We use thousands of chemicals throughout our lifetime — some are benign and some can be extremely harmful. The best way for employers to ensure that their workers stay safe around hazardous chemicals is to establish and maintain a robust Hazard Communication (HAZCOM) program.
What is HAZCOM?
Hazard Communication provides information to employees who may be exposed to hazardous chemicals in their work environment. This information ensures that employees are aware of the chemicals they work with and what they need to do to protect themselves. Protection from hazardous chemicals could involve anything from protective gloves and aprons to respiratory protection and chemical suits.
What constitutes a hazardous chemical?
Chemicals are considered hazardous if they present any physical or health dangers. Chemicals that present physical hazards, including combustible liquids and compressed gases, could be flammable, water reactive or ignite spontaneously.
A health hazard could be a chemical that causes damage to the body’s tissues, organs or internal systems. Examples include chemicals that cause burns on the skin, blindness, damage to the reproductive system, allergic reactions or cancer.
The primary purpose of HAZCOM regulations is to provide information to employees who are exposed to chemicals in the workplace. OSHA maintains different standards based on the type of work being accomplished. When doing construction activities, such as the construction of wells, 29CFR1915.59, Hazard Communication in Construction, would apply. For general maintenance activities, such as work around the shop, OSHA’s General Industry standard would apply, which is designated as 29CFR1910.1200. A complete HAZCOM program under one standard would also likely comply with the other standard.
A written program is essential
The Hazard Communication Standard requires an employer to prepare a written hazard communication program. The primary elements of a written program should:
- Describe the method in which the employer will receive chemicals into the work place
- Train employees on the safe handling of chemicals
- Provide hazard information (MSDS)
- Clearly identify chemicals through labeling
- Clarify how employers will identify hazardous chemicals if they’re stored in anything other than the original container
- Indicate how information about hazardous chemicals will be shared with contractors
- Detail what kind of personal protective equipment (PPE) is needed
Material safety data sheets
A Material Safety Data Sheet (MSDS) details information that is important for educating individuals who might be exposed to hazardous chemicals and is vitally important in case there is an accident involving chemicals. These MSDSs are required with every chemical and are developed by the chemical manufacturer or importer of the product. MSDS are required to accompany each chemical that is purchased. If you do not receive a MSDS with purchased chemicals, you can request one from the supplier.
To ensure that your MSDSs are not substandard, I encourage you to obtain MSDSs from your supplier, the manufacturer or the importer either by a phone request or via the Internet. It will be the most accurate information to have in your shop and out in the field. MSDS that are outdated will not be considered as compliant with OSHA standards. The MSDS provides basic information, such as:
- Contact information for the manufacturer or importer
- Common chemical name
- Physical and chemical properties
- Physical and health hazards
- How the chemical might enter the body
- Exposure limits that are regulated by OSHA or identified by other organizations such as the American Conference of Governmental Industrial Hygienists (ACGIH) or the National Institute of Occupation Safety and Health (NIOSH)
- What type of PPE may be required
- Emergency response information in the event of an accident or a fire. This section of a MSDS should be quickly accessible and made available to first responders immediately upon their arrival at an accident scene.
People sometimes get confused by MSDSs because there is so much information and it can be hard to understand it all. There’s information for the employer, the employee, the industrial hygienists and first responders. If there is a section of a MSDS that they understand and that means something to them, then that section was meant for them and they should take the information seriously.
Another important part of any HAZCOM program is the labeling of primary and secondary containers. Training, written programs and good intentions are of no use if you can’t tell what’s in the bottle.
One recent case in Oregon involved a construction worker using a discarded water bottle to hold methanol. Methanol, if perfectly clear, looks just like water. His coworker and friend picked up the bottle at the end of the day and placed it in the cup holder of his truck, thinking it was one of his water bottles. The next morning on the way to work the coworker drank some of the methanol, thinking it was water. Within minutes he had lost his vision, pulled off the road and called someone for help. He ended up in the hospital for three days and, fortunately for his two little girls, he made a full recovery.
It is vital that employers ensure that containers holding any type of chemicals are clearly marked. Regulations require the product name, identifiable back to the appropriate MSDS, contact information for the manufacturer and a hazard warning such as DANGER or WARNING. Some companies affix the label information with wire and a tag; others use a color-coding approach. The type of labeling is irrelevant as long as employees know and understand the system.
Training is the most critical element of any health and safety program. The same holds true for hazard communication. All the hazard information in the world means nothing if employees are not trained to understand and act upon that knowledge.
Employees must be trained in:
- The hazards of chemicals they work with
- The meaning of the warning labels
- How to properly use and understand the use of PPE
- What to do in case of an emergency and how to obtain a MSDS quickly
The last bullet is the most important reason for Hazard Communication and the MSDS. Not all chemicals affect everyone in the same way. Individual sensitivities vary, but the information on a MSDS provides protection for the vast majority of the population. Providing a MSDS to emergency medical technicians at the scene of an accident greatly improves the victim’s chance for a full recovery and provides important information so they can protect themselves.
This is where training comes in. The better trained employees are about the usefulness and location of MSDSs, the less time will be needed to take action and provide valuable information to health providers, and the better off the victim will be. An educated coworker might be a victim’s best friend in the event of an accident.
For more information about occupational health and safety topics or to access a list of industrial hygiene consultants who specialize in safety issues, visit the American Industrial Hygiene Association.
Stanton E. Thomas is a Health Enforcement Manager/Industrial Hygienist for the Oregon Occupational Safety and Health Division (OR-OSHA) and is a member of the AIHA Meth Lab Working Group.