HAZARD COMMUNICATION TRAINING MODULE There was a time when employees had no legal means to force their employers to provide them with information about the hazardous substances they used at work. They demanded a “Right-to-Know,” or the right to have access to such information, which resulted in the Federal Occupational Safety and Health Act (OSHA). The standards established by OSHA (particularly 29 CFR 1910 and 1926) are now better known as the “Hazard Communications” or “Right-toKnow” standards. All employees have the right to know of properties and potential safety and health hazards of substances to which they may be exposed. Such knowledge is essential to reducing the risk of occupational illness and injury.

Goals of Right to Know: To help you reduce the risks involved in working with hazardous materials. To transmit vital information to employees about real and potential hazards of substances in the work place. To reduce the incidence and cost of illness and injury resulting from hazardous substances. To promote public employer’s need and right to know. To encourage a reduction in the volume and toxicity of hazard substances. This Hazard Communications – Right to Know Training Module includes the following: Material Safety Data Sheets (MSDS) Labeling & Marking Employee Incident Reports Hazard Communication Quiz

Material Safety Data Sheets (MSDS) The Material Safety Data Sheet (MSDS) is a detailed information bulletin prepared by the manufacturer or importer of a chemical that describes the physical and chemical properties, physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures, and control measures. Information on the MSDS aids in the selection of safe products and helps prepare employers and employees to respond effectively to daily exposure situations as well as to emergency situations.The MSDS’s are a comprehensive source of information for all types of employers. There may be information on the MSDS that is not useful to you or not important to the safety and health in your particular operation. Concentrate on the information that is applicable to your situation. Generally, hazard information and protective measures should be the focus of concern.

Your Rights 1. Your workplace is required to have Material Safety Data Sheets available for every single hazardous chemical or substance you use or encounter as part of your job. 2. These must be readily available for employee review at all times you are in the work place! In other words, they cannot be locked in an office or filing cabinet to which you do not have access. 3. If you request to see an MSDS for a product you use at work, and your employer cannot show it to you, after one working day you may refuse to work with that product until you are shown the correct MSDS. 4. If you request your own personal copy of a Material Safety Data Sheet, your employer has 15 working days to provide it. 5. If you do not know where the MSDS’s for your area are kept, find out!

Employer Responsibilities Employers must ensure that each employee has a basic knowledge of how to find information on an MSDS and how to properly make use of that information. Employers also must ensure the following: Complete and accurate MSDS’s are made available during each work shift to employees when they are in their work areas. Information is provided for each hazardous chemical.

What information is provided on an MSDS? OSHA specifies the information to be included on an MSDS, but does not prescribe the precise format for an MSDS. A non=mandatory MSDS form that meets the Hazard Communication Standard requirements can be used as is or expanded as needed. The MSDS must be in English and must include at least the following information:

Section I. Chemical Identity The chemical and common name(s) must be provided for single chemical substances. An identity on the MSDS must be cross-referenced to the identity found on the label.

Section II. Hazardous Ingredients For a hazardous chemical mixture that has been tested as a whole to determine its hazards, the chemical and common names of the ingredients that are associated with the hazards, and the common name of the mixture must be listed. If the chemical is a mixture that has not been tested as a whole the chemical and common names of all ingredients determined to be health hazards and comprising 1 percent or greater of the composition must be listed. Chemical and common names of carcinogens must be listed if they are present in the mixture at levels of 0.1 percent or greater. All components of a mixture that have been determined to present a physical hazard must be listed. Chemical and common names of all ingredients determined to be health hazards and comprising less than 1 percent (0.1 percent for carcinogens) of the mixture must also be listed if they can still exceed an established Permissible Exposure Limit (PEL) of Threshold Limit Value (TLV) or present a health risk to exposed employees in these concentrations.

Section III. Physical and Chemical Characteristics The physical and chemical characteristics of the hazardous substance must be listed. These include items such as boiling and freezing points, density, vapor pressure, specific gravity, solubility, volatility, and the product’s general appearance and odor. These characteristics provide important information for designing safe and healthful work practices.

Section IV. Fire and Explosion Hazard Data The compound’s potential for fire and explosion must be described. Also the fire hazards of the chemical and the conditions under which it could ignite or explode must be identified. Recommended extinguishing agents and firefighting methods must be described.

Section V. Reactivity (Instability) Data This section presents information about other chemicals and substances with which it reacts. Information on any hazardous decomposition product, such as carbon monoxide, must be included.

Section VI. Health Hazards The acute and chronic health hazards of the chemical, together with signs and symptoms of exposure, must be listed. In addition, any medical conditions that are aggravated by exposure to the compound must be included. The specific types of chemical health hazards defined in the standard include carcinogens, corrosives, toxins, irritants, sensitizers, mutagens, teratogens, and effects on target organs (i.e., liver, kidney, nervous system, blood, lungs, mucous membranes, reproductive system, skin, eyes, etc.). The route to entry section describes the primary pathway by which the chemical enters the body. There are three principal routes of entry: Inhalation, skin, and ingestion. This section of the MSDS supplies the OSHA PEL, the ACGIG TLF, and other exposure levels used or recommended by the chemical manufacturer. If the compound is listed as a carcinogen (cancer-causing agent) by OSHA, the National Toxicology Program (NTP), or the International Agency for Research on Cancer (IARC), this information must be indicated on the MSDS.

Section VII. Precautions for Safe Handling and Use The standard requires the preparer to describe the precautions for safe handling and use. These include recommended industrial hygiene practices, precautions to be taken during repair and maintenance of equipment, and procedures for cleaning up spills and leaks. Some manufacturers also use this section to include useful information not specifically required by the standard, such as EPA waste disposal methods and state and local requirements.

Section VIII. Control Measures The standard requires the preparer of the MSDS to list any generally applicable control measures. These include engineering controls, safe handling procedures, and personal protective equipment. Information is often included on the use of goggles, gloves, body suits, respirators, and face shields.

OSHA Requirements Employers must maintain a complete and accurate MSDS for each hazardous chemical that is used in the facility. They are entitled to obtain this information automatically upon purchase of the material. When new and significant information becomes available concerning a product’s hazards or ways to protect against the hazards, chemical manufacturers, importers, or distributors must add it to their MSDS within three months and provide it to their customers with the next shipment of the chemical. Employers must have a manufacturer specific MSDS for each hazardous chemical used in the workplace. While MSDS’s are not required to be physically attached to a shipment, they must accompany or precede the shipment. When the manufacturer/supplier fails to send an MSDS with a shipment labeled as a hazardous chemical, the employer must obtain one from the chemical manufacturer, importer, or distributor as soon as possible. Similarly, if the MSDS is incomplete or unclear, the employer should contact the manufacturer or importer to get clarification or obtain missing information. When an employer is unable to obtain an MSDS from a supplier or manufacturer, he/she should submit a written complaint, with complete background information, to the nearest OSHA area office. OSHA will then call and send a certified letter to the supplier or manufacturer to obtain the needed information. If the supplier or manufacturer still fails to respond within a reasonable time, OSHA will inspect the supplier or manufacturer and take appropriate enforcement action.

Material Safety Data Sheet Checklist If you work in a laboratory or other situation where you create your own chemical solutions or products for use in your workplace, you may need to write your own MSDS for the product(s) you have created. You must ensure that each MSDS you write contains the following information: Product or chemical identity used on the label Manufacturer’s name and address Chemical and common names of each hazardous ingredient Name, address, and phone number for hazard and emergency information Preparation or revision date The hazardous chemical’s physical and chemical characteristics, such as vapor pressure and flash point Physical hazards, including the potential for fire, explosion, and reactivity/instability Known health hazards OSHA permissible exposure limit (PEL), ACGIH threshold limit value (TLV) or other exposure limits Emergency and first-aid procedures Whether OSHA, NTP or IARC lists the ingredient as a carcinogen Precautions for safe handling and use Control measures such as engineering controls, work practices, hygienic practices or personal protective equipment required Primary routes of entry Procedures for spills, leaks, and clean-up

Labeling & Marking Always read the labels provided on the products you use! They will provide you with a wealth of information you need to know in order to use the product safely. NFPA Diamonds NFPA diamonds, from the U.S.-based National fire Protection Association, are used by emergency personnel to quickly and easily identify the risks posed by nearby hazardous materials. This is necessary to help determine what, if any, specialty equipment should be used, procedures followed, or precautions taken during the first moments of an emergency response. NFPA diamonds are used to determine the “worst” hazard present, but do not provide specific chemical names, quantities, or locations. Each diamond represents a different hazard. Blue = Health Hazard Red = Flammability Yellow = Instability White = Special Hazard Information

A numerical rating may also be provided in the blue, red, and yellow diamonds. This number indicated the severity of the hazard, with a 0 indicating no hazard and 4 indicating the most severe hazard.

NFPA Diamond Key:

HMIS Labels The HMIS labeling system operates on the same principal as the NFPA diamond Blue = health hazard Red = flammability Orange = physical hazard Special information (such as what personal protective equipment to wear) will be provided in the white section. It also used a numerical system from 0-4 to indicate the severity of the hazard. These labels are used on individual containers of hazardous materials (i.e. barrels, bottles, cans, buckets, tubs, etc.) so that there are never any unlabeled containers in the work area. It is recommended that they be used on all containers, even if the manufacturer’s label is still in place; however this is just a recommendation.

Always regard unlabeled containers as dangerous! If a substance is transferred from its original container into a portable container which is not labeled, the portable container must be labeled with an HMIS label to identify the contents of the container. All unattended containers should be labeled.

HMIS Labeling Key:

Blue/Health In the latest version of HMIS, the blue Health bar has two spaces – one for an asterisk and one for a numeric hazard rating. If present, the asterisk signifies a chronic health hazard, meaning that long-term exposure to the material should cause a health problem such as emphysema or kidney damage. The numeric rating signifies: 4

Deadly: life threatening, major or permanent damage may result from single or repeated exposures to this substance.

3

Extreme Danger: major injury likely from exposure to this substance unless prompt action is taken and medical treatment is given.

2

Dangerous: temporary or minor injury may occur from exposure to this substance.

1

Slight Hazard: irritation or minor reversible injury possible from exposure to this substance.

0

No Hazard: exposure to this substance offers no significant risk to health.

Red/Flammability For HMIS I and II, the numeric rating (0 = low hazard to 4 = high hazard) is identical to NFPA. For HMIS III, the numeric rating for flammability follows OSHA standards:

4 3 2 1 0

Flammable gases, or very volatile flammable liquids with flash points below 73 °F (23 °C), and boiling points below 100 °F (38 °C). Materials may ignite spontaneously with air (e.g. propane). Materials capable of ignition under almost all normal temperature conditions. Includes flammable liquids with flash points below 73 °F (23 °C) and boiling points above 100 °F (38 °C), as well as liquids with flash points between 73 °F and 100 °F. Materials which must be moderately heated or exposed to high ambient temperatures before ignition will occur. Includes liquids having a flash point at or above 100 °F (38 °C) but below 200 °F (93 °C) (e.g., diesel fuel) Materials which must be preheated before ignition will occur. Includes liquids, solids, and semi solids having a flash point above 200 °F (e.g., canola oil). Materials that will not burn (e.g., water).

Orange/Physical Hazard Prior to April 2002, this bar was yellow and signified levels of instability/reactivity. For the newer orange bar, reactivity hazards are assessed using the OSHA rating for the level of physical hazard:

4 3 2 1 0

Materials that are readily capable of explosive water reaction, detonation or explosive decomposition, polymerization, or self-reaction at normal temperature and pressure. Materials that may form explosive mixtures with water and are capable of detonation or explosive reaction in the presence of a strong initiating source. Materials may polymerize, decompose, self-react, or undergo other chemical change at normal temperature and pressure with moderate risk of explosion. Materials that are unstable and may undergo violent chemical changes at normal temperature and pressure with low risk for explosion. Materials may react violently with water or form peroxides upon exposure to air. Materials that are normally stable but can become unstable (self-react) at high temperatures and pressures. Materials may react non-violently with water or undergo hazardous polymerization in the absence of inhibitors. Materials that are normally stable, even under fire conditions, and will not react with water, polymerize, decompose, condense, or self-react. Non-explosives.

White/Personal Protection The white bar is used to identify what personal protective equipment (PPE) should be used when working with the material.

Employee Incident Reports If you are exposed to potentially hazardous substances that could result in acute (short term) or chronic (long term) health effects, you should fill out an Employee Injury/Accident Report. These reports may be filled out to document exposures to any hazardous substances including chemicals, asbestos, bloodborne pathogens, or others. Once completed, the report is submitted to Worker’s Compensation and filed with your personnel record.If you are exposed to a hazardous substance, it may take several years to develop a disease related to the exposure. The report is a protective measure to ensure eligibility for Workers’ Compensation to help pay your medical bills for a work-related illness. It should be understood that filling out this report is not an admission of liability on the part of RCS or the employee. These reports will not be used against the employee in any way. They are provided for your protection.



Hazard Communication Quiz 1. Which of the following will be found on a Material Safety Data Sheet (MSDS)? a. Spill and Leak Procedures b. Health Hazard Information c. Special Protection Information d. All of the Above 2. The yellow portion of an NFPA Diamond will represent: a. Health Hazard b. Flammability Hazard c. Instability Hazard d. Special Hazard Information 3. An incident report should only be filled out if you have suffered an acute (immediate) chemical injury such as an acid burn. a. True b. False 4. A “4” located in the red portion of an HMIS label indicates that a product: a. Is deadly b. Has a flash point below 73 °F, and a boiling point below 100 °F. c. May detonate d. Is corrosive 5. By law, you must receive hazard communications training each year. a. True b. False 6. Any unattended container with a substance shall have a label to identify the contents of the container. a. True b. False 7. Do you know where the MSDS’s for your building are kept? a. Yes b. No

8. Which of the following is NOT one of your rights concerning material safety data sheets? a. They must be available to you the entire time you are in the workplace. b. If you request to see one for a product you use, and your employer can’t provide it, you may refuse to work with that product after one working day (until it is shown to you). c. If you request your own copy of an MSDS, your employer has 15 say, by law, to provide that copy. d. Your employer must individually cover ALL the MSDS’s for substances you sue in an annual training session. 9. You have the right to know the potential safety and health hazards of substances to which you may be exposed. a. True b. False 10. If you have a question about a chemical or product, you may consult: a. Its MSDS b. Your building administrator c. The Director of Operations & Maintenance d. All of the above