Labeling Hazardous Chemicals Handout
Airborne particulates are a common respiratory hazard on projects. But what about volatile chemicals; how are workers preventing accidental exposure to these hazards? An effective jobsite hazard communication program can help prevent workers’ exposure to volatile airborne chemicals.
Jobsite hazard communication
OSHA requires every jobsite to inform its workers about classified chemical hazards that are on the project. Project managers and supervisors should refer to OSHA’s Section 1910.1200, Hazard Communication standard, for guidance about properly informing workers about chemical hazards. OSHA’s construction industry standards don’t have separate hazard communication requirements. Instead, 1910.134(d)(l)(iii) of OSHA’s Respiratory Protection standard and 1926.59 directs contractors to use 1910.1200 for guidance about hazard communication (HazCom) requirements.
If contractors are on a multi-employer project, each company must follow OSHA’s hazard communication requirements. Here are three primary duties that every contractor has towards other contractors on the same jobsite where hazardous chemicals are present:
- Provide access to safety data sheets for chemicals that workers have exposure to,
- Establish preventive measures that workers can take to avoid exposure to these chemicals, and
- Share information about the labeling system workers should use with all containers on the project.
These duties are separate from each company’s personal obligation to protect its workers, which include:
- Make sure labels on containers are in place and not defaced;
- Maintain safety data sheets, and make them accessible to workers; and
- Train and provide information to employees about avoiding exposure to chemicals and how to stay safe.
OSHA defines a hazardous chemical as “any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.” Workers should review safety data sheets for chemicals at their project to determine how the manufacturer’s classification could affect their safety.
The United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) isn’t an OSHA standard; instead, it’s an internationally agreed-upon standard that the United Nations manage. The GHS standard replaces the assortment of chemical classification and labeling requirements worldwide into a universal system. Any chemicals received at the project must have labels that are HazCom-GHS compliant.
Are containers adequately labeled?
Chemical manufacturers and importers must use HazCom-GHS requirements to label hazardous chemical containers in the U.S. Understanding how to read a compliant label isn’t too difficult. Labels will include:
- A harmonized signal word,
- Pictogram,
- Hazard statements, and
- Precautionary statements.
Use signal words to alert workers about the severity of hazards. Hazard statements describe the nature of chemical hazards. Contractors should use precautionary statements to mitigate workers’ exposure to chemicals. The GHS includes nine pictograms; however, OSHA has only adopted eight of them. Under the Hazard Communication standard, the environmental pictogram isn’t mandatory; it identifies a chemical that is aquatic toxicity. If the jobsite is near a waterway, it may be necessary to use it.
Discuss how to label containers at the jobsite’s next safety meetings properly. Ensure workers understand what labels and resources are available to them onsite. The project should consider using special labels for outdoor use. Inclement weather, or the sun, can cause labels to wear, fade, or become damaged. Using outdoor-rated labels can minimize unnecessary rework to relabel containers.
Use safety data sheets to supplement the jobsite hazard analysis
Safety data sheets (SDS) have a 16-section format, and supervisors should use them to supplement their workers’ safety plans.
Here are some examples of how to do this:
- Note the chemical and product names on the SDS. They will be different from each other. Product names might be more recognizable to workers, but the chemical name will help the jobsite identify specific chemical hazards to which workers may have exposure. For instance, workers might not realize that Acetaminophen is also called Tylenol®.
- Use health hazard information to identify how workers could have exposure to a particular chemical. For example, a chemical might harm a worker’s body if it contacts their eyes or workers inhale it. Jobsites can use this information to implement controls on the jobsite that will protect workers.
- The first-aid section in the SDS will describe what a contractor should do if an employee has exposure to the chemical. Jobsites can use this information to ensure an offsite medical facility or first-aid supplies are readily available if a worker has exposure to the chemical.
- Use PPE and housekeeping information to support other control measures used to protect workers. PPE should be a jobsite’s last line of defense to protect workers from hazards. Proper housekeeping contributes to a safer working environment.
- Using proper storage requirements will help contractors safely store chemicals at their projects so workers can avoid accidental exposure to them.
Store SDSs in a binder or make them accessible to workers online. Supervisors should remember that workers need to have access to SDSs. If the jobsite uses an online database or service, workers will need access to it. Using an online SDS database may not be possible for specific jobsites if the project is in a remote area where internet access isn’t available or reliable. In these cases, use a jobsite binder to manage the SDSs, and it should be kept in a common area for all workers to access them easily.
Hazardous communication training essentials
The most straightforward part of theHazard Communication standard to understand is its training requirement. Jobsites must train their workers about the hazards of chemicals used or stored in their work area. Perform this training during new-hire orientation and whenever workers use a new chemical on to the job. Training must include specific topics like protection, prevention, mitigation, sources of exposure, and first aid. SDSs should be used as guidance when developing HazCom training material.
Make HazCom training specific and relevant to the workplace. For instance, workers often leave aerosol cans in their pick-up trucks. When the air temperature rises inside the truck, the contents in the aerosol can expand rapidly and cause it to rupture. Train workers about this hazard and safely store the aerosol can inside a flammable storage cabinet or safety can — train workers on how to review the chemical’s SDS for specific storage recommendations from the manufacturer.
