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Full Video Script: Welcome back to the 3rd week of our 2020 emphasis program on hazard communication brought to you by Safety Consulting NOW; a full fledged digital safety training, digital safety consulting and learning management platform. Sign up for our free content (like this video) on training.safetyconsultingnow.com and you can also see the huge library we have of our premium content that offers toolbox talk style videos as well as osha required trainings you and your team must have. Now listen. We are digging deep into these emphasis programs. I promise you that if you’re willing to listen to the details of this program (though not very sexy) and you apply the requirements I lay out in these videos, your programs will make your work environments safer and about as osha citation proof as possible. So let’s dig in.
The second part in the approach to communicating information in HazCom 2012 is to maintainSDSs (which is found in paragraph (g) Safety Data Sheets and Mandatory Appendix D). The SDSs are the source of detailed information on hazardous chemicals. This includes information for many different audiences like employers, workers, safety and health professionals, emergency responders, government agencies, and consumers. It’s difficult for one document to serve the needs of all of these different audiences since some require much more technical information than others. Therefore, the SDS sections have generally been organized so that the information of most use to exposed workers, emergency responders, and others who do not need extensive technical detail is in the beginning of the SDS, while the more technical information most commonly read by health and safety professionals is located in the later sections. For example, a description of a chemical’s health effects appears in Section 2 which is titled hazard identification, but the toxicological data by which the determination of these effects is based appears in Section 11, titled toxicological information. All of the sections are available to any reader, but there is a difference between what is necessary fora broader audience (workers and emergency responders, for example), and what might be needed by others designing protective measures or providing medical services.
The SDS requirements in HazCom 2012 are based on an internationally agreed upon 16-section SDS. This format is based on ANSI Z400.12, so it is most likely already familiar to your employees. HazCom 2012 establishes section headings for the SDS, as well as the order in which they are to be provided, and the minimum information required to be included in each section under Appendix D of the standard. However, the information in some of the sections are non-mandatory because they address information that involve the requirements of other government bodies, and therefore aren’t under OSHA’s jurisdiction. Even though these sections are not considered mandatory by OSHA, the headings are still required to be present on the SDS. They will provide useful information for you to address other requirements you may need to follow. The sixteen sections are as follows, including the non-mandatory sections which are sections 12-15. They are:
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure control/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
(And onto the non-mandatory sections)
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information the manufacturer might want to include.
As we discussed in week 1, chemical manufacturers and importers are required to obtain or develop an SDS for each hazardous chemical they produce or import. Chemical manufacturers, importers, and distributors are responsible for ensuring that their customers are provided a copy of these SDSs, at the time of the first shipment, and when an SDS is updated with new and significant information. But, regardless of this happening, employers must have an SDS on file for each hazardous chemical they use. Employers should trust the information received from their suppliers unless they know the information is incorrect.
If you do not receive an SDS automatically, you must request one as soon as possible or most simply, do a quick internet search of the product, print it out, and this is key…review it with your team, train on it and THEN…place it in your SDS boom. If you receive an SDS that is inadequate, like having blank spaces, you must request an appropriately completed one. If your request for an SDS or for a corrected SDS does not produce the information needed, you should contact your local OSHA area office for assistance in obtaining the SDS. Because at the end of the day, you will be the one cited by osha for using a product that is out of compliance and not being able to train your team on the associated hazards. Now, regarding language. The SDSs must be in English. Many larger manufacturers also produce SDSs in other languages. If you have workers who speak languages other than English, you may be able to obtain SDSs in those languages to ensure effective hazard communication and i would highly recommend you seek those out. Another key point: Employers must maintain copies of SDSs in their workplaces, and must ensure that SDSs are readily accessible to workers when they are in their work areas during their work shifts. This accessibility may be accomplished in many different ways. You must decide what is appropriate for your particular workplace. Some employers keep the SDSs in a binder in a central location (e.g., in a pick-up truck on a construction site). Others, particularly in workplaces with large numbers of chemicals, provide access electronically. However, and this is crucial: if access to SDSs is provided electronically, there must be an adequate back-up system in place in the event of a power outage, equipment failure, or other emergency involving the primary electronic system. And it’s also imperative that employees actually have full access to every SDS. Often times, we see a generic laptop in a facility that houses these documents, but when you ask employees if they know how to access it, they couldn’t tell you how. This is an immediate red flag to OSHA and basically shows that you don’t have the structured program required for this particular topic and all of the various elements we’ve been discussing these past few weeks. Now, as long as workers can get the information when they need it, any approach may be used. When workers must travel between workplaces during a work shift, SDSs may be kept at the primary workplace facility. No matter what system is used, employers must ensure that workers and medical personnel can immediately obtain the required information in an emergency. In order to ensure that you have a current SDS for each chemical in the plant as required, and that worker access is provided, OSHA’s compliance officers will be looking for the following items in your program:
1. Designation of person(s) responsible for obtaining and maintaining the SDSs;
2. How such sheet is maintained in the workplace (e.g., in notebooks in the work area(s) or electronically), and how workers obtain access to them when they are in their work area during the work shift;
3. Procedures to follow when the SDS is not received at the time of the first shipment; such as searching for it online.
4. An SDS for each hazardous chemical in the workplace, and training of workers that includes review of SDS format and use.
For employers using hazardous chemicals, an important aspect of the hazard communication program is to ensure that someone is responsible for obtaining and maintaining the SDSs for every hazardous chemical in the workplace.
So let me ask you:
- Who is responsible at your site or facility?
- Are you printing them off and shoving them into a folder?
- Or are you evaluating the first aid measures, personal exposure limits, required PPE, and health hazards and then training on those so each employee knows how to protect themselves?
These are the real questions that need to be answered when it comes to the way you track SDS sheets and their safety measures.
Alright, that wraps up this week. Next week we will be diving into employee training requirements. It’s a commonly cited violation and we wanna make sure we’re pointing you in the right direction. For Summit Safety Group and Safety Consulting NOW, I’m Jake Woolfenden and I’ll see you next week. Please check out training.safetyconsultingnow.com to subscribe to our full video training library. I’ll see you in the next one.