Industrial Hygiene in Construction

If you live in the United States, you have less than one month to train your employees on the new Hazard Communication standard (1910.1200(h) & 1926.59), which should include information about the new types of Safety Data Sheets (formerly known as MSDS) and the adaptation with the Global Harmonization System (GHS). December 1, 2013 is the enforcement start date for OSHA. Don’t make this complicated, it is straightforward. Here’s what you should do:

• Train employees in hazard communication (simply: so they know the hazards they are working with)
• Document your training (in case of an OSHA inspection)
• Show them a sample Safety Data Sheet (SDS), compared with the old MSDS
  • Explain the new standard hazard phrasing & pictograms
  • Explain how to review a SDS
  • Remind them about container labeling
• Explain that the new SDS will not be available immediately, but will roll-out over a few years (or more)

*Please note the “Beer” hazard warning on the right is not GHS compliant. 

For Help:

• Oregon OSHA (OR-OSHA has a new fact sheet on what you need to do for compliance.
• Here’s a link to a sample hazard communication plan (in Word!). More help here.
• AND, a free training guide for employers, another here. Shout-out to Siobhan & Dan at SAIF for this.
• Also, some Susan Harwood free training materials here (spanish too!).

Reviewing a material safety data sheet (MSDS), or soon to be called a SDS (safety data sheet), can be a useful skill. Most times the product is straightforward and gives you what you need. However, there are somethings to watch for and areas to focus to make your reviewing skills better.

To start,  make sure you have the right SDS. Match the product with the form. If is is not exactly right, find the right one. It must list the model/product name & manufacturer.

Below are some suggestions:

• What is the date of the SDS?
  • is it the most recent?
  • when was it last updated?
• Look at section 2/3 (Hazardous components) VERY carefully.
  • google the CAS# and find the name (they sometimes hide the true-name)
  • look at the % of each component
  • what is the listed exposure limit? Is it correct? What about other recommended limits?
  • remember the hazard is only listed in this area if it is greater than 1% of the total
• Look through each section mindful of how you will be using the product.
  • for example: if you are going to be burning the product, usually the SDS will not address these types of concerns/exposures
  • what are the required PPE during “regular use”
  • what happens if you use this product in a confined area?
  • does the manufacturer recommend air monitoring? when?
• Familiarize yourself with the emergency procedures
  • what if it spills?
  • disposal?
  • what can cause exposure? inhalation? skin?
• Look at the other sections with a inquisitive eye
  • do they list other chemicals, which are NOT included in the product section? why?
  • do they mention Proposition 65?
• Finally,
  • post/make available a copy wherever it’s needed
  • make sure you know the product

It is a mixed-bag when it comes to the quality of SDS from a manufacturer. Some of them will work with you, others are a total-pain. Remember it is YOUR RIGHT to know about the products you use. If you don’t feel comfortable with the information they’ve given you, call them. OR, go find another product.

You may have seen a product label which states that, “this product is known to cause cancer”…if used in California. (ha)

Proposition 65 is essentially a labeling rule. in 1986, California made a rule mandating anyone selling to California to label the product… if it had a serious health risk. This rule was above and beyond the OSHA reporting limit of 1%, like on a MSDS (henceforth called SDS, BTW).

The rule is actually good. It makes manufacturers tell you if there is anything hazardous in their product, or if they used anything hazardous when they made the product. (Side: If you haven’t heard, some manufacturers like to hide their ingredients, some say for proprietary reasons. Here’s an example)

More information about the rules is here. There is controversy over it’s usefulness (see here), but in this day in age, I believe you should be made aware of the information.

What usually happens is you find a SDS with no information about the product. Then, as you investigate, you find a “Proposition 65 warning”, indicating something about the product which, “may cause cancer”. So you ask, why does this happen? (more FAQ here) Well, the manufacturer used, or contains, something in their product that is hazardous. It can be a nice trail leading to chemicals which to sample for, or investigate.

The new global harmonization system (GHS) is officially adopted by OSHA. Each state run program is rolling out their acceptance of the new changes. Where I live, we have until December 2013 to train employees in this new type of hazard communication.

Honestly, I’m NOT too EXCITED about it. But, I’m trying to have a good attitude. Below are some good things which may occur:

• Raise the level of awareness of hazardous materials & their toxicity
• Train employees (hopefully, retrain) on how to handle chemicals
• More training = less citations. (?) OSHA’s top ten citations include #3 – hazard communication. Maybe people will actually do the training?! (my guess is that there will be more citations)
• Consistent information worldwide.  All UN countries should have the same format. (this might take years)
• Proprietary information will be more visible on the SDS. In the new rules, manufacturers are required to list the % of their proprietary ingredients.
• Pictograms! They’re so cool. My favorite is the exploding person.
• Maybe this is my favorite?!: Manufacturers will have to look again at their products and classify them according to the physical & health criteria. Nowadays with more relevant information from worldwide occupational exposure limits, it might help make employers aware of the hazards.
  • This might help OSHA enforce newer exposure limits (other than the 1978 AGCIH TLVs).

How do you plan on training your employees? If you need help, contact me here.

The new standard for material safety data sheets (MSDS) which incorporate the global harmonization system (GHS) rules are coming.

Federal OSHA has approved the rules, and in our state, Oregon, they have been proposed, with an adoption to take place in December 2013.

It’s time to panic!… No. Not really.

Most employers will have until December of 2013 to implement the rules. OSHA will be publishing additional (and hopefully, helpful) information on what to do. For most employers it will mean you need to do a few major things:

• Train your employees on the new rules
• Reclassify (rename) the hazards, mainly the flammable ones, which have changed the most.

If you really need help with this, or feel like you can’t wait until OSHA publishes more information, email or find me here and we can discuss.

After performing an industrial hygiene survey (air monitoring), have you considered when you should resample? Here are some considerations that might help you in determining when.

• Are there specific rules that state when you must resample? For example, the construction lead standard (1926.62) states that you must resample yearly (or actually, that you can only use relevant results for one year).
• Has the process changedsince the last time you sampled? This one is hard to determine. Lot of things can change air monitoring results, here’s a “starter list” of things that can change a process.
  • Different employee?
  • Time of year? Summer versus winter? (closed up/open and humidity)
  • Is a new tool in place?
  • Has the ventilation changed?
  • Have new controls been put in place? (administrative, systems operations)
• Has the product changed? Check the safety data sheet (aka MSDS).
• Are more (or less) employees exposed to this hazard? This might change some assumptions you have made about your risk.?

If you have air sampling performed, make sure you have a written report of your findings. Laboratory results without an explanation of how they sampled, where, # of employees, process description, PPE used, safety data sheets, etc….is worthless. You may remember is well enough, but OSHA will have a hard time believing that it is a similar exposure the next time you do the “exact same thing”.

Having this report and sharing it with the employees will fulfill (part of) the hazard communication standard requirement to employees.

Here are the questions I’ve been hearing in regards to the MSDS changes with respect to the new GHS (globally harmonized system of classification & labeling of chemicals)…

I am going to keep the answers REALLY short so you’ll actually read it. Keep in mind, I’m leaving some information out.

• What do I need to do?

As an employer you need to train your employees on how the new MSDS will look.

• How soon do I need to comply?

For contractors, you’ll need to train your employees by Dec 1, 2013.

• What is it?

It’s a universal (global) method to make MSDS have more information and make them all look the same.

• Why are they doing this?

Well, MSDS’s are very good. They’re supposed to be written with the same 15 sections with no-blanks. But, some people don’t do a very good job. Or, in some cases, do an really good job of hiding harmful chemicals, but, legally cover themselves.

• Where can I get help? Right now?!

There will be FREE training (you may have to search for it though) and more information being published. This is a topic you can learn and present to your employees. Since the deadline is a year and 9 months away, you have some time.

• Ok, do you have any places for additional information?