Now that you have reviewed scope of the Hazard Communication Rule and employer responsibilities, it's time to get down to business. The first task is to determine what chemicals you have in your workplace. It's important for the person conducting the initial assessment to be familiar with the definition and characteristics of "hazardous chemicals," so let's take a look.
OSHA has defined the term "substance" as chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition.
For the purposes of the HCS, a hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
Physical hazards - a chemical that is classified as (Click link)
The criteria for determining whether a chemical is classified as a physical hazard are detailed in Appendix B to 1910.1200 -- Physical Hazard Criteria.
Health hazard - means a chemical which is classified as (Click link)
The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to 1910.1200 -- Health Hazard Criteria.
You might think that the chemicals which apply to the rule are those in liquid, gas or particulate form. But, the standard's definition of "chemical" is much broader than that commonly used. According to the HCS, chemicals that apply may exist in one of many forms:
Dusts - are finely divided particles. Example - wood dust.
Fumes - are even smaller particles usually formed when solid metal is heated and vaporized, and then condenses as tiny particles.
Fibers - are similar to dusts but are of an elongated shape. Examples - asbestos and fiberglass.
Mists - are liquid droplets that have been sprayed into the atmosphere.
Vapors - are gases formed when liquid evaporates.
Gases - are substances that are normally airborne at room temperature. A vapor is the gaseous phase of a substance which is a normally a liquid or solid at room temperature.
Solids - such as metal, treated wood, plastic.
Liquids - the most common form in the workplace.
The effects chemicals have on the various organs of the human body depend on several important factors:
Check out this short audio clip by Dan Clark of the theSafetyBrief.com. Ammonia hazards are more common than you think. Many companies use this dangerous substance for refrigeration, and workers need to know the risks. In this podcast, Dan describes anhydrous ammonia, and how it’s used in breweries, cold storage warehouses, processing milk, cheese and meat.
Another important task when assessing the workplace for chemical hazards is to determine the route(s) of entry the chemicals may take. If we know the route(s) of entry, we can then determine appropriate engineering, administrative, and PPE controls to eliminate or reduce the exposure. The four common routes of entry are:
We'll be talking more about the physical characteristics, routes of entry, and toxicity of hazardous chemicals later in the SDS module.
There's a simple two step process for assessing and analyzing the workplace for chemical hazards:
Assess the workplace to see which hazardous chemicals are currently being used. Do this by conducting a walkaround inspection and checking records. Use the results of your assessment to create a list of hazardous chemicals. With chemical list in hand, obtain a SDS for each chemical in preparation for the next step.
With each SDS, analyze the hazards presented by each chemical in the workplace. The SDS is your primary tool to determine the physical and health hazards, routes of entry, toxicity, and other information about each chemical in your workplace.
Once you identify and know the nature of the hazards of each chemical, it becomes important to control those hazards by eliminating or reducing those hazards using a systematic approach.
Hazardous substances can be used safely in workplaces if adequate control strategies are used to prevent exposure to those chemicals. A control strategy includes any device, procedure, piece of equipment, system, etc., that is used to keep hazardous chemicals from contacting workers at harmful levels. To eliminate or reduce exposure to hazardous chemicals, an effective protocol called the "Hierarchy of Controls" has been developed. When you determine during a workplace assessment that exposure to harmful levels of hazardous chemicals is present, try to eliminate or reduce that exposure using the following strategies in the following order:
The first three strategies focus on doing something with the hazard.
Elimination: The best solution is to totally eliminate hazardous substances in the workplace.
Substitution: Substitution is the next-best solution. Replace a toxic substance with a less-toxic substance. If you can't get rid of the toxic substances, you may be able to replace them with substances that are at least less toxic.
Engineering Controls: Redesign or modify processes that use toxic chemicals to eliminate or reduce exposure to the chemical hazard itself.
The last two strategies focus on doing something with behaviors to reduce exposure to the hazard.
Administrative Controls: Change work procedures to reduce the duration, frequency, and severity of exposure to the chemical hazard. The chemical hazard, itself, is not eliminated or reduced using this strategy. The primary focus is to incorporate safer work practices through written safety policies, rules, supervision and training. And that's a problem because you may have to regularly supervise employees as they perform a task. These controls work only so long as employees "behave" properly.
Personal Protective Equipment (PPE): The use of PPE is probably the most common strategy, and mandatory when working with hazardous chemicals. PPE forms a barrier between worker and hazard. Once again, the chemical hazard is neither eliminated nor reduced, and a high reliance is placed on appropriate use of PPE for this strategy to be successful.
Remember, the first question you want to ask is, "How can I eliminate, reduce, or engineer out the hazard?" Hopefully you'll be able to eliminate the hazard or reduce it to the point where safe behaviors or PPE won't be necessary.