e-compliance Training A Hazard Communication - October 2018 In 2012, OSHA modified the Hazard Communication Standard significantly. This was done to adopt the internationally used Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS classifies chemicals and requires communication of hazard information to workers in a standardized way. After the final rule took effect, there was a phase-in period that lasted several years, with multiple compliance dates, all of which have now passed. Manufacturers and employers should now have completed their transition to the new system, along with employee training on the changes and any revised policies/procedures. If you have not already received training on the new information, this training material provides it, along with general Hazard Communication topics. Hazard Communication Plan Hazard Communication is often referred to as Right to Know, because its purpose is to inform employees of known hazards associated with various chemicals used within the workplace, and to provide information on how to prevent injury/illness. The following elements must be included in a compliant plan: A Hazard Classification policy--an explanation of how products are determined to be hazardous; Chemical Inventory--a listing of chemical hazards in the workplace; Safety Data Sheets (SDSs) informational pages that describe hazards associated with a product, safe handling and use precautions, etc. Chemical Hazard Labeling--an explanation of chemical labels and other forms of warning used in the workplace; Training--employees will be trained to work safely with hazardous products. Your practice s Hazard Communication Program or Plan must be available for employees to review upon request. While the employer has a responsibility to develop and maintain a Hazard Communication Program, it is an employee s responsibility to follow established policies. As an employee, your responsibilities include participation in training for hazard communication and following the policies and safety measures developed/adopted by your employer. Working safely requires a cooperative effort between you and your employer. THIS TRAINING SESSION IS RECOMMENDED FOR: All employees, whether administrative or clinical, who use products for which the practice maintains safety data sheets (SDSs). Training Objectives This training session is designed to meet the requirements found in the Hazard Communication Standard (29 CFR 1910.1200). The learning objectives are to inform and retrain employees of: the Hazard Communication Standard and the Globally Harmonized System of Classification and Labeling of Chemicals (GHS); identifying hazardous chemicals; understanding the content of Safety Data Sheets; chemical hazard labeling; pictograms; and hazards associated with chemical products, and measures used to work safely with them. Interactive Training Reminder Compliance Training is an interactive training program in which you can address questions with other staff members or supervisors to obtain clarification for situations in your work setting. Write down any questions that you have about the training topic and address them with your Training Coordinator or supervisor. October 2018
B Hazard Classification It would be burdensome for employers to determine whether every product they use is hazardous. For this reason, the Hazard Communication Standard allows employers to rely on the determination of the manufacturer. Manufacturers have the knowledge and expertise to identify whether a product meets the definition of hazardous under the Rule, which classifies any product that contains 1% or more of a hazardous chemical or.1% or more of a carcinogen as hazardous. by which the substance is known, the recommended use of the chemical, and any restrictions on use. It also provides the name, address and telephone number of the manufacturer. Section 2 - Hazard Identification This section identifies the hazards of the chemical presented and the appropriate warning information associated with those hazards. Information that is also presented on the label of the product, such as the signal word (warning or danger), hazard statement(s), pictograms, and precautionary statement(s) will be found in this section. If a product is hazardous, the manufacturer will provide a safety data sheet (SDS). If it is non-hazardous, the manufacturer will provide a letter stating that the product is nonhazardous. Employers are required to collect and maintain SDSs for all hazardous products in the workplace. SDSs must be made available for employee reference and review. Safety Data Sheets (SDSs) previously known as material safety data sheets or MSDSs Section 3 Composition/Information on Ingredients This section identifies the ingredient(s) contained in the product, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. Section 4 First Aid Measures This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. SDSs are informational pages that identify a product s potential for physical and health hazards, as well as provide instructions for users on how to work safely with a product, personal protective equipment, proper storage and safe disposal of it, and what to do in the event of an accident or spill involving the product. Section 5 Fire-Fighting Measures This section provides recommendations for fighting a fire involving the chemical. Suitable extinguishing equipment will be recommended. Special protective equipment or precautions for fire-fighters, as well as specific hazards that develop from the chemical during a fire will be listed in this section. Manufacturers had until June 2015 to convert existing MSDSs to the new SDS format and make them available to employers for implementation and training. If you notice that some data sheets are still in the old format, ask your Safety Officer to obtain an updated copy. Section 6 Accidental Release Measures This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. You should be able to look at an SDS and find information such as emergency first aid procedures and spill control measures. Additionally, you should understand the new SDS format and chemical hazard labels, which are explained in this training material. Section 7 Handling and Storage This section provides safe handling guidance and conditions for safe storage of the chemical. Precautions for handling incompatible chemicals, minimizing the release of the chemical into the environment, and general hygiene practices will be included. SDS Content The new SDS format contains 16 sections that must appear in the required, standardized order. Section 1 Identification This section contains the product identifier used on the label, and any other common names Section 8 Exposure Controls/Personal Protections This section indicates the exposure limits, engineering controls, and personal protective equipment that should be used to minimize worker exposure. e-compliance Training {Hazard Communication October 2018
Section 9 Physical and Chemical Properties This section identifies physical and chemical properties of the substance or mixture, such as flammability, solubility, flash point, etc. Section 10 Stability and Reactivity This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other. Section 11- Toxicological Information This section identifies toxicological and health effects information or indicates that such data are not available. The likely routes of exposure, description of chronic health effects, measures of toxicity, among other data will be included, if known. Section 12 Ecological Information This section provides information to evaluate the environmental impact of the chemical(s) if it were released into the environment. Section 13 Disposal Considerations (non-mandatory) This section provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to section 8 (exposure controls/ personal protection) of the SDS. Section 14 Transport Information (non-mandatory) This section provides guidance on classification information for shipping and transporting hazardous chemical(s). Section 15 Regulatory Information (non-mandatory) This section identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. Section 16 Other Information - This section indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version. Chemical Inventory The Hazard Communication standard requires that workplaces maintain a listing or inventory of the hazardous chemicals present in the workplace. This is not a physical inventory count, but rather a listing/cross-reference of the hazardous chemicals that are currently stored or used in the practice. The practice will maintain an SDS for each product on the chemical inventory listing. If you ve received a letter from a manufacturer that a product is non-hazardous, it does NOT need to be included on the chemical inventory listing. Exemptions When they are in solid, final form, for direct administration to the patient (i.e. tablets, pills, capsules) medications and drugs are considered exempt from the Hazard Communication Plan and do not require SDSs or labeling. Liquid medications and injectables are NOT exempt, and do require SDSs, unless they have been classified as non-hazardous (again, your Safety Officer would have received a letter from the manufacturer stating that the item is non-hazardous). Sample medications are exempt, as long as there is no employee exposure. This means that you do not open samples in the office--the samples are given to patients in their original, unopened packaging for use outside the practice. Consumer products are exempt from the requirement for SDSs, if they meet certain conditions: 1) they are used in the same manner and 2) with the same approximate frequency that a normal consumer would use them, as is often the case of products such as window cleaner, bug spray, etc. Although it might seem that bleach would qualify as a consumer product, it would not if you use it for routine disinfection, since you would experience more exposure than a normal consumer. Personal Protective Equipment (PPE) Several factors determine PPE that is needed: the potential for exposure during use (i.e., through inhalation, skin or eye contact, etc.), the procedure involving the product, the way the product is handled, and the engineering and work practice controls (i.e., ventilation, handling procedures, etc.) that are in place. Your practice will determine what PPE is appropriate by observing the ways in which a product may be used, and the potential for exposure or injury to the user. If there is reason to anticipate an exposure that could harm an employee even after work practice and engineering controls are in place, then the selection and use of PPE must be identified and explained to you by your Safety Officer or practice management. C e-compliance Training {Hazard Communication October 2018009
D Detecting the Release of a Hazardous Chemical It is important to be aware of the means by which you can detect the presence or release of a hazardous chemical in your workplace. In some limited cases, your employer may conduct monitoring via badges worn by employees, or there may be continuous monitoring devices in place. For others, you should be familiar with the visual appearance or odor of chemicals when they are released, so that you could report a release or over-exposure if it occurs. Be aware of any gas lines present (such as nitrous oxide or other gases), so that if there is a leak, you know how to detect and report it. Chemical Hazard Labeling Manufacturers must now provide labeling that meets the GHS standardized format. Therefore, the labeling burden is largely removed from employers responsibility. The only time practices must place supplemental labels on products is when they transfer a product from its primary container into a secondary, unlabeled container, or when the manufacturer fails to provide a compliant label. In cases where a supplemental label is used, if the indication of hazards is abbreviated, you can find detailed safety information on the SDS for such products. Check with your supervisor or training coordinator for more information to identify and understand any supplemental labeling utilized in your practice. Manufacturer s labels must convey information about chemical hazards using quick visual notations to alert users of the product and provide immediate recognition of the hazards. Labels must also provide instructions on how to handle the chemical so that users are informed about how to protect themselves. Chemical labels provided by the manufacturer must now contain the following information: Signal Words These are used to indicate the relative level of severity of the hazard and alert the reader to a potential hazard on the label. There are only two words used as signal words, danger and warning. The more severe hazards will be identified by the signal word danger, and the less severe hazards by the signal word warning. There will only be one signal word on the label, no matter how many hazards a chemical may have. Hazard Statements Describe the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Manufacturers are required to include all of the applicable hazard statements on the label. Precautionary Statements A description of recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling. There are four types of precautionary statements: prevention (to minimize exposure); response (in case of accidental spillage or exposure emergency response, and first-aid); storage; and disposal. Pictograms These are graphic symbols used to communicate specific information about the hazards of a chemical. The required pictograms consist of a red square frame set at a point, with a black hazard symbol on a white background, sufficiently wide to be clearly visible. There are nine pictograms that may be used, including a hazard symbol pertaining to environmental toxicity. Although OSHA doesn t have jurisdiction over environmental concerns, this hazard symbol will likely appear on the label of many products, as this alert may indicate special disposal requirements. Although OSHA will not enforce the use of the environmental toxicity pictogram on labels, you should understand what the pictogram for environmental toxicity indicates. Name, address, and Telephone Number This is the contact Supplementary Information The label producer or manufacturer may provide additional instructions or information information of the chemical manufacturer, importer, or other responsible party. that they deem helpful for the user of the product. This may include personal protective equipment pictograms, directions Product Identifier This is how the hazardous chemical is for use, and expiration or fill dates. identified. This can be (but is not limited to) the chemical name, code number or batch number. The manufacturer, importer or distributor can determine the appropriate product identifier. The same product identifier must be included on the label and in section 1 of the SDS. e-compliance Training {Hazard Communication October 2018
Pictograms E Flammables Self Reactives Pyrophorics Self-heating Emits Flammable Gas Organic Peroxides Gases Under Pressure Oxidizers Carcinogen Mutagenicity Reproductive Target Organ Toxicity Respiratory Sensitizer Aspiration Toxicity Toxicity (harmful) Irritant Narcotic Effects Acute Toxicity (harmful) Dermal Sensitizer Respiratory Tract Irritation Acute Toxicity (severe) Explosives Self Reactives Organic Peroxides Environmental Toxicity Corrosives CODE Product Name SAMPLE LABEL Product Identifier Hazard Pictograms Company Name Street Address City State Postal Code Country Emergency Phone Number Keep container tightly closed. Keep away from heat/sparks/open flame. No Smoking. Only use non-sparking tools. Use explosion-proof electrical equipment. Do not breathe vapors. Wear protective gloves. Do not eat, drink or smoke when using this product. Wash hands thoroughly after handling. Dispose of in accordance with local regulations as specified. Supplier Identification Highly flammable liquid and vapor. May cause liver and kidney damage. Precautionary Statements Signal Word Danger Supplemental Information Hazard Statements Directions for Use In Case of Fire: use dry chemical (BC) or Carbon Dioxide (CO 2 ) fire extinguisher to extinguish. First aid: If exposed call Poison Center. If on skin (or hair): Take off immediately any contaminated clothing. Rinse skin with water. Fill Weight: Gross Weight: Expiration Date: Lot Number: Fill Date: e-compliance Training {Hazard Communication October 2018009
F e-compliance Training Test Hazard Communication - October 2018 NAME: DATE: SIGNATURE: STAFF POSITION: There are 10 questions to the test for Hazard Communication. Return your test to your supervisor or Safety Training Coordinator upon completion. Individual tests will be maintained with the training log to document participation and understanding of the information. There is no pass or fail grade to the test. Review the training information to find the correct answers to any questions that may have been missed. 1 The Hazard Communication Standard was changed in 2012 to adopt a system that uses a standardized approach to classifying hazardous chemicals. 2 Under the new system, OSHA now has jurisdiction over environmental concerns such as proper product disposal. 3 Safety Data Sheets are no longer needed, because the new manufacturer hazard labels on products now contain all of the required safety information and are immediately available. 4 A product label will have as many signal words as necessary to communicate the hazards associated with that product. 5 If you don t open sample medications in the office, but just give them to patients for use outside the practice, then they are exempt -- you don t need to request or maintain an SDS or label the product. 6 Your practice will determine what PPE is appropriate by observing the ways in which a product may be used, engineering and work practice controls, and the potential for exposure or injury to the user. 7 Any product that contains 10% or more of a hazardous chemical or 1% or more of a carcinogen is classified as hazardous under the Hazard Communication Standard. 8 There are four types of precautionary statements on a hazard label: prevention (to minimize exposure); response (in case of accidental spillage or exposure emergency response, and first-aid); storage; and disposal. 9 Pictograms are graphic symbols on product labels and are used to communicate specific information about the hazards of a chemical. 10 Medications are exempt from the need for SDSs because they include a package insert. October 2018