By Stanton E. Thomas, IH
Published in the September 2008 issue of Today’s Facility Manager

The operation and maintenance of many facilities involves the use of numerous chemicals throughout their life cycles. Some of these chemicals are benign, while some can be extremely harmful. The best way for facility managers (fms) to ensure their workers stay safe around hazardous chemicals is to establish and maintain a robust Hazard Communication (HAZCOM) program.

A HAZCOM program provides information to employees who may be exposed to hazardous chemicals in their work environments. This information ensures that employees are aware of the chemicals they work with and explains what they need to do to safeguard themselves. Protection from hazardous chemicals could involve anything from gloves and aprons to respiratory protection and chemical suits. Chemicals are considered hazardous if they present any health dangers. Those presenting physical hazards could be flammable substances, combustible liquids, compressed gases, or water reactive materials.

A health hazard could be a chemical that causes damage to body tissues, organs, or internal systems. Examples would be substances that cause burns to the skin, blindness, damage to the reproductive system, allergic reactions, or cancer.

HAZCOM Standard

The primary purpose of the Hazard Communication Standard (HCS) is to provide information to employees exposed to chemicals in the workplace. OSHA maintains different standards based on the type of work being done. During instances when construction is being performed, HAZCOM in Construction would apply. For general maintenance activities, like those that take place around the shop, OSHA’s General Industry standard-29CFR1910.1200-would apply.

For the most part, the language in the rules is the same. A complete HAZCOM program under one standard would also likely comply with the other standard. An HCS requires an employer to prepare a written HAZCOM program.The primary elements of a written program should:

• describe the method in which the employer will bring chemicals into the workplace;
• train employees on the safe handling of chemicals;
• provide hazard information via a material safety data sheet (MSDS);
• clearly identify chemicals through labeling;
• clarify how hazardous chemicals will be identified if they’re stored in anything other than the original container;
• indicate how information on hazardous chemicals will be shared with contractors; and
• detail what kind of personal protective equipment (PPE) is needed.

Material Safety Data Sheet

An MSDS details information that is important for educating individuals who may be exposed to hazardous chemicals. These pages are also vitally important in case of an accident involving chemicals.

An MSDS is required for every chemical and is developed by the chemical manufacturer or importer of the product. It is required that an MSDS accompany each chemical purchased. If fms do not receive an MSDS, they can request one from the supplier.

To ensure that the MSDS is not substandard, the sheet should come from the supplier or directly from the manufacturer or importer. Fms can obtain these sheets either by phone or from the Internet. Information that is outdated will not be as compliant with OSHA standards.

Container Labeling

Another important part of a HAZCOM program is the labeling of primary and secondary containers. Training, written programs, and good intentions are of no use if people cannot identify what is in a container.

One recent case in Oregon involved a construction worker who used a discarded water bottle to hold methanol which, if perfectly clear, looks just like water. His co-worker and friend picked up the bottle at the end of the day and placed it in his truck’s cup holder, thinking it was one of his water bottles.

The next morning on the way to work, the co-worker drank some of the methanol, unaware it was not water. Within minutes, he had lost his vision, pulled off the road, and phoned someone for help. He ended up in the hospital for three days. Fortunately, he made a full recovery.

It is vital for employers to ensure that containers holding any type of chemicals are clearly marked. Regulations require the product name (identifiable back to the appropriate MSDS), contact information for the manufacturer, and a hazard warning such as “DANGER” or “WARNING.” Some companies affix the label information with wire and a tag, while others use a color coding approach. Fms need to make sure employees know and understand the system.

Knowledge Through Training

Training is the most critical element of any health and safety program. The same holds true for HAZCOM. All the hazard information in the world means nothing if employees are not trained to understand and act upon that knowledge. Employees must be aware of:

• hazards of chemicals they work with;
• the meaning of the warning labels;
• how to use PPE properly;
• what to do in an emergency; and
• how to obtain an MSDS quickly.

That last bullet point is the most important reason for HAZCOM and MSDS. Not all chemicals affect everyone the same way, and individual sensitivities vary, but the information on an MSDS provides protection for the majority of the population.

Providing an MSDS to medical first responders at the scene of an accident greatly improves the victim’s chance of a full recovery and provides important information for future protection and accident avoidance.

The better trained employees are about the purpose and location of an MSDS, the less time needed to take action and relay information to health providers. An educated co-worker may be a victim’s best friend in the event of an accident.

Thomas is a health enforcement manager/ industrial hygienist for the Oregon Occupational Safety and Health Division (OR-OSHA) and a member of the AIHA Meth Lab Working Group. For more information, visit the American Industrial Hygiene Association (AIHA) Web site at www.aiha.org.