
  • CORROSIVE - Can cause destruction of living
    tissue (e.g., acids, caustics)
  • EXPLOSIVE - Can cause release of pressure, gas,
    and heat
  • FLAMMABLE - Can burn when ignition source and air
    are present

22
DEFINITIONS
  • IRRITANT - Can cause reversible inflammatory
    effect (e.g., eyes water, itching)
  • OXIDIZER - Promotes combustion oxygen
  • SENSITIZER - Can cause an allergic reaction in
    some people
  • TOXIC - Can cause health effect

23
ROUTES OF ENTRYChemicals can enter the body in a
number of ways. Depending on the chemicals
route of entry, you may need respiratory
protection, skin protection such as gloves or
aprons, or face and eye protection such as face
shields and goggles.
  • INHALATION Nose
  • INGESTION Mouth
  • SKIN CONTACT Skin, Eyes
  • INJECTION Skin (subcutaneous vs. dermal)

24
MATERIAL SAFETY DATA SHEETS (MSDSs)
  • MSDSs are documents that inform you of the
    hazards associated with a chemical and how to
    protect yourself from those hazards
  • MSDSs must be readily accessible to employees in
    the work area where the chemicals are used
  • Each company publishes its own MSDSs with their
    address and emergency contact information. Thus
    if you have a chemical such as acetone from two
    different manufacturers, you will need an MSDS
    from both of those manufacturers

25
MATERIAL SAFETY DATA SHEETS (MSDSs) (The
following are types of information that can be
found on an MSDS)
  • Identity
  • Ingredients
  • Physical Properties
  • Hazards
  • Physical
  • Health
  • Precautions
  • Storage
  • Control Measures
  • Disposal
  • Spills
  • Personal Protective Equipment (PPE)

26
MATERIAL SAFETY DATA SHEETS - ACQUISITION
  • Manufacturers are required to ship MSDSs to
    Tulane with the first shipment of a chemical
  • OEHS maintains a hard-copy library of all MSDSs
    received from the manufacturers and all chemicals
    listed on the inventories that are submitted.
    The OEHS library of MSDSs is kept at the OEHS
    office downtown, the OEHS office Uptown, and at
    the Primate Center
  • MSDSs are also available on the OEHS website
    www.som.tulane.edu/oehs under the MSDS link
  • The OEHS website/MSDS link also contains FAX
    numbers for common chemical manufacturers
  • Contact OEHS if you have trouble finding an MSDS
    that you need

27
MATERIAL SAFETY DATA SHEETS ACQUISITIONWays to
Obtain MSDSs at Tulane
  • OEHS Website www.som.tulane.edu/oehs then click
    on the MSDS link
  • Online MSDS collections
  • Online Manufacturer Links
  • Manufacturer FAX numbers
  • Other University Websites
  • OEHS Library of hard copies of MSDSs

28
ELECTRONIC MATERIAL SAFETY DATA SHEETSOSHA now
recognizes that MSDSs can be kept electronically
in the work area, if all of these criteria are
met
  • All employees are trained on how to obtain MSDSs
  • MSDSs are able to be printed
  • An alternative to obtaining MSDSs in the event of
    power loss or other emergency must exist (Contact
    OEHS Library of MSDSs)

29
TRADE SECRETS
  • The OSHA HAZCOM standard provides for protection
    of trade secrets.
  • The identity of a trade secret chemical must be
    given to health professionals, employees, or
    designated representatives in a medical
    emergency. The chemical manufacturer may require
    a written statement of need and confidentiality
    agreement as soon as circumstances permit.
  • In a non-emergency, the health professional,
    employee, or designated representative may
    provide a written request for disclosure of a
    chemicals identity. This written request may be
    denied but the manufacturer must explain how
    alternate information will satisfy the specific
    occupational or medical need. OSHA may be
    contacted to review the request and denial.

30
TRAININGAll who work with or around chemicals
must be trained.
  • All training must be documented.
  • Training forms can be found at www2.som.tulane.edu
    /oehs/safety/04F-oehss03.pdf.
  • Online quizzes for this training Powerpoint
    presentation will go directly to OEHS and will
    serve as your training documentation for the OSHA
    Hazard Communication Standard Powerpoint
    presentation.
  • Supervisors must provide training on specific
    chemical hazards in the work area, PPE and/or
    work practices to use while doing your job, etc.

31
TRAININGAll who work with or around chemicals
must be trained.
  • You must be able to show you understood the
    training.
  • Quiz
  • Random Interviews (Be able to answer
    questions)
  • Demonstrations (actually obtain an MSDS)

32
OSHA REQUIRED TRAINING INFORMATIONEmployees must
be familiar with the following
  • The requirements of the OSHA HAZCOM standard
  • Any operations in their work area where hazardous
    chemicals are present
  • The location and availability of Tulanes written
    HAZCOM plan and how to obtain MSDSs

33
OSHA REQUIRED TRAINING INFORMATIONEmployees must
be familiar with the following
  • How to detect the presence or release of a
    hazardous chemical in the work area
  • Physical and health hazards of chemicals present
    in the work area
  • How to protect oneself from hazards
  • Details of Tulanes HAZCOM program including
    labeling and MSDSs

34
OSHA REQUIRED TRAINING INFORMATIONEmployees must
be familiar with the following
  • For hazards of non-routine tasks, check with your
    supervisor
  • For specific emergency procedures for your area,
    check with your supervisor
  • For hazards associated with unlabeled pipes in
    the work area, contact Facilities Services

35
CONTRACTOR INFORMATION
  • Contractors who could be exposed to chemicals at
    Tulane must be given the opportunity to review
    Tulanes written HAZCOM Plan and must be told
    about particular hazards in the work areas in
    which they will be working
  • Tulane and OEHS will provide MSDSs to contractors
    upon request

36
CONTRACTOR INFORMATION
  • Contractors who bring chemicals on Tulane
    property to be used in the course of their work
    must supply Tulane with a list of these
    chemicals, and must supply MSDSs and information
    to Tulane upon request
  • See OEHS Policies and Procedures Manual at
    www.som.tulane.edu/oehs for more information on
    contractors and HAZCOM

37
SUMMARY - HAZCOM COMPLIANCE CHECKLISTAre you in
compliance with HAZCOM?
  • Annual chemical inventory submitted to OEHS
  • Access to MSDSs available in the work area
  • Training documentation forms/quizzes on HAZCOM
    topic sent to OEHS
  • Proper container labeling for all containers in
    work area
  • Up-to-date door labels for laboratories
  • Familiarity with Tulanes written Hazard
    Communication Plan available in OEHS Policies
    Procedures Manual on OEHS website
    www.som.tulane.edu/oehs

38
Tulane UniversityOffice of Environmental Health
Safety (OEHS) www.som.tulane.edu/oehs Pam
Fatland, Chemical Safety Manager(504) 988-2800 /
pfatlan_at_tulane.eduIf unable to proceed to quiz,
type the link below into your browserhttp//auror
a.tcs.tulane.edu/ehs/enterssn.cfm?testnum12
Proceed to Quiz
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