Appendix B Sample Hazard Communication Program

183 Pages·2014·4.19 MB·English

Introduction
IUOE National Training Fund
National HAZMAT Program
1293 Airport Road
Beaver, WV 25813
[phone]
Fax [phone]
[email protected]
www.iuoehazmat.org
This publication was made possible by grant number 5 U45 ES009763-21 from the National
Institute of Environmental Health Sciences (NIEHS), NIH. Its contents are solely the
responsibility of the authors and do not necessarily represent the offi cial views of the NIEHS,
NIH.
• It is not the intent of the content developers to provide compliance-based training in this
presentation, the intent is to address hazard awareness in the hazardous waste operations
and emergency response (HAZWOPER) industry, and to recognize the overlapping
hazards present in many construction workplaces.
• It should NOT be assumed that the suggestions, comments, or recommendations
contained herein constitute a thorough review of the applicable standards, nor should
discussion of “issues” or “concerns” be construed as a prioritization of hazards or
possible controls. Where opinions (“best practices”) have been expressed, it is important
to remember that safety issues general and HAZWOPER jobsites specifi cally will
require a great deal of site- or hazard-specifi city – a “one size fi ts all” approach is not
recommended, nor will it likely be very effective.
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Introduction
To: Users of IUOE National Training Fund Programs
The IUOE National Training Fund -- National HAZMAT Program offers a broad
spectrum of safety and health training, as well as training support to other users
of the National HAZMAT Program’s resources. The National HAZMAT Program
has available, at no cost, the following:
(cid:120) Direct training for IUOE Local Union members and other appropriate
groups conducted at the Local Union, at an employer’s site, or other
appropriate locations
(cid:120) Training materials, including personal protective equipment, and other
types of equipment for National HAZMAT Program Master Instructors’
HAZWOPER and other safety and health related classes
(cid:120) New instructor mentoring for HAZWOPER and other safety and health
related classes
(cid:120) Safety and health regulations and standards interpretation assistance
(cid:120) Technical safety and health, emergency/disaster response, and energy
security and restoration assistance
(cid:120) Training data information from the National training database for Local
Union members and others who have completed training through the
National HAZMAT Program
(cid:120) Expertise to provide best practices and information sharing, develop
scenarios, and conduct exercises to prepare all stakeholders to protect
and restore critical infrastructure should an event, manmade or natural,
occur
(cid:120) Training information on HAZWOPER, OSHA, emergency/disaster
response, and other safety and health classes held at other IUOE Local
Unions nationwide
Inquiries regarding the services the IUOE National Training Fund -- National
HAZMAT Program have to offer can be directed to Barbara McCabe at 1293
Airport Road, Beaver, WV 25813, called in at [phone], faxed to (304)
253-7758, or emailed to [email protected].
The IUOE National Training Fund encourages all workers to take advantage of
the National HAZMAT Program’s services to assist you to be employable,
competitive, and safe in the workplace.
Sincerely,
Jeffrey R. Vincent
Executive Director,
IUOE National Training Fund
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Introduction
Table of Contents
Course Introduction 1-1
Hazard Communication (Hazcom) Standard Overview 2-1
Globally Harmonized System (GHS) and Registration, Evaluation,
Authorization and Restriction of Chemicals (REACH) 3-1
Training Requirements 4-1
Chemical and Toxicology Overview 5-1
Hazard Classifi cation Under GHS 6-1
Communicating Chemical Hazards 7-1
Hazard Controls 8-1
Spill Response 9-1
Appendix A: Glossary A-1
Appendix B: Sample Hazard Communication Program B-1
Appendix C: Sample Safety Data Sheets C-1
Appendix D: Hazard Pictograms and Signal Words D-1
Appendix E: Sample Spill Response Plan E-1
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Preface
Notes for instructors
Course delivery and classroom management
This is a 4-hour Hazard Communication course that satisfi es the general training requirements
of OSHA’s Hazard Communication Standard 29 CFR 1910.1200 which was updated in 2012.
If this course is not delivered and tailored for participants’ specifi c worksite, some additional
training will be required at their worksite (e.g., what chemicals are in their work area, where
the employer Hazcom Program is, where Safety Data Sheets (SDSs) are, etc.). If this material
is tailored to a specifi c worksite/employer (e.g. using worksite specifi c SDS and the employer
Hazcom Program) then no additional initial training should be required.
The course is designed with the adult education paradigm of student involvement and small
group activities. This paradigm will foster participation from the class and allow students to draw
on their work experience to learn material and solve problems.
We encourage you to be an instructor who facilitates the course. Try to use the activities and
assertion evidence presentations to draw out students’ experiences related to chemical use in the
workplace and then to help them fi ll in the missing pieces.
If you are an “experienced” trainer, you should expect to study, review and prepare for this
course for at least two to four hours per hour you will be teaching. There is a great deal of
information in this course, including a robust set of instructor’s notes embedded in the
PowerPoint presentations. It is advisable to review the presentations, at least a few times, to
become familiar with them and how the assertion evidence format works. You may also want to
review supporting material, such as IUOE’s 40-hour Basic Site Worker course to brush up on
hazard controls, chemistry, units of measurement, etc. Since this course covers the updated
Hazard Communication Standard, an effort should be made to familiarize yourself and co-
trainers in your group to the new regulation.
Refer students to the HAZCOM student manual. It is for their reference. It expands on the
material presented in the PowerPoint slides. It also contains activities in the manual and
provides space to record answers.
OSHA Hazard Communication Standard 2012 update overview
Provided below is OSHA’s overview of the updated Hazcom Standard.
Purpose
The Hazard Communication Standard (HCS) 1994 includes a paragraph that describes the
purpose of the HCS, and addresses preemption of state and local laws. The Hazard
Communication Standard (HCS 2012) includes essentially the same paragraph as the HCS 1994.
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Preface
The primary modifi cation to this paragraph is to state affi rmatively that part of the purpose is to
harmonize with international requirements. OSHA also clarifi ed the standard’s preemptive affect
on state laws. Other than terminology, no additional substantive changes have been made in this
paragraph of the HCS.
Scope and application
In this paragraph, OSHA has removed reference to Appendix E, which previously provided
employers with guidance information regarding the determination of their compliance
obligations. Rather than include this information in the Appendix, OSHA will provide separate
guidance documents to employers. Additionally, this paragraph in the HCS 2012 will continue to
address the many practical accommodations OSHA has made regarding application of the HCS
to different types of workplaces, as well as deal with the interface of the HCS to other Federal
laws that address similar areas. No changes in these rules are necessary to incorporate the GHS;
therefore, only terminology changes have been made in this paragraph of the HCS.
Defi nitions
Several key changes have been made to update the defi nitions section. This Final Rule provides
more detailed physical and health hazard criteria. However, this information has now been
moved from this section into Appendices A and B. Additionally, in order to be consistent with
the GHS, OSHA has added, deleted, and modifi ed a number of the defi nitions. The following
changes were made to defi nitions in the HCS 2012:
• Added the following defi nistions: classifi cation, hazard category, hazard class, hazard
not otherwise classifi ed, hazard statement, label elements, pictogram, precautionary
statement, product identifi er, pyrophoric gas, Safety Data Sheet, signal word, simple
asphyxiant, and substance.
• Deleted the following defi nitions: combustible liquid, compressed gas, explosive,
fl ammable, fl ashpoint, hazard warning, identity, Material Safety Data Sheet, organic
peroxide, oxidizer, pyrophoric, unstable (reactive), and water-reactive.
• Revised the following defi nitions: chemical, chemical name, hazardous chemical, health
hazard, label, mixture, physical hazard, and trade secret.
• The defi nition of Hazardous Chemical was located incorrectly in the HCS 1994 and here
in this document it has been properly relocated to where it should have been placed in
the correct alphabetical order. While it remains an important defi nition in both the HCS
1994 and the HCS 2012, the proper relocation in alphabetical order is the reason for this
defi nition being struck in the Refer to the Summary and Explanation of the Final Rule to
gain a better understanding of the changes.
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Preface
Hazard classifi cation
The hazard classifi cation approach in the GHS is quite different from the performance-oriented
approach in the HCS 1994. The GHS has specifi c criteria for each health and physical hazard,
along with detailed instructions for hazard evaluation and determinations as to whether mixtures
of the substance are covered. OSHA has included the general provisions for hazard classifi cation
in paragraph (d) of the revised rule, and added extensive appendixes that address the criteria for
each health or physical effect. Mandatory Appendices A and B provide classifi cation guidance for
Health Hazards and Physical Hazards, respectively. The hazard classifi cation criteria contained
in the HCS 2012 is test method-neutral. That is, the person classifying a chemical or substance
should use available data and no additional testing is required to classify a chemical. Please refer
to the Summary and Explanation of the Final Rule to gain a better understanding of the changes.
Hazard Communication Program

This section of the HCS 1994 was retained. As the GHS does not include any requirements
regarding Hazards Communication Programs, OSHA is maintaining the provisions of the HCS
1994. No substantive changes (only terminology) have been made in this paragraph of the HCS
2012.
Labels
This paragraph has been extensively re-written. While, the HCS 1994 had a simple and
performance-oriented approach to labels, this fi nal rule sets forth detailed and specifi c provisions
for labeling. Additionally, a new mandatory Appendix C indicates what specifi c information
is to be provided for each hazard class and category once a chemical is classifi ed. Under this
revised paragraph chemical manufacturers and importers must provide a label that includes: the
product identifi er; supplier information which is to include name, address and phone number of
manufacturer, importer or distributor; and the signal word, pictogram, and hazard statement for
each hazard class and category. Precautionary statements must also be provided. The HCS 1994
does not require the use of pictograms, specifi c signal words, or precautionary statements.
Safety Data Sheets (SDS)
Safety Data Sheets, previously referred to as Material Safety Data Sheets, will now require a
16-section format that is essentially the same as the ANSI standard for Hazardous Workplace
Chemicals - Hazard Evaluation and Safety Data Sheet and Precautionary Labeling Preparation
(ANSI Z400.1/Z129.1-2010), already familiar to U.S. employers. Paragraph (g) lists the sections
in the order they are to be provided on the Safety Data Sheets. This paragraph is supplemented
by new mandatory Appendix D, which details the information to be included under each heading.
The HCS 1994 requires similar information, but allows any format to be used. This Final
Rule is designed more in-line with the GHS, which has a uniform approach. This uniformity
will improve the effectiveness of the SDS, as well as make it easier for employers to comply.
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Preface
The appendix to this side-by-side analysis compares the requirements of the new mandatory
Appendix D of the Final Rule to the current requirements of the HCS 1994.
Training and information
The provisions in paragraph (h) indicate that the new label, SDS formats and presentation of
information must be discussed in training. All employers will be required to conduct additional
training to ensure that their employees are familiar with the new standardized labels and SDSs.
Otherwise, the training provisions remain the same as the HCS 1994.
Trade secrets
The trade secret provisions of the GHS are consistent with the HCS 1994 and therefore only
a few changes were made to this section. The GHS, unlike the current HCS 2012, requires
disclosure of the percentage composition of mixtures on the SDS. This fi nal rule adopts this
requirement, but allows the manufacturer to claim trade secret protection for this requirement.
This is the only substantive change to the existing standard’s trade secret protections.
Effective dates
OSHA’s Final Rule requires employers to train employees on the new label elements and SDS
format by December 1, 2013. All other provisions are to be in effect by June 1, 2015, with two
exceptions. First, distributors will be given an extra six months to ensure all manufacturer labels
are updated. Second, all employers will have an additional year to ensure that updated workplace
signs, Hazard Communication Program, and auxiliary training necessary for newly identifi ed
physical or health hazards, as provided in (h)(1), are in place.
Appendices
Mandatory Appendices A, B, C, D, E and non-mandatory Appendix F.
Allocated time

The minimum time to facilitate this course effectively is 4 hours, including activities and report
back. If you fi nd the class has a need or a pertinent discussion has developed, adjust time as you
see fi t. Also, it is understood that 4 hours of time may be hard to come by; however, to effectively
teach Hazcom with adult methods, 4 hours is a minimum starting point. If this course is delivered
as an initial Hazcom course in less than 4 hours, it may not satisfy the Hazcom requirements
under OSHA. There is no minimum Hazcom training time under the standard but, as stated by
OSHA, “The employer, however, maintains the responsibility to ensure that their employees are
adequately trained and are equipped with the knowledge and information necessary to conduct
their jobs safely.” Also, the new GHS-based labeling and pictogram requirements found in the
standard will take time to understand as instructors and students alike. Delivering instruction on
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