It's time to review your safety programs

March 1, 1999

It's Time to Review Your Safety Programs

By Fred Workley

March 1999

Fred Workley is the president of Workley Aircraft and Maintenance Inc. in Manassas, VA. He is on the technical committees of PAMA and NATA and participates in several Aviation Rulemaking Advisory Committees. He frequently speaks to groups on issues of current interest to the aviation community. He holds an A&P certificate with an inspection authorization, general radio telephone license, a technician plus license, ATP, FE, CFI-I, and advance and instrument ground instructor licenses.

Try this in your facility. Find the Material Safety Data Sheets (MSDS) and determine if they have a quarter inch of dust on the top of them. I go into many organizations located all over the country. They all say that they have a safety program that meets all the regulations. I ask questions like, "Who in the organization conveys to new employees the basic understanding of how to read chemical labels, how is the Hazard Communication Standard being met,and are the MSDS sheets reflective of the currently used chemicals? When was the last time you had a good housecleaning of your "hazardous material" storage area?

I hope that you are not surprised!

The answers tell me that we need a review of some of the basics.

Its every employer's responsibility to teach employees about the Hazard Communication Standard. The Hazard Communication Standard is a uniform standard to explain workplace hazards — it clearly spells out what specific information has to be communicated and how it must be communicated. It is an OSHA (Occupational Health and Safety Administration) requirement to cover the handling of workplace chemicals, addressing both health and safety issues, and it is a "Right to Know" requirement for potential chemical hazards. This is a Federal standard; however, and there may also be state and local "Right to Know" laws that you must meet.

We are often exposed to chemicals in the workplace. Improper handling of some of these chemicals are dangerous and can, if they enter the body, can result in nausea or organ damage. Chemicals generally enter the body through the skin, nose, mouth or eyes, and can result in illness, injury or incapacitation. The effects may be also be external—like burns or rashes.

Have you reviewed your written program lately? The Hazard Communication Standard requires employers to develop, implement, and continuously maintain a documented program for the instruction of employees. The written program has to list all the hazardous chemicals used in each specific work area and how to handle them.

The program has to include information on how to read and understand MSDS and chemical labels. Also, it must cover chemicals moved in pipes. The written methods program must include how to observe and detect a release or presence of hazardous chemicals in the workplace.

The last element of the written program is to provide for training of new employees and a means to inform non-employees, either visitors or vendors, about the specific hazardous chemicals present in each work area.

When any chemical is made or distributed, its potential hazards must be determined. Manufacturers, importers, and distributors are required by law to assess the extent of this potential hazard and make this information available on a Material Safety Data Sheet (MSDS). For each chemical used in the workplace, it is the employer's task to make readily available the MSDS sheets and to tell everyone where the MSDS sheets are in the facility.

Anyone using a chemical has to also take responsibility for knowing how to read labels, understanding MSDS sheets and precautions in handling chemicals, and knowing what to do in the event of a chemical spill or if chemicals splash on someone. The MSDS tell how the chemical would enter the body and gives emergency first aid procedures to cover symptoms as faintness, dizziness, headache, and irregular heart beat.

There is no specific format for the MSDS, but it serves as the vehicle to inform everyone of safety procedures, emergency response options, as well as chemical components and dangers. The MSDS will generally have the chemicals; its trade name and often the formula. The chemical identification of ingredients with exposure limits are listed as either ACGIH-TLV (American Conference of Government Industrial Hygienists & Threshold Limit Value) or OSHA-PEL (Occupational Safety and Health Administration & Permissible Exposure Limit). Addresses and emergency numbers are provided.

Physical data includes: percentage of volatile components, odor, appearance, boiling point, specific gravity, vapor pressure and density, evaporation rate, and solubility in water. Also included is information regarding the stability of the chemical, how it reacts, and the extent of reaction with other chemicals and compounds, along with instructions to prevent an unexpected and unwanted chemical reaction.

MSDS also include information on fire prevention and fighting. Explosion and fire data includes: fire extinguishers to use and their media, the temperature at which the chemical ignites (flash point), any unusual fire hazards or unique dangers, special fire fighting procedures, and chemical flammability limits by volume. Any spill or leak procedure will be identified. All equipment needed in clean up and any special precautions — including methods for disposal, will be clearly defined. Also, any special precautions for handling will be listed. Safe handling of hazardous chemicals may require protective clothing, gloves, respirators, eye protection, and ventilation information.

The Hazard Communications Standard also requires that all containers that are used in a work area be labeled with special precautions identified with either words or descriptive symbols. Some chemicals require special storage precautions like refrigeration and explosion proof cabinets.

The one exception is a portable container for use immediately by the person transferring the chemical. Everyone must have training in reading the labels and understand what those labels mean. The label should identify the chemical, hazard severity, health hazards, and any required protective clothing or equipment.

The most common labels are the color bar type label and the NFPA type panel label (National Fire Protection Agency). Understanding the meaning of labels can avoid serious accidents. Always follow the directions and precautions to ensure safe handling of all chemicals. Investigate all chemicals that lack labels and don't mix chemicals that you have not positively identified. The end result may be a big "surprise."

Everyone has the "Right to Know" regarding hazardous materials in the workplace. Following instructions and warnings exhibited in the Hazard Communication Standard and on Material Safety Data Sheets will avoid surprises that could prove harmful to equipment and personnel.