Hazard Communication

Hazard Communication Standard

In 1983, the Federal Government, through the Occupational Safety and Health Administration (OSHA), established the Hazard Communication Standard (HCS) codified in OSHA 29 CFR 1910.1200 “to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees.”

Wright State University developed and maintains a Hazard Communication Program to give all employees the right to know about any type of hazard they may encounter while performing their duties. The program complies with all requirements of OSHA's Standard for Hazard Communication.

All employees must complete Hazard Communication Training.

Compliance with this program at Wright State University is mandatory.

Five Elements for Compliance

The following five key elements are outlined in the standard and are included in the Wright State University Hazard Communication Program:

  1. Materials Inventory and Hazard Identification – A list of the hazardous materials present in your work area.
  2. Safety Data Sheets (SDSs) – A detailed description of each hazardous material listed in the Materials Inventory.
  3. Labeling – Containers of hazardous materials must have labels to identify the material and warn of its potential hazard to employees.
  4. Training – All employees must be trained to identify and work safely with hazardous materials.
  5. Written Program – A written program must be available to all employees

Labels

Labels and other forms of warning

Under the original Hazard Communication Standard (HCS/HazCom 1994), the label required 3 pieces of information from manufacturers:

  1. Identity of chemical
  2. Appropriate hazard warning
  3. Name and address of manufacturer.

Under the revised Hazard Communication Standard (HCS2012), once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category.  

HCS 2012 Label Requirements

  1. Product Identifier
  2. Signal Word
  3. Pictogram(s)
  4. Hazard Statements
  5. Precautionary Statements
  6. Supplemental Information

ghs_labelexample.gif

 

Label Requirements for Containers

Containers

Workplace containers must show either:

  1. Product identifier and
  2. Words, pictures, symbols, or combination thererof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the HCS2012, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

The product identifier on the label can be any name that links the label, the SDS, and the inventory list of chemicals.

Stationary Process Containers

Stationary process containers may be labeled with

  • signs,
  • placards,
  • process sheets,
  • batch tickets, operating procedures, or
  • other such written materials

This labeling may be used in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of the Hazard Communication Standard to be on a label.

The supervisor shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift.

Additional Label Requirements

Existing labels on incoming containers of hazardous chemicals must not be removed or defaced -- unless the container is immediately marked with the required information.

Workplace labels or other forms of warning must be

  • legible,
  • in English, and
  • other languages may be used on the label, as long as the information is presented in English as well.

Labels must be revised with any new, significant information regarding the hazards of a chemical within six months of becoming aware of the new information.

Examples of workplace labels:  container, transferred container, stationary container.

Safety Data Sheets

Safety Data Sheets

The Hazard Communication Standard (HCS2012) requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products.

The SDS is a detailed document that communicates hazard information to

  • employers, 
  • employees, 
  • physicians, 
  • other health professionals, and 
  • emergency personnel.

Wright State must ensure that SDSs are readily accessible to employees.

SDSs require a 16‑section format that is essentially the same as the ANSI standard for Hazardous Workplace Chemicals-Hazard Evaluation and Safety Data Sheets and Precautionary Labeling Preparation (ANSI Z400.1 & Z129.1 - 2010), already familiar to U.S. employers. 

Currently, a uniform format is not mandatory. As of June 1, 2015, the HCS2012 will require new SDSs to be in the 16-section uniform format, and include the section numbers, the headings, and associated information under the headings below:

1

Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.  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).

2

Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.  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).

3

Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.   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, or
  • 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.

4

Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.  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.

5

Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.  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.

6

Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.  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)

7

Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.  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)

8

Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).  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).

9

Section 9, Physical and chemical properties lists the chemical's characteristics.  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;
  • Flash point;
  • Evaporation rate;
  • Flammability (solid, gas);
  • Upper/lower flammability or explosive limits;
  • Vapor pressure;
  • Vapor density;
  • Relative density;
  • Solubility(ies);
  • Partition coefficient: n-octanol/water;
  • Auto-ignition temperature;
  • Decomposition temperature; and
  • 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

10

Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.  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.)

11

Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.  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

12

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).

13

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
14

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)1.
  • UN proper shipping name1.
  • Transport hazard class(es)1.
  • Packing group number, if applicable, based on the degree of hazard2.
  • 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).

15

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)
16

Section 16, Other information, includes the date of preparation or last revision.  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.

Pictograms

Pictograms

As of June 1, 2015, the Hazard Communication Standard (HCS) will require pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification.

Training

When is training required?

Employees require effective information and training on hazardous chemicals in their work area

  • at the time of their initial assignment, and 
  • whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. 

Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals.  Chemical-specific information must always be available through labels and SDSs.

What is included in the training?

The training includes information on the following:

  • Requirements of the HCS2012
  • Operations where hazardous chemicals exist
  • Location and availability of the Written Program (Hazard Communication Policy)

Required elements of training:

  • Methods and observations to detect the presence or release of hazardous chemicals (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.)
  • Chemical hazards in the workplace including
    • Physical,
    • Health,
    • Simple ashpyxiation,
    • Combustible dust, and
    • Hazards of chemicals in the work area
  • How employees can protect themselves
  • Details of the hazard communication program

All information and training specific to individual work areas will be given to each group at the site-specific level by the employee’s supervisor and/or the Department of Environmental Health and Safety.