What’s Wrong with this Picture?: Hazcom - Transferring Liquids Answers

1) Not wearing proper PPE. Based on the NFPA numbers, the employee should be wearing personal protective equipment including gloves, goggles (and possibly a face shield), and a splash apron.

Related information:

• 1910.132 General Requirements
• 1910.138 Hand Protection
• 1910.133 Eye and Face Protection
• ez Explanations®: Personal Protective Equipment
• ez Explanations®: Chemical Protection
• Safety Training (OSHA): Personal Protective Equipment: Hand Protection
• Safety Training (OSHA): Personal Protective Equipment: Eye and Face Protection

2) Stable working platform. The stool does not make a stable surface for handling chemicals. The employee should use a stable working surface.

• OSH Act Section 5(a)(1): General Duty Clause
• As a “best practice,” employees should use a stable working surface

3) The label on a stored container is smeared. A container on the shelf (behind the gloves) has a dirty label. If the hazard information on the label is not legible, the label should be replaced.

Related information:

• ez Explanations®: Hazard Communication
• 1910.1200(f)(9) Hazard communication labels must be legible
• Audit Programs (OSHA & EPA) Checklists: Chemical Storage Area - Hazard Communication: Labeling
• OSHA Informational Publications: Hazard Communication Guidelines OSHA #3111

4) Fire Protection. Flammable or combustible liquids must be transferred in approved areas with spill controls and ignition controls, including grounding.

• ez Explanations®: Flammable and combustible liquids
• 1910.106(e)(2)(iii) Separation and protection
• 1910.106(e)(2)(iv) Handling liquids at point of final use
• 1910.106(e)(6)(i) Sources of ignition - General
• 1910.106(e)(6)(ii) Grounding

5) Storage of materials. Some stored items on the shelves stick out into the aisle, or appear likely to fall. They should be secured or moved to a lower shelf.

Related information:

• ez Explanations®: Housekeeping
• ez Explanations®: Materials Handling and Storing
• 1910.22 Housekeeping
• 1910.176 Handling materials-general

6) Care and use of PPE. The goggles and gloves on the shelves are not stored properly, and they could become contaminated.

• ez Explanations®: Personal Protective Equipment
• 1910.132(e) Defective or damaged personal protective equipment must not be used.
• 1910.132(f)(1)(v) Employees must be trained in the proper care and maintenance of PPE.

7) Discussion Item: Material Safety Data Sheets. The employee does not need to have an MSDS on-hand. However, he should know where to find it.

• ez Explanations®: Hazard Communication
• 1910.1200(e) Hazard Communication: Written Hazard Communication Program
• Safety Training (OSHA): Hazard Communication: General

8) Discussion Item: Eye Wash Stations. Although an eyewash station is not visible in the photograph, a station is located within 10 seconds of travel time from the hazard.

• ez Explanations®: Emergency Eyewashes/showers
• 1910.151(c) Medical Services and First Aid

If you see other things wrong in these pictures (please provide exercise title in comments) or have ideas for new pictures, please Contact Us.