Hazard Communication Standard
Background
The Community Right-To-Know reporting requirements build on the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS). Initially, the HCS applied only to manufacturers (designated by the Standard Industrial Classification (SIC) codes 20-39). However, in 1987, OSHA amended the regulation to incorporate all businesses, regardless of classification or size.
Under the Hazard Communication Standard, chemical manufacturers and importers must research the chemicals they produce and import. If a substance presents any of the physical and health hazards specified in the HCS, then the manufacturer or importer must communicate the hazards and cautions to their employees as well as to "downstream" employers who purchase the hazardous chemical. "Communicate the hazards" means training the workers specifically about the chemicals used at the workplace and how to use them properly and safely. This includes using the chemicals safely and properly in processes at the workplace. This can also mean how to safely work near or use equipment that has hazardous chemicals contained in it that could be released into the workplace, such as an ammonia refrigeration unit that could release anhydrous ammonia into the workplace in the event the heat exchanger coils are ruptured or a valve seal fails. Workers should never be working with chemicals or equipment that they are unfamiliar with. The goal behind the HCS is a safer workplace for workers. Informed of the hazards they encounter on the job, workers and their employers can create that environment.
Failure to comply with the Hazard Communication Standard represents OSHA's most cited program. 50% of OSHA's citations relate to a failure to implement the Hazard Communication Standard. |
Protection under OSHA's Hazard Communication Standard (HCS) includes all workers exposed to hazardous chemicals in all industrial sectors. Employees have both a need and a right to know the hazards and the identities of the chemicals they are exposed to when working. Employees also need to know what protective measures are available to prevent adverse effects from occurring.
More than 30 million workers are potentially exposed to one or more chemical hazards. There are an estimated 650,000 existing hazardous chemical products, and hundreds of new ones are being introduced annually. The Hazard Communication Standard (HCS) covers both physical hazards (such as flammability or the potential for explosions), and health hazards (including both acute and chronic effects).
By making information available to employers and employees about these chemical hazards, and the recommended precautions for their safe use, proper implementation of the HCS will result in a reduction of illnesses and injuries caused by chemicals. Employers will have the information they need to design an appropriate protective program. Employees will be better able to participate in these programs effectively when they understand the hazards involved, and to take steps to protect themselves. Together, these employer and employee actions will prevent the occurrence of adverse effects caused by the use of chemicals in the workplace.
The HSC established uniform requirements to make sure that the hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated and that this hazard information is transmitted to affected employers and exposed employees.
Chemical manufacturers and importers must convey the hazard information they learn from their evaluations to downstream employers by means of labels on containers and material safety data sheets (MSDS's). In addition, all covered employers must have a hazard communication program to get this information to their employees through labels on containers, MSDS's, and training.
This hazard communication program ensures that all employers receive the information they need to inform and train their employees properly and to design and put in place employee protection programs. It also provides necessary hazard information to employees so they can participate in, and support, the protective measures in place at their workplaces.
All employers in addition to those in manufacturing and importing are responsible for informing and training workers about the hazards in their workplaces, retaining warning labels, and making available MSDS's with hazardous chemicals.
Some employees deal with chemicals in sealed containers under normal conditions of use (such as in the retail trades, warehousing and truck and marine cargo handling). Employers of these employees must assure that labels affixed to incoming containers of hazardous chemicals are kept in place. They must maintain and provide access to MSDS's received, or obtain MSDS's if requested by an employee. And they must train workers on what to do in the event of a spill or leak. However, written hazard communication programs will not be required for this type of operation.
All workplaces where employees are exposed to hazardous chemicals must have a written plan which describes how the standard will be implemented in that facility. The only work operations which do not have to comply with the written plan requirements are laboratories and work operations where employees only handle chemicals in sealed containers.
The written program must reflect what employees are doing in a particular workplace. For example, the written program must list the chemicals present at the site, indicate who is responsible for the various aspects of the program in that facility, and state where written materials will be made available to employees.
The HCS mandates the following:
HAZARD ASSESSMENT
Each employer will conduct a hazard assessment for each chemical used in the workplace.
INVENTORY OF CHEMICALS
A list of chemicals used in the workplace is to be made available to the employees.
Material Safety Data Sheet (MSDS)
A MSDS is to made available for each chemical in the workplace.
LABELING
The employer is to adopt a labeling program for each chemical used in the workplace.
TRAINING
The employer is to demonstrate that all employees are trained on the HCS including the MSDS.
Each employer is to provide a written program describing this HCS. The written program is to be available to all employees.
http://www.osha-slc.gov/OshStd_data/1910_1200.html
OSHA's relatively new directive CPL 2-2.59A (http://www.osha-slc.gov/OshDoc/Directive_data/CPL_2-2_59A.html) along with its news release (http://www.osha.gov/media/oshnews/apr98/osha98163.html) specifically instructs its inspectors to verify if the employer/owner/operator has reported their EPCRA reportable hazardous materials AND coordinated its emergency action plan with the local fire department having jurisdiction.
The OSHA inspector will ask the employer if the facility has EPA reportable quantities of hazardous substances, and, if they do, whether the facility notified the LEPC of the hazardous substances. The OSHA inspector will also ask the employer if the facility has experienced any chemical releases in excess of reportable quantities, and will ask the employer for information regarding the facility's emissions inventory. This information would establish the quantities and types of hazardous substances at a facility and provide documentation through EPA's reporting requirements. The OSHA inspectors are instructed to make referrals, as appropriate, in writing to the EPA Regional Office.
In evaluating any work exposure the following concepts apply:
Recognition - Recognize the hazard
Evaluation - Measure the hazard
Control - Control the hazard in the following ways:
HAZARDS CAN BE ANY OF THE FOLLOWING:
The Occupational Safety and Health Administration (OSHA) is responsible for issuing standards and rules for safe and healthful working conditions, tools, equipment, facilities, and processes. Employers have the general duty of providing their workers a place of employment free from recognized hazards to safety and health, and must comply with OSHA standards. OSHA sets chemical exposure limits called Permissible Exposure Limits (PEL).
But these OSHA PELs have been known to be wrong before. For example, Methylene Chloride once had an OSHA PEL of 500 parts per million (PPM), and now, over a period of ten years, that PEL has been revised downward to 25 PPM. 1,3 Butadiene once had an OSHA PEL of 1,000 PPM, and this has now been reduced to 1 PPM.
OSHA PELs are based on the concept that the worker is exposed to chemicals for no more then 8 hours at a time. The worker thus has "downtime," or time away from the chemicals and workplace, allowing the body time to remove or lower the amount of chemicals in the system. Studies have shown that workers may exhale chemicals for hours that they have inhaled at the workplace after leaving work as the body rids itself of these chemicals. Continuous exposure to chemicals in the workplace with no downtime does not allow for the body to cleanse itself, therefore continuous exposure limits can cause the body to accumulate the chemical at a greater rate than it can expel it, a potentially unhealthy or dangerous situation. OSHA PELs do not apply to continuous exposure.
Firefighters responding to a chemical spill or release should determine the OSHA PEL for the chemical spilled and consider the "safe" zone for the public to be at 1/100th or 1/1,000th the OSHA PEL. There may be quite a problem in determining exactly what chemical has been spilled, so this task for firefighters is not easy. The name used for the edge of the "safe" zone is the area where the chemical is below the Level of Concern (LOC).
The firefighters responding to a chemical spill or release often consider or use another standard, the IDLH, or Immediately Dangerous to Life or Health. What the IDLH level is also helps emergency responders determine whether to use a respirator, or what types respirator to use, in a response. Obviously, knowing what these different standards are, what they mean, and how to interpret them is something to be done long before any accident occurs. This is another reason why chemical emergency preparedness depends on real-time, valid, facility chemical inventory information.
OTHER CHEMICAL EXPOSURE ISSUES
To further complicate matters, the OSHA PEL may not be an entirely correct figure. The National Institute of Occupational Safety and Health (NIOSH) has created standards for exposure to chemicals with Recommended Exposure Limits (REL) that are usually below OSHA PEL standards. And the American Conference of Governmental Industrial Hygienists (ACGIH) has created standards named Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs) that are also generally below OSHA PEL levels.
NIOSH Recommended Exposure Limits (REL) are developed under the authority of the Occupational Safety and Health Act of 1970 (29 USC Chapter 15) and the Federal Mine Safety and Health Act of 1977 (30 USC Chapter 22). NIOSH develops and periodically revises recommended exposure limits( RELs) for hazardous substances or conditions in the workplace. NIOSH also recommends appropriate preventive measures to reduce or eliminate the adverse health and safety effects of these hazards. To formulate these recommendations, NIOSH evaluates all known and available medical, biological, engineering, chemical, trade, and other information relevant to the hazard. These recommendations are then published and transmitted to OSHA and Mine Safety and Health Administration (MSHA) for use in promulgating (creating) legal standards. The operative word here is "recommend." NIOSH is purely an advisory body and has no legal authority of its own. OSHA is the only agency who has the legal authority to set exposure standards. The main difference between OSHA and NIOSH is that OSHA uses an 8 hour time weighted average while NIOSH uses a 10 hour time weighted exposure limit. [Time-weighted average means averaged over a period of time, so higher and lower exposure levels can occur.]
Also, NIOSH sets "ceilings" for which exposure levels cannot be exceeded at any time. OSHA rarely sets "ceiling" exposure levels. OSHA is not always successful in implementing NIOSH's recommendations: In July 1992, the 11th Circuit Court of Appeal in its decision in AFL-CIO v. OSHA, 965 F.2d 962 (11th Cir., 1992) vacated more protective PELs set by OSHA in 1989 for 212 substances, moving them back to PELs established in 1971.
American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) refer to airborne concentrations of substances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse health effects. These exposure levels are based on animal studies. With these and with all such exposure standards, there is uncertainty, and not a guarantee that adverse health will not result from exposure to these levels of chemicals in the air.
There are other related terms and abbreviations that may be encountered. STELs, which are Short-Term Exposure Levels (15 minutes), are based on the idea that a short-term exposure to certain levels of certain chemicals may be allowed. For the vast majority of chemicals, there is simply not enough toxicological data to warrant or establish a STEL.
TWA stands for Time-Weighted Average, which is based on the idea that exposure to levels of chemicals above the Threshold Limit Values are allowed so long as the employee is subjected to periods of time when the exposure to levels of chemicals below the Threshold Limit Values during the workday.
Biological Exposure Indices (BEIs) are reference values intended as guidelines for the evaluation of potential health hazards in the practice of industrial hygiene. BEIs represent the levels of determinants which are most likely to be observed in specimens collected from a healthy worker who has been exposed to chemicals to the same extent as a worker with some inhalation exposure to the TLV. What this means is laboratory animals have exhibited certain symptoms after exposure to levels of a certain chemical, such as traces of a chemical in their urine. And using this animal study data, similar symptoms are expected in humans at a similar level of exposure, with some adjustments regarding the size and weight of the human who has been exposed to the chemical. If the human has been exposed to the same chemical in large enough amounts, there would likely be some of this chemical in the human's urine. If a certain amount of a chemical caused a laboratory animal to get sick, then a proportional amount will likely make the human sick. BEIs are not intended for use as a measure of adverse effects or for diagnosis of occupational illness.
1. OSHA Permissible Exposure Limits:
PEL-TWA |
8 hours time weighted average concentration |
2. NIOSH Recommended Exposure Limits:
REL-TWA |
8 hour time weighted average concentration |
REL-STEL |
15 minute time weighted average concentration |
REL-C |
Ceiling concentration - not to be exceeded |
IDLH | 30 minute concentration that is Immediately Dangerous to Life and Health |
3. ACGIH recommended Treshold Limit Values:
TLV-TWA |
8 hour time weighted average concentration |
4. IDLH - Immediately Dangerous to Life or Health
The maximum level from which a worker could escape without any irreversible health
effects within a 30 minute time-frame.
[LINK to http://www.cdc.gov/niosh/npg/npg.html]
Intel XL EHS Workstation Overview
Employers are responsible for the safety and health of their workers. Some corporations, like Intel, have put together exceptional worker health and safety programs. OSHA tracks and reports the figures for recordable injuries (Recordable Rate, or injuries requiring treatment beyond first aid) and lost worker time (Lost Day Case [LDC], or injuries resulting in restricted duty or workers staying at home). The 1997 OSHA figures are available. The 1997 Recordable Rate for General Manufacturing was 10.3 per 200,000 hours worked, for the Electronics industry was 6.6/200,000 hrs, and for Intel worldwide was 0.26/200,000/hrs. The 1997 LDC Rate for General Manufacturing was 4.8 per 200,000 hours worked, for the Electronics industry was 3.1/200,000 hrs, and for Intel worldwide was 0.09/200,000 hrs.
Intel's OSHA figures for worker injuries and lost worker time due to injuries on the job site are among the best in the world. This did not happen by accident, but rather by careful planning and oversight in the Intel EHS (Environmental Health and Safety) Workstation Overview.
Intel has posted an overview of its EHS Workstation Overview on its XL web site, at http://www.intel.com/intel/other/ehs/projectxl/ at the heading Intel EHS Workstation Overview. Click here to go to the Intel XL EHS Workstation Overview.
http://www.intel.com/intel/other/ehs/projectxl/Workstation/XLdatamgmtNEW.htm