By Fred Workley
The Occupational Safety and Health Administration (OSHA) Hazard Communications Standard (HCS) (29 CFR 1910.1200) gives you the right to know about hazards on the job. Your workplace should have a written hazard communication program in place so you know what the hazards are and how to protect yourself against their potentially dangerous effects.
Understanding the HCS
The HCS is designed so that employers who use chemicals do not have to take on the additional responsibility of evaulating hazards. Hazards must be identified by the chemical manufacturer and reported to everyone who purchases their products through proper labeling and material safety data sheets (MSDS).
Employers who use chemicals are responsible for establishing a workplace program and keeping their employees informed of any and all hazards.
A written hazard communication program is required in all workplaces where employees are exposed to hazardous chemicals. The written plan must detail how the requirements for labels, MSDS, employee information, and training are going to be met.
As part of this plan a list of all hazardous chemicals must be kept on file, MSDS must be kept on file for all hazardous chemicals, all chemicals must be properly labeled, and employees must be properly informed on how to deal with hazardous chemicals.
Developing the list
As previously mentioned, the HCS requires that a list of all hazardous materials be kept as part of the written program. When developing a program it is important to identify all hazards in the workplace, not just in liquid form, but also any vapors or dust created in the working environment.
The HCS covers both physical and health hazards, so any potentially hazardous materials should be accounted for under the hazard communication program.
Physical hazards have the potential to cause physical or mechanical damage. They usually result in an explosion or fire. It is important to be aware of a hazard's flash point, the temperature at which a liquid forms a combustible mixture with the surrounding air. The autoignition temperature is also important to note. It is the temperature at which a material spontaneously bursts into flame.
There are seven specific categories of health hazards that must be taken into account in evaluating workplace hazards: carcinogens, corrosives, highly toxic materials, irritants, sensitizers, toxic materials, and target organ effects. These are defined in terms of observations and biological tests.
Any hazardous components that exceed 1 percent must be listed on the MSDS. Carcinogens must be listed if they make up more than 0.1 percent of the mixture. Any chemical components that have been found to be hazardous as a result of tests must be listed even if they are present in concentrations below 1 percent. So even with small percentages of hazards, you can be assured that you will know exactly what you are being exposed to.
Hazardous chemicals have hazard warning labels that are either written, printed, or show a graphic on the container. The hazard-warning label can either be a label, tag, or marking. The warning must convey the hazards of the chemicals in the container.
When chemicals are dispensed in small quantities, each small container must be labeled or marked with the chemical contents. If the hazard-warning label becomes dirty, unreadable, or falls off replace it as soon as possible. Don't mix chemicals. If any portion of the resulting mix is hazardous then the whole quantity is now considered hazardous. This is called the derived from rule. Look around your work area and see how you're doing on identifying chemicals that you use.
Material Safety Data Sheets
Along with the warning label to alert you to the hazard, you should have ready access to the Material Safety Data Sheets (MSDS). You should read the MSDS before working with chemicals. It is good to know applicable precautions and procedures. Use the recommended protective equipment and be aware of emergency information.
The MSDS is one place where you can go to find important information on any chemical. There is no standard format for the MSDS, but they all provide similar types of information. The employer is required by the HCS to review all incoming MSDS sheets, to maintain a file, and to make this information available to you along with training on chemicals you use. The MSDS has information to identify hazardous chemicals and the properties of each hazard. In addition, the MSDS identify safety hazards, precautions for safe handling, cleanup procedures for leaks and spills, plus first-aid and emergency procedures.
Understanding the hazards
MSDS list the appearance of the materials to make it easier to identify them. Chemical properties are important because of their ability to react with another substance to form a new substance. Characteristic odors can serve as a warning for leaks and escapes. Within the limits of safety, it is a good idea for you to be familiar with the characteristic odors of the chemicals to which you are exposed.
Physical data like the chemical's evaporation rate is made available because some chemicals could become a hazard due to fumes in the work area. Other data is given such as the boiling point (a low boiling point indicates a volatile chemical), melting point, vapor pressure, and percent volatiles by volume that indicates how much of the mixture can evaporate. Additional data can indicate whether the substance can be concentrated preferentially in a petroleum-like solvent or dissolve in water. This would include the solubility in water and the water/octanol partition coefficient.
Setting the limits
Maximum permissible exposure concentrations are shown on the MSDS. Some chemical exposure limits are set by federal regulations as OSHA permissible exposure limits. The American Conference of Government Industrial Hygienists has set some standards for threshold limits. These limits usually involve both concentration of the chemical and the duration of the exposure. Evidence that a chemical can cause cancer must also be noted in the MSDS. The standard requires a statement if the chemical is listed in the National Toxicology Program Annual Report on Carcinogens, the International Agency for Research on Cancer Monographs, or by OSHA.
The MSDS lists specifications for safe storage and has warnings about the possibility of reaction with other chemicals. Many chemicals, especially those used as industrial reactants, have a lot of energy locked in them. When they react, this energy may be released in the form of heat, or new chemical substances, possibly toxic, may be formed and released. Different materials will react under different conditions, and the information given on the MSDS should indicate conditions to avoid.
Cleanup and control
Cleanup procedures are listed on the MSDS. This information applies to both personal safety and protection with containment. The cleanup guidance is to help you prevent contamination of the environment. There will be a list of materials that will neutralize the spilled chemical. Information on disposal methods is given in detail.
All applicable control measures offered by the manufacturer are listed on the MSDS including temperature, pressure, and concentrations. Required personal protective equipment and proper work practices are also listed.
Emergency and first-aid instructions for treatment including routes of entry, antidotes, and care of the victim are clearly stated.
You should be notified of the chemical hazards in your workplace. And additional training is required if a new hazardous chemical is introduced to your work area.
If you haven't gotten hazard training demand it. It will keep you informed and alert to any dangers in the workplace. A key to this training is understanding the MSDS. It serves as a virtual one-stop shop for understanding chemical hazards.
Stay informed and stay safe. Keep 'em Flying.
Fred Workley is the president of Workley Aircraft and Maintenance Inc. in Benton City, WA, and Indianapolis, IN.