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Hazard Communication Standard, General Industry – Regulation 29 CFR 1910.120

Ranking: 2

A Workplace Story

From a California FACE report:

A 23-year-old associate working in a university research laboratory used a syringe and needle to extract a pyrophoric chemical (t-butyl lithium) from a bottle. When the plunger came out of the syringe barrel, the t-butyl lithium – which was an air-sensitive reagent – ignited on contact with room air. The chemical splashed onto the victim’s clothing and set them on fire. (She was not wearing a laboratory coat at the time of the incident.) She died of the burn injuries she sustained.

The victim had been employed with the university for eleven weeks when the incident occurred. The employer had a written Injury and Illness Prevention Program (IIPP) and laboratory safety manual that required each research laboratory to have a written safe operating procedure (SOP) for the use of each hazardous chemical or substance. The principal investigator for each laboratory was responsible for preparing the SOP and training their employees and research staff on the safe handling of chemicals, including air-sensitive reagents such as t-butyl lithium. Although the principal investigator of the lab where the victim had worked said she’d received verbal instruction on the safe use of pyrophoric chemicals, there was no written documentation of her receiving any laboratory safety training.

The Numbers

Enforcement from October 2019 through September 2020

Total citations: 49

Total inspections: 24

Total proposed penalties: $174,174

Industries most often violating the hazard communication standard:

Manufacturing (part 2 of 3): $45,665

Transportation and Warehousing (1 of 2): $10,410

Manufacturing (part 1 of 3): $31,830

Accommodation and Food Services: $25,200

Public Administration: $19,506

Manufacturing (part 3 of 3): $9,516

Transportation and Warehousing (2 of 2): $10,311

Health Care and Social Assistance: $5,205

Retail Trade (part 2 of 2): $9,639

Wholesale Trade: $4,000

Prevention

Controlling exposures to chemical hazards and toxic substances is the fundamental method of protecting workers. A hierarchy of controls is used as a means of determining how to implement feasible and effective controls.

OSHA’s longstanding policy is that engineering and work practice controls must be the primary means used to reduce employee exposure to toxic chemicals, as far as feasible, and that respiratory protection is required to be used when engineering or work practice controls are infeasible or while they are being implemented.

Eliminating toxic substances or substituting safer alternatives for them is one recommendation from OSHA.

Engineering controls include:

  • Change process to minimize contact with hazardous chemicals
  • Isolate or enclose the process
  • Use of wet methods to reduce generation of dusts or other particulates
  • General dilution ventilation
  • Use fume hoods

Administrative and workplace controls include:

  • Rotate job assignments
  • Adjust work schedules so that workers are not overexposed to a hazardous chemical

Personal protective equipment (PPE) may include:

  • Chemical protective clothing
  • Respiratory protection
  • Chemical resistant gloves
  • Eye protection

Compliance

Under OSHA’s Hazard Communication Standard (HCS), chemical manufacturers, distributors and importers must provide Safety Data Sheets (SDSs) for each hazardous chemical to downstream users to communicate information on these hazards. The information contained in the SDS is required to be presented in a consistent user-friendly, 16-section format. It should include the properties of each chemical; the physical, health and environmental health hazards; protective measures; and safety precautions for handling, storing and transporting the chemical. It must be in English (although it can be in other languages as well).

Employers that have hazardous chemicals in their workplaces are required by OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a hazard communication program. The program must include labels on containers of hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and training for workers. Each employer must also describe in a written program how it will meet the requirements of the HCS in each of these areas.

Employers can implement an effective hazard communication program by following these six steps:

Step 1. Learn the Standard/Identify Responsible Staff

  • Obtain a copy of OSHA’s Hazard Communication Standard.
  • Become familiar with its provisions.
  • Make sure that someone has primary responsibility for coordinating implementation.
  • Identify staff for particular activities (e.g., training).

Step 2. Prepare and Implement a Written Hazard Communication Program

  • Prepare a written plan to indicate how hazard communication will be addressed in your facility.
  • Prepare a list or inventory of all hazardous chemicals in the workplace.

Step 3. Ensure Containers are Labeled

  • Keep labels on shipped containers.
  • Label workplace containers where required.

Step 4. Maintain Safety Data Sheets (SDSs)

  • Maintain safety data sheets for each hazardous chemical in the workplace.
  • Ensure that safety data sheets are readily accessible to employees.

Step 5. Inform and Train Employees

  • Train employees on the hazardous chemicals in their work area before initial assignment, and when new hazards are introduced.
  • Include the requirements of the standard, hazards of chemicals, appropriate protective measures and where and how to obtain additional information.

Step 6. Evaluate and Reassess Your Program

  • Review your hazard communication program periodically to make sure that it is still working and meeting its objectives.
  • Revise your program as appropriate to address changed conditions in the workplace (e.g., new chemicals, new hazards, etc.). WMHS

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