Check labels on all listed materials to ensure they meet the labeling requirements. Also, add any additional and necessary information prior to making such products available for use. Then, prepare your program for hazard communication and management, including engineering controls, safe work practices and required PPE. If you have 10 or more employees, your hazard communication program must be kept up-to-date and in writing. Keep this on file in the hazard communication program manager's office.
The final step in your program is training employees on risks, using chemicals safely and protecting themselves BEFORE they are exposed to any hazardous chemicals. Your company must set up a Right-To-Know Training Program which ensures:
• Employees understand the Right To Know regulation, how to read MSDS and the types of hazards that can be present.
• Employees understand their specific hazards in the workplace, based on what they actually do at work, and the methods that you are using to control their exposure.
• Employees acknowledge their training (i.e., sign a training log) after the training session, indicating they attended training and received the proper information.
A product-specific MSDS must be available for each substance, and products must be properly labeled at all times. Giving an employee the MSDS to read DOES NOT satisfy the intent of the law with regard to training. The training is a forum for learning not only the hazards of the chemicals in their work areas, but also details how the employer controls these hazards through their hazard communication program. Employees should be able to ask questions to ensure they understand the information presented. For documentation purposes, training could include a short test. Depending on where you live, you should also be aware some states have regulations that require retraining on an annual basis.
Making Your Hazardous Chemical Inventory
To identify which chemicals in your workplace need to be included in a hazardous chemical inventory, first study the label on each product. This must be done on all containers, regardless of size. Hazardous chemicals can be found in containers ranging in size from 2 oz. to a 55-gal.-drum. The warning words to look for are: HAZARD, WARNING, DANGER and CAUTION.
If any one of these warning words appears, the chemical must be listed on your inventory. Manufacturers' labels are not consistent, and the warning information will not always be found in the same place on the label. Inspect each label carefully to determine if the product is hazardous.
To conduct a workplace inventory, walk through and identify chemicals by department. List all chemicals or hazardous materials observed. Consult purchasing records for any additional chemicals, and review OSHA log and accident reports, if any exist. Evaluate your building materials for asbestos, insulation or PCBs in transformers, if any are on-site. Be sure to also consider any byproducts or intermediate chemicals given off by operations performed in the workplace.
Once you have identified which products contain hazards, list the common name, complete chemical trade name, name of the manufacturer, how often the chemical is used, size of the container(s) and how much is stored. For each item on the list, you must have MSDS on file. To obtain MSDS, you must contact the manufacturer or distributor, preferably in writing. In requesting MSDS, be sure to use the exact trade name. Then, read all the MSDS to determine what and how the hazards exist.
Employers must also protect their employees from hazardous chemicals brought on site by contractors. Purchase orders or contracts should include requirements to have MSDS on site, and require that all contractors' materials be labeled.
If a product can be purchased at a retail store, it may not need to be listed, and the MSDS may not be needed. However, this type of product must be listed if it is used more frequently or in a different manner than normal retail or residential use.
As discussed in our first article, developing a safety program may seem like a daunting and expensive task for your business, but it is essential and money well spent. Studies have shown a $4 to $6 return for every dollar invested in safety and health. This continuing article series will help you with the basics of how to put together the required safety programs for your business. Remember, a successful safety program is a key to having not only healthy and competent workers, but also a healthy, successful business.
About The Author: Shannon DeCamp can be reached at 800-852-8314, or you can visit www.technetrainonline.com for more information on OSHA Compliance requirements for the surfacing industry.