OSHA’s Hazard Communication Standard (29 CFR 1910.1200) provides workers exposed to hazardous chemicals with a “right-to-know” the identities and hazards of those materials. Additionally, employees must also be told the appropriate protective measures associated with the hazardous chemicals. When workers have this important information, they are able to take steps to protect themselves from the negative effects caused by accidental exposure.
OSHA's Hazard Communication Standard (HCS) requires employers and manufacturers to develop and distribute chemical information as stated below:
This means that even though an employer was not responsible for the manufacturing of the hazardous chemical, the employer has the responsibility for transmitting information about the hazardous chemical to his or her employees.
In 2012, OSHA released an update to the Hazard Communication Standard. The new HCS 2012 is now aligned with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) that provides many benefits, including the following:
The previous HCS 1994 gave workers the right-to-know, but the new HCS 2012 gives workers the right-to-understand. This is an important distinction between the two versions.
In order to ensure chemical safety in the workplace, employers need to provide employees with the information associated with the chemicals they are exposed to (HCS 1994). This information should include any relevant chemical properties, hazards associated with the chemicals, and means to protect oneself from an accidental exposure. Employers also need to check for understanding of this information (HCS 2012). For example, if a chemical is a strong acid, it is not enough for an employee to know the chemical is an acid. The employee needs to understand the hazards of a strong acid and how to protect themselves from the associated hazards.
The HCS 2012 applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.
Let’s take a closer look at some of the components of this statement.
"Foreseeable emergency" means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.
The phrase "known to be present" is important. If a hazardous chemical is known to be present by the chemical manufacturer or the employer, it is covered by the standard.
"Hazardous chemical" means any chemical which is classified as a physical hazard or a health hazard, such as a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
“Employees,” such as office workers or bank tellers who encounter hazardous chemicals only in non-routine and isolated instances are not covered. For example, an office worker who occasionally changes the toner in a copying machine would not be covered by the standard. However, an employee who operates a copying machine as part of her/his work duties would be covered by the provisions of the HCS.
In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use (such as are found in marine cargo handling, warehousing, or retail sales), employers must:
Chemicals that are health hazards can damage an exposed person’s tissue, vital organs, or internal systems. Generally, the higher the chemical’s toxicity, the lower the amount or dose necessary for it to have harmful effects. The effects vary from person to person, ranging from temporary discomfort to permanent damage. The extent of damage depends upon dose, toxicity, and duration of exposure to the chemical. Health effects range from short-duration symptoms that often appear immediately (acute effects) to persistent symptoms that usually appear after longer exposures (chronic effects). Health effects can be classified by how they affect tissue, vital organs, or internal systems.
Here are a few hazards:
A paint maker (victim) was working by himself using a paint stripper to remove dried paint from the inside of a tank. The stripper contained methylene chloride, methanol, and mineral spirits. The tank was a permit-required confined space. The space was not adequately ventilated and the victim was not trained in confined space entry. There was no attendant at the tank opening to monitor the work process while the victim was in the tank. The victim was wearing a cartridge respirator that did not adequately protect against inhaling methylene chloride vapors.
The victim was observed unresponsive at the bottom of the tank by a co-worker. The co-worker tried to rescue the victim and was overcome by vapors. The high concentration of methylene chloride in the product, the tank configuration, the inadequate ventilation, and the inadequate training and implementation of confined space procedures were contributing factors in this incident. The victim died from exposure to dichloromethane (methylene chloride).
The investigator determined in order to prevent exposure to methylene chloride while cleaning paint tanks, employers should ensure:
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