Summer
Reading – A
Classic in Worker Safety
Barbara Kanegsberg, SQRC
You probably had to read the “Bill of Rights” somewhere in your
interaction with the educational system. If you work with chemicals, do you
know what you ought to read or at least glance at 29CFR 1910.1200 “Hazard
Communication”? While not as riveting as the latest “Harry Potter,” reading
29CFR 1910.1200 is actually not at all painful, and it’s very instructive.
Hopefully, your employer provides a Hazard Communication program. While training
programs are important, to be truly educated, it’s useful to get back
to the source of requirements: for programs, for labeling, for MSDS.
Do a web search on hazard communications, and you will be presented with
zillions of training programs (ok, maybe not zillions – but many).
To progress beyond training to education, the legendary 29 CFR 1910.1200
is available on-line
on the OSHA website. We have provided a link for your convenience.
The rule deals with chemical hazards and covers:
• Evaluating of hazards of chemicals, produced or imported
• Transmitting information about potential chemical hazards to employers and employees
Transmitting means comprehensive hazard communication programs. Such
programs include:
• Container labeling
• Other types of warning
• Material Safety Data Sheets (MSDS)
• Employee training
• Significant updates
It is also important to be aware of what the rule does NOT cover. A few
examples include:
• Hazardous waste
• Food and alcohol
• Drugs (eg. items covered by the FDA)
• Ionizing and non-ionizing radiation
• Biological hazards
• Hazard communication in languages other than English
Mixtures and blends
The term “chemical” means an element, a chemical molecule, or
a mixture. There is an important proviso that if a mixture has
not been tested as a whole to determine health hazards, it is assumed to
present the same
health
hazards as components that are
• carcinogens at levels 0.1% or over (by weight or volume
• other components at 1% or over (by weight or volume)
There are some potential “gotchas” for you as an employee. Typically,
the health hazards of blends are not evaluated, in part for economic reasons.
However, there can be synergistic effects, where the performance, materials
compatibility, and/or toxicity of blends are non-additive (Ref. B. Kanegsberg, “TANSTAAFL”*).
Therefore, if you begin to work with any new blend on a regular basis, you
should handle it with reasonable caution. If the blend appears to show enhanced
performance, you might be particularly observant of chemical handling practices.
In addition, it may not be valid to assume that there is no problem with non-carcinogens
present at concentrations less than 1%, particularly for complex formulations.
Those fractions of a percent can add up if large numbers of chemicals are blended.
You don’t have to panic; just be prudent.
For another thing, “components” listed in an MSDS are taken to mean health hazards. A chemical may not present a hazard to workers, but it may interfere with product performance. This could lead to noise and/or stress hazards from superiors or customers.
Continuing education
In a recent issue of “Green Files,” we explained why allowable
levels of chemicals in air can differ in the workplace
and in the community. One important difference between worker safety and
community
exposure is
that if you work with chemicals, you have to get educated.
I think that if you work with chemicals, 29 CFR 1910.1200
is your special Bill of Rights. It’s worth a bit of time to read it and to understand the
implications for your facility. Find and dust off the official Hazard Communications
book. Maybe it’s time for a refresher course, maybe
even an update.
Disclaimer: The preceding is my best effort at summarizing
and discussing 29 CFR 1910.1200. I am a chemist,
not a lawyer.
References:
Web link to 29 CFR 1910.1900
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099
B. Kanegsberg, ‘Cal/OSHA PELs, Community Standards for Worker Exposure
Limits?”, The Green Files, Vol. 2, issue 1, 2007.
B. Kanegsberg, “TANSTAAFL,” Clean Source,
Vol. IV, no. 2, June, 2007.
*(‘There Ain’t No Such Thing as a Free Lunch’)