Hazard Communication Emergency Response WSHSC 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 MSDSs 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 exemptions. Exempted items – not covered Hazardous waste Articles (solid objects) Most drugs Food and alcoholic beverages Exempted items – not covered Cosmetics Consumer products (most of the time) Tobacco & tobacco products Articles – when they are & are not covered Article Not Covered 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), 42 Material Safety Data Sheet • The main way the chemical Inhalation enters the body, • The legal limit allowed in the 750 ppm air • If the chemical is a carcinogen No Adequate • Precautions for safe use of theventilation, keep hazardous chemical, away from open flame Material Safety Data Sheet • Exposure control methods, Wear respirator, including personal protective rubber gloves equipment, • 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 Labels Chemicals Labeled with the Following: – Identity of hazardous chemical – Hazard warnings including health effects Labels 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 Training What hazardous chemicals are used in the work area How to work safely with these chemicals How the employee can tell if he or she is being overexposed 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 chemical 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 handled: No written program required Keep MSDSs if received Existing labels must be intact Spill or leak response training required Hazard Communication - Written program Tailored to the worksite List of hazardous chemicals Labeling MSDSs Training 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 information –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 exist There is a potential for exceeding the lower explosive limit (LEL), also known as the lower flammability limit (LFL), of a substance. IDLH Any atmospheric condition that would: 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 responses or Prevent an incident from increasing in severity. Examples include shutting down processes and closing emergency valves. NIOSH Pocket Guide to Chemical Hazards IDLH of Formaldehyde is 20 ppm Formaldehyde has a low vapor pressure 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 Operations Common Findings No plans There doesn’t appear to be any clear roles or assigned duties. Responders have not received adequate training 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 response. Key Points All emergency response personnel must receive annual refresher training. 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 Values WRD 32.99 – Post Emergency Oil Spill Response Operations The United States Department of Transportation's Emergency Response Guidebook (search at: http://www.dot.gov). Directives and Other Assistance, Cont. WISHA Helpful Tools – Developing Emergency Response Plans National Fire Protection Association (NFPA) – A variety of standards and guides for emergency response activities.