Slide 1 - Welcome to Washington State Healthcare Safety Council

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					Hazard Communication
Emergency Response
July 31, 2009
Employer Chemical Hazard Communication
   WAC 296-800-170 “HazCom”

   Four Major Parts:
   1. MSDS
   2. Labeling
   3. Training
   4. Written Program
Hazard Communication

Employees have the right to know about
hazardous chemicals at their worksite:

What the chemicals are,

What are the hazards,

How to protect themselves.
This training will cover
 What are hazardous chemicals
 Exemptions
 Labeling
 Training
 Written Program
What are hazardous chemicals?
 "Hazardous Chemical" is a term that is
  broadly used in the hazard
  communication rule.
 A hazardous chemical includes:
   – solvents
   – glues
   – paints
   – products that may release a
     hazardous chemical.
 What are hazardous chemicals?
 Flammables cause thermal burns
  or death

 Corrosives cause chemical burns
  to skin, eyes or lungs

 Toxics cause reversible or
  permanent effects to internal
  organs or whole body
  What are hazardous chemicals?

 Sensitizers cause allergic
  response from repeated doses.

 Irritants cause reversible effects.

 Carcinogens cause cancer usually
  over a long time.
What are hazardous chemicals?
 Generally if an item is regulated by
  another federal rule it is not covered by
  hazard communication.

 The following slides present items that
  may be exempted from the rule; please
  see WAC 296-800-17055 for the specific
Exempted items – not covered

Hazardous waste

Articles (solid objects)

Most drugs

Food and alcoholic beverages
  Exempted items – not covered

Consumer products (most of
the time)

Tobacco & tobacco products
Articles – when they are & are not covered

   Article Not            Covered
   Brick   used whole     sawed or
           or intact      cut in half
   Pipe     bent with a cut by a
            tube bender torch
   Nylon    tying a knot burning the
   rope                  ends
  HazCom Breakdown
Four Major Parts to the Standard:
  •Material Safety Data Sheets (MSDSs)
  •Labeling Chemical Containers
  •Employee Training
  •Written Program
 MSDSs – what information do they have?
Names of hazardous chemicals in       Acetone
a product,
Physical and chemical properties   Flammable &
of the product,                    highly volatile

Physical hazards of working with       Burns
the product,
Short and long term health           Headaches,
hazards of working with the         eye irritation
product (including signs and
symptoms of overexposures),
    Material Safety Data Sheet
• The main way the chemical         Inhalation
enters the body,

• The legal limit allowed in the    750 ppm

• If the chemical is a carcinogen      No
• Precautions for safe use of theventilation, keep
hazardous chemical,              away from open
     Material Safety Data Sheet
• Exposure control methods,
                                  Wear respirator,
including personal protective     rubber gloves
• Emergency and first aid         Eyes: flush with
procedures,                     water for 15 minutes

• The date the MSDS was
prepared or revised,                    1996

• Name, address and phone
                                      John Doe 1234
number of the person responsible         Maple St.
for the information in the MSDS.      Anywhere, USA
    Trade Secrets
 Manufacturer can withhold name of
  specific chemicals in a product

 Hazard information must still be
  disclosed in MSDS

 In emergencies name of chemical must
  be disclosed for medical treatment

 Disclosure also required if written
  request made for certain purposes
 Chemicals Labeled with the Following:

  – Identity of hazardous chemical

  – Hazard warnings including health effects

 Labels NOT required if the product:

  –Will be used in same work shift

  –Is used by person who did the transfer

  –Is under the control of the person who
   did the transfer
 What hazardous chemicals are used in the work
 How to work safely with these chemicals
 How the employee can tell if he or she is being
 What information is available in a material safety
  data sheet (MSDS)
 Where to find MSDSs in the work area
 Information on the requirements of the Employer
  Chemical Hazard Communication Rule
Training and Information
Employees must be trained on how to
work safely with hazardous chemicals.

This includes the things you have done
to protect employees including:
  •Engineering controls,
  •Work practices
  •Emergency Procedures
  •Personal Protective equipment
  •The labeling system you use
  •How to find information on the hazards in
  the material safety data sheet or label.
Employees must be trained on the
methods used to detect the presence
or release of hazardous chemicals in
the work area.
 Air monitoring
 Continuous monitoring devices
 The visual appearance or odor of the
 The physical and health hazards of the
  hazardous chemical
Hazard Communication Program
  –Identify hazardous chemicals and
   make a list
  –Obtain MSDSs for each product
  –Make MSDSs easily accessible
  –Ensure containers are labeled
  –Develop a written program
  –Ensure effective training
Hazard Communication - Special Situation

If only sealed containers are
   No written program required
   Keep MSDSs if received
   Existing labels must be intact
   Spill or leak response training
Hazard Communication - Written program

 Tailored to the worksite
 List of hazardous chemicals
 Non-routine tasks
 Multi-employer worksites (if needed)
HazCom – Multi-employer Worksites
  –Several employers at one site

  –More than one employers’
   employees are visiting/working

  –Mutual responsibility to share

  –Not just construction sites
   (janitorial, pest control,
   maintenance contractors)
Emergency Response
  (WAC 296-824)
Emergency Response

 A response to an anticipated
  release of a hazardous substance
  that is, or could become, an
  uncontrolled release
Hazardous Substance

 Any biological, radiological, or
  chemical substance that can have
  adverse effects on humans (see
  WAC 296-824-800 for a more
  specific definition).
Uncontrolled Release
 A release where significant safety
  and health risks could be created.
  Releases of hazardous substances
  that are either incidental or couldn't
  create a safety or health hazard
  (i.e., fire, explosion, or chemical
  exposure) aren't considered to be
  uncontrolled releases.
Incidental Release

 A release that can be safely
  controlled at the time of the release
  and does not have the potential to
  become an uncontrolled release.
     Danger Area
 Areas where conditions pose a serious danger to
  employees, such as areas where:
 Immediately dangerous to life or health (IDLH)
  conditions could exist
 High levels of exposure to toxic substances could
 There is a potential for exceeding the lower
  explosive limit (LEL), also known as the lower
  flammability limit (LFL), of a substance.
 Any atmospheric condition that
 Cause an immediate threat to life
 Cause permanent or delayed
  adverse health effects
 Interfere with an employee's ability
  to escape
     Limited Action
 Action necessary to:
 Secure an operation during emergency
 Prevent an incident from increasing in
 Examples include shutting down
  processes and closing emergency valves.
  NIOSH Pocket Guide to Chemical

 IDLH of Formaldehyde is 20 ppm
 Formaldehyde has a low vapor
 Dependant on size of room,
  ventilation rate, and surface area of
  the spill
Basic Requirements
   Written Emergency Response Plan
   Training Responders
   Medical Surveillance
   Recordkeeping
   Management of Emergency Operations
   Incident Command
   Personnel Briefing
Basic Requirements, Cont..
 Buddy System = 2 In and 2 Out
 Rescue and Medical Assistance
 Personal Protective Equipment
 Post Emergency Response
Common Findings
 No plans
 There doesn’t appear to be any clear
  roles or assigned duties.
 Responders have not received adequate
 No procedures for limited actions
 Personal Protective Equipment
 No Command Structure
  Key Questions

 Are employees expected to participate
  in an emergency response?
 Is the facility covered by community
  emergency response plan?
   Key Points

 Emergency response is not defined by
  the quantity of hazardous substance
  or the level of PPE. It depends on the
  danger and the safety and health risk
  the release may pose to employees.
 Key Points
 The level of training depends on the
  role employees will be expected to
  play in the event of an emergency
 Key Points
 All emergency response personnel
  must receive annual refresher
 Key Points
 The emergency response planning
  and procedures is to be based on
  the worst case scenarios.
 Key Points
 Selection of PPE is to be based on
  the worst case scenarios.
 Key Points
 The emergency response plan and
  procedures is to be site specific.
Compliance Issues/Recommendations
 Use Small Containers of Formaldehyde
   – Prefilled containers for Specimens
 Proper Amount of Absorbent
 MSDS for concentration used
 Clearly Define Roles for a Spill
   – Who responds, who evacuates
Compliance Issues/Recommendations
 Badge Sampling
  – Methanol Mixed with Formaldehyde
  – Methanol Interferes with Sample
  – 35% Below Actual Exposure
     Directives and Other Assistance
 WRD 12.75 – Emergency Response to
  Hazardous Substance Releases
 WRD 10.6 – 1994 NIOSH Pocket Guide IDLH
 WRD 32.99 – Post Emergency Oil Spill
  Response Operations
 The United States Department of
  Transportation's Emergency Response
  Guidebook (search at:
Directives and Other Assistance,
 WISHA Helpful Tools – Developing
  Emergency Response Plans
 National Fire Protection Association
  (NFPA) – A variety of standards
  and guides for emergency response