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USA LAW ENFORCEMENT
HAZCOM
Not everything is HAZMAT but
everything is HAZCOMM
2012
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What in the back of your half ton
• Exposure to chemicals poses serious problems
for many workers. Chemical exposure may
cause or contribute to many serious health
effects such as heart ailments, kidney and lung
damage, sterility, cancer, burns, and rashes.
Some chemicals may also be safety hazards
and have the potential to cause fires,
explosions, and other serious accidents
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EVERY OFFICER must KNOW
• Substances Exempt by Standard (Consumer Products)
• Primary and Secondary Container Labels
• NFPA Labeling and Number System
• Review of MSDS contents
• MSDS Terminology
• MSDS Availability
• Exposure Prevention (protective measures)
• Acute and Chronic Health Hazards
• Physical Hazards
• First Aid (eyes, skin, respiratory)
FOR EVERY CHEMICAL THEY CHECK OR COME IN CONTACT
WITH IN THEIR DAILY PATROLS AND COMPLAINTS
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AS A LAW ENFORCEMENT MEMBER
• Recognize what Hazardous Materials are; the problems they pose; the
risks and outcomes Haz Mat events present; and identify the Haz Mat First
Responder's Awareness VS Operational Role (including the limits of both
roles).
• Recognize a Haz Mat event through basic clues, warning signs, placards,
labels, shipping papers and MSDS's; cite the need for a positive safety
attitude; and describe a mental safe approach tactic upon recognition of
the Haz Mat event.
• Describe basic First Responder actions, citing the need for safety,
isolating/denying entry, and making required notification to begin a safe
and effective response to a Haz Mat incident.
• Describe purpose and need to safely initiate command, and explain
purpose, need and benefits of scene management.
• Describe identification and hazard assessment techniques; and
demonstrate use of the North American Emergency Response Guidebook
to initiate basic action planning
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IN LAW ENFORCEMENT WHO CAN
YOU CALL WHO CAN HELP OUT
• Recognition and Safety of Hazardous Materials
• Safety, Isolation and Notification
• Personal Protection Equipment and the
Limitation of the First Responder
• Containment and Protective Actions
• Decontamination, Disposal, and Documentation
• Outside Agency Coordination
• Toxicology
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Health & Safety Regulations under
OSHA
• Hazard specific regulations
– Specific standards for exposures to hazardous materials; ex. workplace
air standards for chemicals
• Workplace Hazard Communication Standards
(HazCom – Hazard Communication Standard)
– Requirement that workers are aware of hazards in their work
environment.
• Laboratory Safety Standard
– Specific HazCom standard for laboratories
• Hazardous Waste Operations & Emergency Response
(HazWoper)
– Applies HazCom to workers working with hazardous waste, ties up
loose ends of HazCom
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Hazard Communication and OSHA
“Employee Right to Know”
29 CFR 1910.1200
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Responsibilities
Manufacturers/Importers and Distributors of hazardous materials:
– determine hazards
– responsible for quality of hazard determination
– communicate hazard information to customer
Employer responsibility
– Identify, List Hazardous Chemicals in Workplace
– Obtain MSDS's & Labels
– Written HAZCOM Program
– Provide Information and training to Employees
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Communicating Hazards
Employees must have the knowledge necessary
to understand all sources of hazard and
emergency information available to them
– Material Safety Data Sheets
– Manufacturer's Product Labels
– Warning Labels
– Shipping Labels and Papers
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Convey Information
Manufacturers / Distributors
– Labels on Containers
– MSDS
Employers
– Identify, List Hazardous
Chemicals in Workplace
– Obtain MSDS's & Labels
– Written HAZCOM Program
– Provide Info. to Employees
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Laboratory vs. Non-laboratory Use
Work operations where coverage of the rule is limited.
– Research Laboratories
– operations where chemicals are only handled in sealed containers (e.g., a
warehouse)
Employers having these types of work operations should
– keep labels on containers as they are received,
– maintain material safety data sheets and provide access
– provide information and training
FOR LABORATORIES
– Occupational exposure to hazardous chemicals in laboratories. – 29 CFR
1910.1450 and the Chemical Hygiene Plan
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Written Hazard Communication
Program 1910.1200(e)
• Employers shall develop, implement, and maintain at each workplace, a written hazard
communication program which at least describes how the criteria specified in paragraphs (f),
(g), and (h) will be met, and which also includes the following:
– A list of the hazardous chemicals known to be present using an identity that is
referenced on the appropriate material safety data sheet
– The methods to inform employees of the hazards of non-routine tasks and the hazards
associated with chemicals contained in unlabeled pipes in their work areas.
• Paragraph f - "Labels and other forms of warning.“
• Paragraph g - "Material safety data sheets.“
• Paragraph h - "Employee information and training."
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Labels Communicate Hazards
• HMIG(S)
– Hazardous Material Identification Guide (System)
• NFPA
– National Fire Protection Agency
• DOT
– Department of Transporation
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NFPA vs. HMIS
• Both systems have three color-coded fields to indicate the
flammability (red), health (blue), and reactivity (yellow) hazards
associated with the material.
• Both use a system of five numbers, ranging from 0 to 4, to indicate
the severity of hazard, with 0 being the least and 4 being the most
hazardous.
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NFPA vs. HMIS
• Differ in the fourth, white field
– special handling in the NFPA system
– protective equipment in the HMIG system).
• HMIS is intended as an HCS compliance tool
– employees who must handle hazardous chemicals in the workplace
are the intended audience
• NFPA was designed for first responders.
– numbers assigned in the NFPA system assume that a fire, spill, or
emergency is present
Excellent Example: NO WATER ! !
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HMIS White Field
Letter indicates the type of personal protection required by the
employee when handing and working with the labeled material
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NFPA White Field
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MSDS
• Identity of the chemical or product
• Hazardous ingredients
• Physical/chemical characteristics
• Fire and explosion hazards
• Reactivity data
• Health hazards
• Precautions for safe handling and use
• Control measures
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Hazard Specific Regulations:
Airborne Contaminants
• PELs – Permissible Exposure Limits, enforced by OSHA, based
on TWAs – time weighted averages (8 hrs/day for 40 hr wk).
Mathematical average of exposure conc.
• TLVs – Threshold Limit Values, same as PELs, but are not
enforced by government, developed by ACGIH. (American
Conference of Governmental Industrial Hygienists)
• RELs - Recommended Exposure Limits, established by NIOSH,
for review by OSHA for revising PELs. (Natl. Institute of
Occupational Safety & Health)
• STEL – Short Tern Exposure Limit, time weighted average
concentration to which worker can be continuously exposed
for a short period (typically 15 minutes).
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Hazard Specific Regulations:
Airborne Contaminants cont.
• C – Ceiling Limit, not a time weighted average, but
instead a maximum concentration that should not be
exceed at any time.
• IDLH – Immediately Dangerous to Life or Health,
defined as a concentration or condition that poses an
immediate threat to life or health.
• Difference between PEL & TLV – with various
designations: OSHA – PEL, PEL-TWA, PEL-C, PEL-
STEL, ACGIH – TLV-TWA, TLV-STEL, & TLV-C.
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Other Hazard Specific Regulations
• Relating to risks associated with energy, noise, heat,
cold, radiation, vibration, repetitive motion, dust,
and oxygen deficient environments
• Example: Ergonomic regulations to alleviate the the
development of Carpal Tunnel Syndrome
• Example: OSHA Standard for oxygen deficient
atmosphere is <19.5% oxygen, ACGIH defines it at
18%
– At what concentration do we see physiological effects of
oxygen deficiency ?
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HazCom: Workplace Hazard
Communication Standards
• All businesses that use hazardous chemicals are
covered by the HazCom standard
• Labeling, MSDS’s, & employee training are the basic
elements of hazard communication programs
• The Laboratory Safety Standard is a hazard
communication program for laboratories only
• HazWoper covers hazardous waste clean-up workers
TSD facilities, and emergency responders to chemical
spills
– 40-hr H&S training offered as part of OCC’s degree
program falls under the HazWoper Standard.
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General Requirements
• Reduce exposure below established exposure
levels
• Air monitoring
• Informational program
• Decontamination procedure
• Emergency response plan to handle possible
on-site emergencies
• Off-site emergency response plan
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First Responder Awareness Level
• First Responders at the Awareness Level are
individuals who are likely to witness or
discover a hazardous substance release and
who have been trained to initiate an
emergency response sequence by notifying
the proper authorities of the release
• They would take no further action beyond
notifying the authorities of the release
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First Responder Operations
Level
• Trained to respond in a
defensive fashion without
actually trying to stop the
release
• Function is to contain the
release from a safe
distance, keep it from
spreading and to prevent
exposures
GHS=WHMIS= HazComm North America
Purpose of OSHA’s
Hazard Communication Standard
OSHA’s Hazard Communication Standard (HCS) is
designed to ensure that information about hazards
chemicals disseminated.
Chemical manufacturers are required to evaluate
the hazards of the chemicals they produce, and to
provide information about them through labels and
material safety data sheets (MSDS’s).
Employers who use hazardous chemicals in their
workplaces must follow this Standard to assure
employee safety.
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Elements of
HAZCOM Standard
A Written HAZCOM Program includes
employee training requirements.
Hazard Container Material Safety
Communication Labeling Data Sheet
Program
Program MSDS
Label
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Container Labeling
All containers of hazardous
chemicals must be marked with:
Identify of the chemical
Appropriate hazard warnings
A picture or symbol ok Zip Cleaner
Name and address of the
XYZ Company
responsible party
PO Box 1
(manufacturer, etc.) Any town, OH
All Labels must be in English and
Flammable,
prominently displayed.
Avoid Prolong
Breathing
Material Safety Data Sheets
Prepared by the chemical manufacturer or
importer and describe:
Physical hazards, such as fire and explosion
Health hazards, such as signs of exposure
Routes of exposure
Precautions for safe handling and use
Emergency and first-aid procedures
Control measures
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Material Safety Data Sheets (cont’d)
Must be in English and include information regarding the specific
chemical identity and common names.
Must provide information about the:
Physical and chemical characteristics
Health effects
Exposure limits
Carcinogenicity (cancer-causing)
Identification (name, address, and telephone number) of the
organization responsible for preparing the sheet
MSDS Sheets are always accessible to employees.
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Definitions
Terms no longer being defined due to changes in
terminology:
Hazard warning; identity; and material safety data sheet
(MSDS)
Terms revised to be consistent with the GHS:
Chemical; chemical name; hazardous chemical; health
hazard; label; mixture; physical hazard; and trade secret
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Definitions
The following terms are being added to the
definitions section:
Classification; hazard category; hazard class; hazard not
otherwise classified; hazard statement; label elements;
pictogram; precautionary statement; product identifier;
pyrophoric gas; safety data sheet (SDS); signal word;
simple asphyxiant; and substance
These terms are primarily related to the changes in approach
to evaluating hazards, and providing label information
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Physical Hazards
Hazard Class Hazard Category
Explosives Unstable Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6
Explosives
Flammable Gases 1 2
Flammable Aerosols 1 2
Oxidizing Gases 1
Gases under Pressure 1
Compressed Gases
Liquefied Gases
Refrigerated Liquefied Gases
Dissolved Gases
Flammable Liquids 1 2 3 4
Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G
Pyrophoric Liquids 1
Pyrophoric Solid 1
Pyrophoric Gases Single
category
Self-heating Chemicals 1 2
Chemicals, which in 1 2 3
contact with water, emit
flammable gases
Oxidizing Liquids 1 2 3
Oxidizing Solids 1 2 3
Organic Peroxides Type A Type B Type C Type D Type E Type F Type G
Corrosive to Metals 1
Combustible Dusts Single
Category
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(f) Labels
Required Elements
Product identifier
Signal words
Hazard statements
Pictograms
Precautionary statements
Name, address, and telephone number of the chemical
manufacturer, importer, or other responsible party
A new Appendix C, Allocation of Label Elements, has been
provided to indicate the label requirements by hazard class
and category
Labels are to be updated within 6 months of getting new and
significant information about the hazards, or ways to protect
those exposed
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Employers Who Use Chemicals in
The Workplace Will Need To:
• Train employees on new labeling system, pictograms,
and SDS format (by 12/1/13).
• Ensure that only new format SDSs are maintained (by 6/1/15).
• Ensure that products are not received without new labels (by
12/1/15).
• Update your labeling system using the new GHS system (by
6/1/16).
• Update your Hazcom program to reflect changes (by 6/1/16).
• Provide any additional training (such as updates to the Hazcom
program-by 6/1/16).
Major changes to the Hazard
Communication Standard
o Hazard classification: Provides specific criteria for classification
of health and physical hazards, as well as classification of
mixtures.
o Labels: Chemical manufacturers and importers will be required
to provide a label that includes a harmonized signal word,
pictogram, and hazard statement for each hazard class and
category. Precautionary statements must also be provided.
o Safety Data Sheets: Will now have a specified 16-section
format.
o Information and training: Employers are required to
train workers by December 1, 2013 on the new labels
elements and safety data sheets format to facilitate
recognition and understanding.
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TLVs, PELs, & other exposure llimits
• TLVs, PELs, and “any other exposer limit
recommended by the chemical manufacturer,
importer or employer are required”
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Carcinogenicity
• If a chemical is listed as carcinogen by IARC or
NTP, it must be noted on the SDS
• If OSHA finds a chemical to be a carcinogen, it
must be noted on the SDS
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GHS Hazard Classification
– Acute Toxicity (any route of exposure)
– Skin Corrosion or Irritation
– Serious Eye Damage or Eye Irritation
– Respiratory or Skin Sensitization
– Germ Cell Mutagenicity
– Carcinogenicity
– Reproductive Toxicity
– Specific Target Organ Toxicity (single or repeated
exposure)
– Aspiration Hazard
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GHS Hazard Classification
• The list of chemicals presenting a ‘Physical’ hazard
was deleted from the current HCS and the proposed
HCS has identified a new listing
• A ‘Physical Hazard’ means a chemical that is
classified as posing one of the following hazardous
effects:
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GHS Hazard Classification
– Explosive
– Flammable (gases, aerosols, liquids, or solids)
– Oxidizer (liquid, solid, or gas)
– Self-Reactive
– Pyrophoric (liquid or solid)
– Self-Heating
– Organic Peroxide
– Corrosive To Metal
– Gas Under Pressure
– Contact With Water Emits Flammable Gas
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GHS Hazard Classification
• The HCS does not address environmental hazards
and OSHA does not have jurisdiction over that. There
are environmental hazard classifications:
– Hazardous to the Aquatic Environment
• Acute Aquatic Toxicity
• Chronic Aquatic Toxicity
– Bioaccumulation Potential
– Rapid Degradability
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Hazardous Chemical
• OSHA classified as Hazardous Chemicals:
– Pyrophoric gases, signal word “danger”, “catches
fire spontaneously if exposed to air”*
– Simple asphyxiants, signal word “warning”, “may
displace oxygen and cause rapid suffocation”*
– Combustible dust, signal word “warning”, “May
form combustible dust concentrations in the air”*
*Hazard Statements
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The New Safety Data Sheets
o Formerly known as “MSDS”
o Uniform format by June 1, 2015 with 11
required sections:
Section 1, Identification Section 7, Handling and storage
Section 2, Hazard(s) Section 8, Exposure
Section 3, Composition/information controls/personal protection
on ingredients Section 9, Physical and chemical
Section 4, First-aid measures properties.
Section 5, Fire-fighting measures Section 10, Stability and reactivity
Section 6, Accidental release Section 11, Toxicological
measures information
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The New Safety Data Sheets (cont.)
o Other sections on the new SDS:
• Section 12, Ecological information*
• Section 13, Disposal considerations*
• Section 14, Transport information*
• Section 15, Regulatory information*
• Section 16, Other information, includes the date of
preparation or last revision.
o Only 1 set of data sheets is required. May be a time where
MSDSs/SDSs under both standards will be present in the
workplace. This situation is acceptable to OSHA, and employers
will not be required to maintain two sets of MSDSs/SDSs.
*Since other agencies regulate this information, OSHA will not enforce
Sections 12 through 15; however, the SDS must include at least the
heading names for those sections.
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Hazard Communication Standard
Label
• Labels will be required to have
pictograms (to convey hazards about
the chemical), a signal word, hazard
and precautionary statements, the
product identifier, and supplier
identification.
• NFPA and HMIS labels are permitted;
however, the information provided
must be consistent with the new HCS.
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Update Labels to GHS
Current OSHA Template
Identity of hazardous chemical
Hazard warnings
Contact information for
manufacturer/importer/
responsible party.
GHS Template
Product Identifier
Pictograms
Signal word
Precautionary Statements
Hazardous Statements
Supplemental Information
Supplier Identification
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GHS Labels
• Three standardized GHS label elements:
– Symbols (Hazard Pictograms) that convey health, physical,
and environmental hazard information assigned to a GHS
hazard class and category
– Signal Words “Danger” or “Warning” used to emphasize
hazards and relative level of severity of the hazard and
assigned to a GHS hazard class and category
– Hazard Statements which are standard phrases assigned to
a hazard class and category that describe the nature of the
hazard
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GHS Labels
• Key Elements
– Product Identifier
– Supplier Identifier
– Chemical Identity
– Hazard Pictograms*
– Signal Words*
– Hazard Statements*
– Precautionary Information
* Standardized
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GHS Labels
Red
border
GHS
------
Black
border
Transport
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GHS Labels
Hazard Classes may have ‘Categories’
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GHS Labels
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GHS Labels
Example of a Transportation and GHS label combined
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(f) Labels Example
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(f) Labels Sample HS85 Label
HS85
Warning
Batch number: 85L6543
Harmful if swallowed. Wash hands and face thoroughly after handling. Do
not eat, drink or smoke when using this product. Dispose of
contents/container in accordance with local, state and federal
regulations.
First aid: If swallowed: Call a doctor if you feel unwell. Rinse mouth.
GHS Example Company, 123 Global Circle, Anyville, NY 130XX
Emergency Telephone (888) 888-8888
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(f) Labels
Employers are responsible for maintaining the labels on the
containers, including, but not limited to, tanks, totes, drums,
and for training their employees on the hazards listed on the
labels in the workplace.
Labels must continue to be:
legible
contain the pertinent information (such as the hazards and
directions for use)
not able to be defaced, (i.e., fade, get washed off,) or
removed in any way as stated in revised Hazard
Communication Standard, 29 CFR 1910.1200(f)(9)
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Safety Data Sheets (SDS)
The GHS uses a specified order of information, as well as title
descriptions, on the 16-section safety data sheet.
Health, physical and environmental hazard criteria for
substances and for classification of mixtures.
Consistent with voluntary industry consensus standards, such
as ANSI.
Should improve comprehensibility and issues regarding
accuracy of information.
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Safety Data Sheet Format
1. Identification of the
substance or mixture and of the 9. Physical and chemical
supplier properties
2. Hazards identification 10. Stability and reactivity
3. Composition/information on 11. Toxicological information
ingredients 12. Ecological information
4. First-aid measures (non-mandatory)
5. Fire-fighting measures 13. Disposal considerations
6. Accidental release measures (non-mandatory)
7. Handling and storage 14. Transport information
(non-mandatory)
8. Exposure controls/personal
protection 15. Regulatory information
(non-mandatory)
16. Other information, including
date of preparation or last
revision
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Safety Data Sheets (SDS)
SDS in the workplace for each hazardous chemical
which is used
OSHA requires these forms for each hazardous
chemicals
Readily accessible during each work shift to
employees when they are in their work area(s)
Safety Data Sheets (SDS)
Identifies chemicals by name
Tells potential harm and how chemicals will
enter the body (Inhalation, ingestion, and/or
skin absorption)
Explains signs and symptoms of exposures
Explains emergency procedures
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Temporary Employees
The temporary agency employer
would provide generic hazard
training and information
concerning categories of
chemicals employees may
potentially encounter
Host employers would then be
responsible for providing site-
specific hazard training pursuant
to sections 1910.1200(h)(1)
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Appendices
Appendix A, Health Hazard Criteria (Mandatory) (NEW)
Appendix B, Physical Hazard Criteria (Mandatory) (NEW)
Appendix C, Allocation of Label Elements (Mandatory) (NEW)
Appendix D, Safety Data Sheets (Mandatory) (NEW)
Appendix E, Definition of “Trade Secret” (Mandatory)
Appendix F, Guidance for Hazard Classifications re:
Carcinogenicity (Non-Mandatory) (NEW)
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FLAMMABLE LIQUIDS
(Classified in Accordance with Appendix B.6)
Pictogram
Flame
Hazard Signal Hazard statement
category word
1 Danger Extremely flammable
liquid and vapor
2 Danger Highly flammable
liquid and vapor
3 Warning Flammable liquid and
vapor
Pictogram
No Pictogram
Hazard Signal Hazard statement
category word
4 Combustible liquid
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Revision of 29 CFR 1910.106 Flammable Liquids
Flammable liquids are divided into four categories as
follows:
(i) Category 1 . . . FPs below 73.4 o F (23 o C)
and having a BP at or below 95 o F (35 o C).
(ii) Category 2 . . . FPs below 73.4 o F (23 o C) and
BP above 95 o F (35 o C).
(iii) Category 3 . . . FPs at or above 73.4 o F (23
o C) and at or below 140 o F (60 o C).
(iv) Category 4 . . . FPs above 140 o F (60 o C)
and at or below 199.4 o F (93 o C).
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Revision of 29 CFR 1910.106 Flammable
Liquids
GHS Flammable and Combustible Liquids Standard
(29 CFR 1910.106)
Category Flashpoint ºC (°F) Boiling Class Flashpoint ºC (°F) Boiling Point
Point ºC (°F)
ºC (°F)
Flammable 1 < 23 (73.4) ≤ 35 (95) Flammable Class IA < 22.8 (73) < 37.8 (100)
Flammable 2 < 23 (73.4) > 35 (95) Flammable Class IB < 22.8 (73) ≥ 37.8 (100)
Flammable 3 ≥ 23 (73.4) and ≤ Flammable Class IC ≥ 22.8 (73) and < 37.8
60 (140) Combustible Class II (100)
≥ 37.8 (100) and < 60
(140)
Flammable 4 > 60 (140) and ≤93 Combustible Class IIIA ≥ 60 (140) and <93.3
(199.4) (200)
None Combustible Class IIIB ≥ 93.3 (200)
** Not covered by §1910.1200 or §1910.106 however interpretation letter indicates these are covered by §1910.107
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Resources
• OSHA published ‘A
Guide to The Globally
Harmonized System of
Classification and
Labeling of Chemicals
(GHS)
• It can be downloaded
from the OSHA website
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Quiz
1) The Pictogram in the upper right is for _____.
2) Training in the hazards of the chemical is initially and when
__________________.
3) _______ use containers would not require a label.
4) Name at least two things an employee would have to be
trained on for flammable paint: ________________
___________________
5) SDS’s must be accessible to employees during their
_____________________________.
6) Name two chemicals that would be in the list of hazardous
chemicals? ___________ ______________
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MSDS – Material Safety Data Sheets
• Informational sheet supplied by manufacturer for
any hazardous material
• No standardized format exists, but MSDS must
provide information on 18 points
– Including, specific chemical identification, CAS#, potential
for fire/explosion, physical properties of substance, acute
& chronic health risks, PEL, etc.
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MSDS – Material Safety Data Sheets
Cont.
• Generally broken into 9 sections
– Section I – Name & manufacturer identification
– Section II – Information on ingredients, exposure limits,
CAS#, if any components are considered carcinogens, and
common names & synonyms
– Section III – Physical data on material including its
appearance and color
– Section IV – Fire & explosion hazards, including flashpoint,
LEL & UELs, and fire fighting procedures
– Section V – General information on health hazards
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MSDS – Material Safety Data Sheets
Cont.
• Remaining 4 sections
– Section VI – Stability & reactivity data
– Section VII – Provides information on precautions for safe
handling and use (commonly called spill & leak
procedures)
– Section VIII – Recommendations for types of personal
protective equipment appropriate with this material
– Section IX – Special precautions section, catch-all for any
important precautions
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Informational Terms Included on
MSDS’s
• Flashpoint – the lowest temperature at which vapors above a
flammable, volatile material ignite when exposed to an ignition
source (e.g. flame)
• Vapor pressure – a measurement of a liquids ability to volatilize
• Vapor density – relative measure of density of a gas compared with
standard air
• LEL – Lower Explosive Limit, minimum concentration of a
flammable gas require for ignition
• UEL – Upper Explosive Limit, maximum concentration of a
flammable gas require for ignition
• Fire Triangle: Fuel – Heat – Oxygen
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