Monitoring Monday – Hazard Communication

Hazard Communication Program

 The OSHA Hazard Communication Standard is designed to ensure chemical safety in the workplace.

The standard requires employers to provide written information about the identities and hazards associated with the chemicals they may be exposed to. Each employer must also describe in a written program how it will meet the requirements of the HCS in each of these areas. This program must include labels on containers of hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and provide training on handling the chemicals appropriately. This program must be available and understandable to workers (staff and volunteers).

This standard requires employers using hazardous chemicals to comply with four main requirements:

• Ensuring the proper chemical labeling on containers
  • Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
• Providing Safety Data Sheets (SDSs)
  • The SDS includes information such as the properties of each chemical; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical.
• Providing information and training to employees about chemical hazards in the workplace.
  • Employers are required to train on the label elements and safety data sheets to facilitate recognition and understanding.
• Developing and maintaining a written hazard communication program.

Water Quality Monitoring Programs can implement an effective hazard communication program by following these six steps:

Step 1. Learn the Standard/Identify Responsible Staff

• Obtain a copy of OSHA’s Hazard Communication Standard.
• Become familiar with its provisions.
• Make sure that someone has primary responsibility for coordinating implementation.
• Identify staff for particular activities (e.g., training).

Step 2. Prepare and Implement a Written Hazard Communication Program

• Prepare a written plan to indicate how hazard communication will be addressed in your facility.
• Prepare a list or inventory of all hazardous chemicals in the workplace.

Step 3. Ensure Containers are Labeled

• Keep labels on shipped containers.
• Label workplace containers where required.

Step 4. Maintain Safety Data Sheets (SDSs)

• Maintain safety data sheets for each hazardous chemical in the workplace. (Tips: Keep updates PDFs in a folder along with all of your equipment instructions. If your program does not have an SDS for specific material, you can contact the manufacturer to obtain one.)
• Ensure that safety data sheets are readily accessible to employees. (Tip: Maintain a binder of all SDSs and make it easily accessible to everyone.

Step 5. Inform and Train Employees

• Train employees on the hazardous chemicals in their work area before initial assignment, and when new hazards are introduced. Include the requirements of the standard, hazards of chemicals, appropriate protective measures, and where and how to obtain additional information.

Step 6. Evaluate and Reassess Your Program

• Review your hazard communication program periodically to make sure that it is still working and meeting its objectives.
• Revise your program as appropriate to address changed conditions in the workplace (e.g., new chemicals, new hazards, etc.).

What is a Safety Data Sheet (SDS)? 

Let’s take a look at Safety Data Sheets in more detail. A Safety Data Sheet (SDS) is the first stop for safety information about any chemical. SDSs are like instruction manuals for chemicals. Even the most seemingly innocuous, standard reagents like water, salt, and sugar have one, and they may read like a horror story. However, every SDS has the same 16 categories. This makes it so you can quickly learn the important facts about your reagent and handle it safely and confidently!

A chemical manufacturer, distributor, or importer must provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for hazardous chemicals to users to communicate information on these hazards.  They tell you their primary hazards, how to handle them, how to dispose of them, first aid and firefighting measures, how to post them, and more. SDSs also contain other information for each pesticide, such as physical properties, health effects, toxicity, first aid, personal protection controls, safe storage, and disposal.

Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency. Monitoring Programs may want to designate a person(s) responsible for obtaining and maintaining the SDSs.

 The SDS has 16 sections which include information such as properties of each chemical; physical, health, and environmental health hazards; protective measures; safety precautions for handling, storing, and transporting the chemical. 

Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., fire fighting).

Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision.

Section 1: Identification

This section identifies the chemical on the SDS as well as the recommended uses. It also provides

the essential contact information of the supplier. The required information consists of:

• Product identifier used on the label and any other common names or synonyms by which the substance is known.
• Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.
• Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier).

Section 2: Hazard(s) Identification

This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards. The required information consists of:

• The hazard classification of the chemical (e.g., flammable liquid, category1 ).
• Signal word.
• Hazard statement(s).
• Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions of the symbols in black and white or be a description of the name of the symbol (e.g., skull and crossbones, flame).
• Precautionary statement(s).
• Description of any hazards not otherwise classified.
• For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please note that this is a total percentage of the mixture and not tied to the individual ingredient(s)

Section 3: Composition/Information on Ingredients

This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of:

Substances

• Chemical name.
• Common name and synonyms.
• Chemical Abstracts Service (CAS) number and other unique identifiers.
• Impurities and stabilizing additives, which are themselves classified and which contribute to the classification of the chemical.

Mixtures

• Same information required for substances.
• The chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards and are:
  • Present above their cut-off/concentration limits or
  • Present a health risk below the cut-off/concentration limits.

• The concentration (exact percentages) of each ingredient must be specified except concentration ranges may be used in the following situations:
  • A trade secret claim is made,
  • There is batch-to-batch variation,
  • The SDS is used for a group of substantially similar mixtures.

Chemicals where a trade secret is claimed

• A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required.

Section 4: First-Aid Measures

This section describes the initial care that should be given by untrained responders to an

individual who has been exposed to the chemical. The required information consists of:

• Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion). 
• Description of the most important symptoms or effects, and any symptoms that are acute or delayed. 
• Recommendations for immediate medical care and special treatment needed, when necessary.

Section 5: Fire-Fighting Measures

This section provides recommendations for fighting a fire caused by the chemical. The required information consists of:

• Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation.
• Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns.
• Recommendations on special protective equipment or precautions for firefighters.

Section 6: Accidental Release Measures

This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. The required information may consist of recommendations for:

• Use of personal precautions (such as removal of ignition sources or providing sufficient ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing.
• Emergency procedures, including instructions for evacuations, consulting experts when needed, and appropriate protective clothing. 
• Methods and materials used for containment (e.g., covering the drains and capping procedures).
• Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning or vacuuming; adsorbent materials; and/or equipment required for containment/clean up).

Section 7: Handling and Storage

This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information consists of:

• Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited). 
• Recommendations on the conditions for safe storage, including any incompatibilities. Provide advice on specific storage requirements (e.g., ventilation requirements).

Section 8: Exposure Controls/Personal Protection

This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of:

• OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available.
• Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed system).
• Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, skin or respiratory protection needed based on hazards and potential exposure).
• Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; and breakthrough time of the glove material).

Section 9: Physical and Chemical Properties

This section identifies physical and chemical properties associated with the substance or mixture.

The minimum required information consists of:

• Appearance (physical state, color, etc.); • Upper/lower flammability or explosive limits;
• Odor; • Vapor pressure;
• Odor threshold; • Vapor density;
• pH; • Relative density;
• Melting point/freezing point; • Solubility(ies);
• Initial boiling point and boiling range; • Partition coefficient: n-octanol/water;
• Flash point; • Auto-ignition temperature;
• Evaporation rate; • Decomposition temperature; and
• Flammability (solid, gas); • Viscosity.

The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust’s explosive potential.

Section 10: Stability and Reactivity

This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other. The required information consists of:

Reactivity

• Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available.

Chemical stability

• Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled. 
• Description of any stabilizers that may be needed to maintain chemical stability.
• Indication of any safety issues that may arise should the product change in physical appearance.

Other

• Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur. 
• List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions). 
• List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation.
• List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.)

Section 11: Toxicological Information

This section identifies toxicological and health effects information or indicates that such data are not available. The required information consists of:

• Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact). The SDS should indicate if the information is unknown.
• Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
• The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a single dose.
• Description of the symptoms. This description includes the symptoms associated with exposure to the chemical including symptoms from the lowest to the most severe exposure.
• Indication of whether the chemical is listed in the National Toxicology Program (NTP)

Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions) or found to be a potential carcinogen by OSHA.

Section 12: Ecological Information (non-mandatory)

This section provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment. The information may include:

• Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available (e.g., acute or chronic aquatic toxicity data for fish, algae, crustaceans, and other plants; toxicity data on birds, bees, plants).
• Whether there is a potential for the chemical to persist and degrade in the environment either through biodegradation or other processes, such as oxidation or hydrolysis.
• Results of tests of bioaccumulation potential, making reference to the octanol-water partition coefficient (Kow) and the bioconcentration factor (BCF), where available.
• The potential for a substance to move from the soil to the groundwater (indicate results from adsorption studies or leaching studies).
• Other adverse effects (e.g., environmental fate, ozone layer depletion potential, photochemical ozone creation potential, endocrine disrupting potential, and/or global warming potential)

Section 13: Disposal Considerations (non-mandatory)

This section provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS.

The information may include:

• Description of appropriate disposal containers to use.
• Recommendations of appropriate disposal methods to employ.
• Description of the physical and chemical properties that may affect disposal activities.
• Language discouraging sewage disposal.
• Any special precautions for landfills or incineration activities.

Section 14: Transport Information (non-mandatory)

This section provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea. The information may include:

• UN number (i.e., four-figure identification number of the substance)
• UN proper shipping name
• Transport hazard class(es)
• Packing group number, if applicable, based on the degree of hazard.
• Environmental hazards (e.g., identify if it is a marine pollutant according to the International Maritime Dangerous Goods Code (IMDG Code)).
• Guidance on transport in bulk (according to Annex II of MARPOL 73/783 and the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (International Bulk Chemical Code (IBC Code)).
• Any special precautions which an employee should be aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises (indicate when information is not available).

Section 15: Regulatory Information (non-mandatory)

This section identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. The information may include:

• Any national and/or regional regulatory information of the chemical or mixtures (including any OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product Safety Commission regulations).

Section 16: Other Information

This section indicates when the SDS was prepared or when the last known revision was made. 

The SDS may also state where the changes have been made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here.

Employer Responsibilities Regarding Labels

Employers are responsible for maintaining the labels on the containers, including, but not limited to, tanks, totes, and drums. This means that labels must be maintained on chemicals in a manner which continues to be legible and the pertinent information (such as the hazards and directions for use) does not get defaced (i.e., fade, get washed off) or removed in any way.

The employer is not responsible for updating labels on shipped containers, even if the shipped containers are labeled under HazCom 1994. The employer must relabel items if the labels are removed or defaced. However, if the employer is aware of newly-identified hazards that are not disclosed on the label, the employer must ensure that the workers are aware of the hazards.

Labels For a Hazardous Chemical Must Contain:

•  Name, Address and Telephone Number of the chemical manufacturer, importer or other responsible party.
• Product Identifier is how the hazardous chemical is identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in section 1 of the SDS.
• Signal Words are used to indicate the relative level of severity of the hazard and alert the reader to a potential hazard on the label. There are only two words used as signal words, “Danger” and “Warning.” Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the label no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning,” then only “Danger” should appear on the label.
• Hazard Statements describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. For example: “Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin.” All of the applicable hazard statements must appear on the label. Hazard statements may be combined where appropriate to reduce redundancies and improve readability. The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards no matter what the chemical is or who produces it.
• Precautionary Statements describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling. There are four types of precautionary statements: prevention (to minimize exposure); response (in case of accidental spillage or exposure emergency response, and first-aid); storage; and disposal. For example, a chemical presenting a specific target organ toxicity (repeated exposure) hazard would include the following on the label: “Do not breathe dust/fume/gas/mist/vapors/spray. Get medical advice/attention if you feel unwell. Dispose of contents/container in accordance with local/regional/ national and international regulations.”
• Pictogram(s) consists of a symbol on a white background framed within a red border and represents a distinct hazard(s).
• Supplementary Information. The label producer may provide additional instructions or information that it deems helpful. It may also list any hazards not otherwise classified under this portion of the label. This section must also identify the percentage of ingredient(s) of unknown acute toxicity when it is present in a concentration of ≥1% (and the classification is not based on testing the mixture as a whole). If an employer decides to include additional information regarding the chemical that is above and beyond what the standard requires, it may list this information under what is considered “supplementary information.” There is also no required format for how a workplace label must look and no particular format an employer has to use; however, it cannot contradict or detract from the required information.

Erick Burres

Clean Water Team Coordinator

California Water Quality Collaboration Network Facilitator

Safe to Swim Network Co-facilitator

Email: erick.burres@waterboards.ca.gov

Phone: 213 712 6862 mobile

Mailing address: Erick Burres – Clean Water Team C/O SARWQCB - 3737 Main Street, Suite 500, Riverside, CA 92501