An Industrial Hygiene Perspective on Hazard Communication

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					An Industrial Hygiene
Perspective on Hazard
   Communication
 Christopher L. Holzner, MSPH, CIH, CSP


               Society of Chemical Hazard Communication Meeting
                              September 19, 2007
Rohm and Haas Company

•   A global pioneer in the creation and development
    of innovative technologies and solutions for the
    specialty materials industry
•   Innovative technologies and solutions help to
    improve life everyday, around the world
•   Extensive technical knowledge and industry
    expertise
•   Inventive, responsive, customer-focused
•   Nearly a century of innovation and service
Rohm and Haas Today
We Serve a Broad Set of End Markets




         Building & Construction 29%                                      Water 7%




                                            Packaging & Paper 15%




      Electronic & Electronic Devices 17%                           Food & Food Related 2%




                                              Transportation 9%




               Household Goods &                                     Industrial & Other 14%
                Personal Care 7%
Rohm and Haas Today
We are a Global Company
                                                                     2006: Sales $8.23 B
   NORTH AMERICAN REGION                       EUROPEAN REGION




                                                $2,030 MM | 25%
              $4,199 MM | 51%
                                                 EMERGING   | $184
                 SALT |   $829



                                                                            $1,659 MM | 20%
                                                                            EMERGING   | $1,202


                          $342 MM | 4%
                           EMERGING   | $342




                                                                        ASIA PACIFIC REGION
   LATIN AMERICAN REGION
  Definition of Industrial Hygiene

  Industrial Hygiene: Science and art devoted to
  the anticipation, recognition, evaluation,
  prevention, and control of those environmental
  factors or stresses arising in or from the workplace
  which may cause sickness, impaired health and
  well being, or significant discomfort among
  workers or among citizens of the community.*

* American Industrial Hygiene Association
OSHA Form 20
Google search:
  >12,200,000 hits for MSDS
  >3,180,000 hits for Material Safety Data Sheet
Respiratory Protection
• “Avoid breathing dust”

 Respiratory protection:
 • A respiratory protection program meeting OSHA 1910.134 and
   ANSI Z88.2 requirements or equivalent must be followed
   whenever workplace conditions warrant a respirator's use.
 •   None required if airborne concentrations are maintained below the
     exposure limit listed in Exposure Limit Information.
 •   When dusty conditions are encountered, wear a properly-fitted
     NIOSH-approved (or equivalent) half-mask, air-purifying
     respirator. Air-purifying respirators should be equipped with
     NIOSH-approved (or equivalent) N95 filters. If oil mist is present,
     use R95 or P95 filters.
Personal Protective Equipment
• “Use impervious gloves.”

 Hand Protection
 • NOTE: Material is a potential skin sensitizer.
 • The gloves listed below may provide protection against permeation.
   Gloves of other chemically resistant materials may not provide
   adequate protection:
     – Butyl rubber or Nitrile
 •   Gloves should be removed and replaced immediately if there is any
     indication of degradation or chemical breakthrough. Rinse and
     remove gloves immediately after use. Wash hands with soap and
     water.
Spill Clean-up
• “Clean up spills immediately.”

 Methods for cleaning up:
 • Adsorb the spill with spill pillows or inert solids such as clay or
   vermiculite, and transfer contaminated materials to suitable
   containers for disposal.
 • Deactivate spill area with freshly prepared solution of 5% sodium
   bicarbonate and 5% sodium hypochlorite in water. Apply solution
   to the spill area at a ratio of 10 volumes deactivation solution per
   estimated volume of spill to deactivate any residual active
   ingredient. Let stand for 30 minutes.
 • DO NOT add deactivation solution to the waste pail to deactivate
   the adsorbed material.
Ventilation
• “Use local ventilation.”

 Engineering measures:
 • Use explosion-proof local exhaust ventilation with a
   minimum capture velocity of 150 ft/min (0.75 m/sec) at
   the point of dust or mist evolution.
 • Refer to the current edition of Industrial Ventilation: A
   Manual of Recommended Practice published by the
   American Conference of Governmental Industrial
   Hygienists for information on the design, installation,
   use, and maintenance of exhaust systems.
Operational Information
• Component exposure limits // monitoring methods
• Health hazard/toxicology data
• Specific glove/protective clothing
  recommendations
• Specific respirator cartridge recommendations
• Engineering controls
• Combustion and decomposition by-products
• Emergency response procedures
• Eco-tox data
• Medical surveillance // biological monitoring
Internal Hygienists
  • IHs have training and experience in:
    –   Respiratory protection
    –   Toxicology, epidemiology
    –   Exposure assessment
    –   Engineering controls (i.e. local exhaust ventilation)
    –   Safety and health regulations
    –   Emergency response
    –   Personal Protective Equipment
    –   Environmental protection
    –   Hazard evaluation
    –   Employee training
Collaboration Examples

•   Standard phrases
•   Workplace Exposure Limits
•   Exposure monitoring methods
•   Glove/protective clothing permeation testing
•   Respirator cartridge testing
•   Training information for customers
•   Chemical Safety Summary Card (CSSC)
Chemical Safety Summary Card (CSSC)

•   One page document
•   Intended as a quick reference
•   Raw materials/intermediates included
•   Sections:
    – Product Identification
    – Hazards Identification
    – Exposure Controls/Protective Measures
• Not a replacement for the complete MSDS
MSDS Intranet
New Challenges – Chemical Process Safety
    Washington, DC, March 25, 2004 - Carolyn Merritt, Chairman of the
    U.S. Chemical Safety and Hazard Investigation Board (CSB) told a
    Congressional committee that:


•   The safety information accompanying chemical products delivered to industrial
    plants frequently is deficient, leading to avoidable deaths and injuries.
•   "Deficiencies in hazard communication and Material Safety Data Sheets are
    among the common causes of major chemical accidents that result in loss of
    life, serious injures, and damage to property and the environment."
•   Deficiencies in communicating hazards on the data sheets were cited in 10 of
    19 investigation reports (1998-2004). The deficiencies were found to be an
    actual root cause, contributing cause, or major causal factor in nine of the ten.
•   The Chairman in particular cited the inadequacy of information in data sheets
    concerning combustible dust dangers that occur in certain chemical
    processes.
Honeywell to Pay Millions for Chemical
Release that Resulted in Worker's Death
September 17, 2007


 • 1 ton cylinder mislabeled as refrigerant actually
   contained 1800 lbs. of antimony pentachloride
 • Honeywell received 2 years probation
 • $8M criminal fine
 • $2M for victim’s family
 • $2M for community restitution (various
   organizations)
MSDS - Who’s the audience?
  The AIHA fully supports one MSDS format for all target
  audiences. The AIHA encourages the use of international
  standards/guidelines (including recommended phrases and
  symbols) that allow MSDS preparers to communicate hazards in an
  understandable way to each of the various MSDS users. The AIHA
  recognizes that providing information on an MSDS, beyond that
  required by the OSHA Hazard Communication Standard, is
  necessary to fulfill needs of the variety of target audiences (e.g.,
  transportation, global inventory status, waste disposal
  information). Specific formatting and content guidelines or
  regulations can facilitate this need. One must remember that the
  MSDS is a reference document meant to be used with education
  and labeling to communicate hazards. It is not meant to be a
  stand-alone document.

          Hearing on Material Safety Data Sheets and Hazard Communication
                              UNITED STATES SENATE
           COMMITTEE ON HEALTH, EDUCATION, LABOR AND PENSIONS
            SUBCOMMITTEE ON EMPLOYMENT, SAFETY AND TRAINING
                                    March 25, 2004
Emerging Markets




      Source: New York Times
Ongoing/Future Hazcom Issues

•   MSDS technical content
•   Readability
•   Emerging markets
•   Inter-regional labeling
•   GHS implementation
•   Chemical process safety
Truth in Labeling!
Thank you.