Note: This is the third installment in a series of four articles on building a safety program for your shop.
Parts 1 and 2 of this safety series have discussed the basic components of every safety program: hazard assessment, hazard control and training as well as detailed requirements for personal protective equipment (PPE) and respirators.
This month's article focuses on hazard communication. This is an essential part of a safety program for most fabrication shops because hazard communication violations are one of OSHA's most frequent citations.
What Is Hazard Communication?
OSHA's hazard communication standard requires evaluation and communication of all chemical hazards at the workplace. Each employee who works with or around hazardous chemicals must receive information about those chemicals through a comprehensive training program. Hazard communication programs are also commonly referred to as “right-to-know” programs.
Chemical manufacturers must evaluate the hazards of the chemicals they produce or import, and inform employers of those hazards through labels and material safety data sheets (MSDS). The law is designed to ensure that employers receive the information they need in order to design and implement adequate protection programs, as well as to educate their employees because informed employees can better conform to protective measures instituted in their workplaces.
Why Is A Hazard Communication Program Necessary?
The goal of every hazard communication program is to reduce the incidence of chemical and material source illnesses and injuries in the workplace. The law requires employers to protect their workers by managing the work environment and training employees. Training includes the chemical hazards of toxic substances as well as safe work practices and use of PPE with respect to hazards.
What Chemical Hazards Exist In The Surface Industry?
The primary chemicals used in surface fabrication include denatured alcohol and adhesives, along with some caulk and paint. These chemicals and others, as well as housekeeping or yard maintenance chemicals, must be included in your HazCom program and associated training. The employer must determine safe handling and storage procedures, provide proper PPE and make available showers and eye wash stations when harmful chemicals may be splashed on parts of the body. You must have MSDS on-site for each chemical in your workplace, and you must have a comprehensive training program for all employees with exposure. You must also assess the level of employee exposure to each chemical used in the workplace, and ensure you provide adequate protection through work practices, ventilation and PPE.
Your hazard communication program must include silica if you cut, sand, polish or similarly process granite or other stone containing silica at your facility. You must take measures to reduce exposure to silica dust as much as possible. Using water-fed tools or finding other ways to supply water at the point of operation to suppress dust is one common control method. Local exhaust ventilation systems can also be used to reduce exposure where the dust is generated. If you cannot reduce silica exposure to permissible levels, a complete respirator program must be put into place and include proper selection, fit-testing, cleaning and maintenance, supervision, training and written procedures.
What Constitutes An Effective Hazard Communication Program?
Every safety program begins with a hazard assessment to determine what chemical hazards exist in your workplace. You must be familiar with the permissible exposure limits of airborne contaminants and physical agents used. This means you, as the employer, must:
• Make a chemical inventory of all materials used in the shop that contain hazardous ingredients or can create hazards during use.
• Obtain an MSDS for each chemical, and maintain the MSDS file, which must be accessible to all workers on each shift. Then, cross-reference the chemical inventory list you have made to the MSDS file.
• You (or an industrial hygienist) should read your MSDS to assess potential hazards, required protective equipment and specific training needs.
The next step in an effective hazard communication program is hazard control. Hazards can be eliminated or controlled in the following ways:
• Whenever possible, eliminate or engineer away hazards. Use general or local exhaust systems to control dusts, vapors, gases, fumes, smoke, solvents or mists that may be generated in your workplace.
• Develop safe work practices to minimize risks, such as using hazardous materials only in specific work areas that can be ventilated.
• Personal protective equipment (PPE) is the last line of defense for protection from chemical hazards. You must select the correct PPE for each work task, which may include protective equipment for eyes, face, head, extremities, protective clothing, respiratory devices and protective shields and barriers. This equipment must be provided and maintained by the employer. When employees provide their own protective equipment, it is the employer's responsibility to assure its adequacy, maintenance and sanitation. Develop a written PPE program, including what PPE must be worn and who specifically must wear it.