Page 34 - Occupational Health & Safety, January/February 2020

CHEMICAL SAFETY/SDS
How to Conquer Four HazCom Labeling Conundrums
Why is HazCom such a sand trap for compliance citations?
BY JOANN MRGICH
Whether you’re in an office, on a con- struction site, manufacturing products or managing a warehouse, chances are high there are potentially hazardous chemicals in your workplace. Most workplace hazard- ous chemicals fall under the regulation of the Occu- pational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS). Putting OSHA HCS into practice (HazCom) is critical for compliance and worker safety.
Yet year after year, HazCom violations are at the top of OSHA’s “Top Ten Most Frequently Cited Stan- dards” list online, coming in at number two for the 2019 fiscal year. In fact, if you do a quick Google search of the top ten lists for OSHA citations go- ing back to 2002, you’ll see that HazCom violations haven’t dipped below the number three spot in all that time. So why is HazCom such a sand trap for compli- ance citations?
Well, in general, what OSHA requires for compli- ance is determined by more than the mere presence of chemicals. The quantities, frequency of use and if or where the chemicals may be shipped all help de- termine which standards apply. Certainly, the 2016 culmination of OSHA’s transition to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is also a contributing factor.
This article answers four of the most common, yet most confusing, questions about HazCom labeling when it comes to getting and staying compliant.
How Do I Know Which Workplace
Chemicals Need HazCom Labels?
What is considered a hazardous chemical? OSHA standard 1900.1200 (Hazard Communication, Tox- ic and Hazardous Substances) defines hazardous chemicals as “any chemical which is classified as a physical hazard or a health hazard, a simple asphyxi- ant, combustible dust, pyrophoric gas, or hazard not otherwise classified.”
OSHA standard 1910.119, Appendix A is a helpful list of highly hazardous chemicals which would cer- tainly require HazCom labeling. This list also includes threshold quantities (i.e. the amount above which presents a potential for a catastrophic event). Unfor- tunately, it is not a comprehensive list of all potentially hazardous chemicals.
The good news is that any new hazardous chemi- cals coming into your facility should already come with labels that are fully GHS-compliant. All you have to do is maintain those labels and ensure they remain both intact and legible. However, if you are transfer-
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ring those chemicals to other (secondary) containers, then you would need to create additional GHS-com- pliant labels for the secondary containers.
However, this is where deciding which chemicals need HazCom labels gets murkier because there are some secondary container exclusions. If you prefer to stay in the clear calm waters of certainty, remem- ber the safest option is to simply label all secondary chemical containers with full GHS labels, regardless.
Portable containers. Containers intended for im- mediate use by one (and only one) employee are ex- cluded from HazCom labeling. Consider this scenario: each morning an employee pours one cup of bleach into a bucket, dilutes it with water and proceeds to clean the facilities with the mixture. When the em- ployee is done, the remaining mixture is disposed of. The bucket containing the bleach mix does not require a HazCom label while the employee is cleaning.
If an employee were to create the same cleaning solution, yet wish to leave it behind for other workers to use throughout the day, a HazCom label would be required. Similarly, if the employee wished to store the mixture for future use, the secondary container for storing the mix would require a HazCom label.
Consumer use. Consumer chemicals used in typi- cal consumer fashion would typically use them do not require HazCom labeling. An ammonia-based house- hold cleaning spray you could buy at the grocery store is a good example of a consumer chemical. Keeping it on hand in the break room for employees to clean up after themselves would not require HazCom labeling. In this scenario the chemical is being used in the same way the average consumer would use it.
Substances covered under other regulations.
HazCom labeling does not apply to substances that are regulated by other government agencies or stat- utes. For example: hazardous waste (RCRA); pesti-