According to section 5(a)(1) of the OSHA Act, often referred to as the General Duty Clause, employers are required to “furnish employees a place of employment that is free from recognized hazards that are causing or are likely to cause death or serious physical harm”. Providing information and training on the chemicals employees work with or possibly near is required to establish such a workplace. The Hazard Communication standard was created to establish guidelines to ensure employees have the knowledge and training needed to work safely with chemicals in the work place. Specific hazard communication requirements can be located in the standards for general industry, shipyard employment, marine terminals, long shoring, and construction.
The hazards associated with chemicals are as numerous as standards that cover them. Chemicals can pose both health and physical hazards. Health hazards can range from minor irritation and sensitization or can be as serious as cancer causing agents. Physical hazards can be in the form of flammables, corrosives, or reactive substances. Hazard communication is designed to inform employers and employees alike of these hazards and the protective measures needed to prevent injury or even death.
Chemicals or hazardous substances can enter the body in four ways:
Inhalation – Chemicals enter the body through the nose or mouth and travel to the lungs. Some chemicals are then trapped in the lungs. Others can pass into the blood stream causing damage to additional vital organs.
Ingestion – Occurs when chemicals or substances are swallowed and end up in the stomach. From there, many chemicals will enter the small intestine and then enter the bloodstream.
Absorption – This can occur when chemicals contact the skin. Once again these chemicals can enter the bloodstream and travel throughout the body. Absorption can also easily occur when chemicals splash into the eyes.
Injection – Chemicals are injected when they pass through a cut, wound, or puncture of the skin. Injection can also occur when gases under high pressure cut skin tissue, forcing chemicals into the body.
Due to the many ways a chemical can enter the body, the Hazard Communication Standard centers on “Your Right to Know”. So what do you have the right to know and how is it accomplished?
All employees have the right to know what types of chemicals they are working with and how to protect themselves from possible harmful effects. The standard specifically lists what employers must have in place to communicate the hazards of the chemicals present and the protective measures to prevent exposure to these chemicals. This list includes:
- A hazard communication program must be written and implemented. This written program will document how hazard communication was implemented and effectively communicated to employees.
- All containers must be labeled. Regardless of amount or time used, all containers used to store or transfer chemicals must be equipped with legible labels.
- Employees must be provided with access to Material Safety Data Sheets (MSDS).
- Training must be provided for all employees potentially exposed to chemicals. Hazard Communication training must include:
- – An overview of the Hazard Communication Standard
- – Chemicals that are present in the workplace
- – All health and physical effects of these chemicals
- – How to prevent or control exposure through safe work practices and personal protective equipment
- – Emergency procedures in the event of accidental exposure
- – The location of the written HazCom program
- – How to properly read product labels and MSDS documents
In addition to the above items, employers must have a list of all chemicals that are used by employees. This list will then be used to create an MSDS binder that must be readily available to all employees. This chemical inventory as well as the MSDS binder and employee training must be updated each time a new chemical is introduced to the workplace.
Chemicals are all around us and can cause serious injury or even death if not used properly. The time to know and understand the hazards associated with these chemicals is prior to the use. Only an informed and properly trained employee can be a safe employee!