Words: Lori Lovely
Hazard communication, also known as HazCom, is the Occupational Safety and Health Administration (OSHA)’s mandated set of processes and procedures to share information about the identities and dangers of chemical handling, shipping, and exposure. Under the rules, manufacturers and importers must evaluate the hazards of the chemicals they deal with and prepare appropriate labels and safety data sheets to convey that information to their customers.
It is also the responsibility of every employer who has hazardous chemicals in the workplace to maintain labels and safety data sheets, train employees to handle those chemicals safely, and implement a written hazard communication program that outlines how they will comply with the HazCom Standards.
“Hazard Communication is a secondary thought of safety,” reflects Sean Loftis, Operations Manager and Safety Director for Carolina Masonry. “It is probably one of the most overlooked items for the masonry industry that we just don’t think about. I think, as masons, we take [it] for granted, because [the items] are with us every single day. We don’t really prepare.” He estimates that 99% of the time masons are not exposed to chemicals, as “we don’t deal with a lot of caustic materials.”
Some of the specific hazards that mason contractors come into contact with on the jobsite include wet mortar and concrete. “Those are the two biggies,” affirms Zach Everett, Corporate Safety Director for masonry companies Brazos Masonry Inc., and Legacy Masonry, LLC.
If a material is in a solid form, like brick or cast stone, Everett says “you don’t really have to do anything with it, because you’re not going to inhale it. You’re not going to ingest it because it’s in solid form. But, if we start cutting on it, and we make it airborne, then it becomes a chemical exposure at that point.”
But the “big thing” of the last few years, Everett states, is silica. “Concrete block, concrete, brick, stone, cast stone – when you cut it, it becomes airborne. You can breathe it.” There are different levels of silica concentrations in the various materials, but all require workers to use protection … and a label to communicate the hazard.
Wet materials can also pose a hazard. For example, when mortar is mixed, it’s in a wet form, and if you get it on your skin or in your eyes, it can cause caustic burns. As Loftis points out, “even our mortar has Portland in it,” which can cause chemical burns just like concrete can.
Treatment is “basic chemistry,” according to Loftis, who explains that “a little bit of vinegar” can neutralize concrete burns “almost instantly.” But employees must first be able to correctly identify the chemical in order to effectively address the exposure.
Time is of the essence when a worker is potentially exposed to a hazardous material, which makes OSHA’s Hazard Communication Standard especially crucial to ensuring jobsite safety. Aligned with the Globally Harmonized System (or GHS), Hazcom is a U.N. global hazard communication system which standardizes the way hazardous chemical are classified, and then communicated, via safety data sheets and labels. This regulation standardizes hazard communication practices and procedures in workplaces all over the world.
The process begins with labels. One of the recent changes to the HazCom Standard requires that chemical manufacturers and importers provide a label which includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must include recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical, or from improper storage or handling.
Mislabeling, missing labels, or not paying attention to the labels are some of the most pressing issues, Loftis says, because “then nobody knows what [it is].” For example, while red containers are typically used for gasoline, yellow for diesel, and blue for kerosene, not all employees will always adhere to the norm. As a result, the name of the chemical should be written on the container. “Or,” says Loftis as an example, “if it’s mixed gas in the 1½ gallon container, you need to write ‘mixed gas’ on there.” He explains that commonly on jobsites, employees can and do assume the container’s contents by its smaller size, and could burn up a saw as a result when there’s no oil in the gas.
Additionally, “a lot of people transfer chemicals into smaller containers, and then they’re not labelled,” Everett agrees. Oftentimes, companies will order a fifty-five-gallon drum of a chemical, but then the employees don’t want to or can’t transport it easily to where it is needed on the jobsite, so they will transfer the contents into a smaller container- that doesn’t always get the proper label. Says Everett, “one thing to watch there is either you have to label it, or – and OSHA does allow this – it has to stay in that individual’s personal possession, start-to-finish. He can’t take that container and lay it down and walk off from it, because someone else [may] come along and says, ‘Oh, look at this, Gatorade! I’m gonna’ drink it.’”
Due to the serious health and safety risks posed by a lack of awareness and understanding of a chemical’s risk of exposure, Everett further explains, “whoever produces the chemical is supposed to also produce this Safety Data Sheet.” Another of the recent changes to the Hazcom Standard, the 16-section format for the SDS is designed to keep employees safer. “The only thing that’s not required to put in there is patent-sensitive information, proprietary information,” Everett continues, adding, “every time it changes hands, this information should be passed along, so that it can also get to the next person and the end user.” Loftis, too, points out that Carolina Masonry keeps a properly labeled SDS on each chemical on the jobsite in order to “constantly communicate those hazards to the employees.”
Thorough training on the new labeling system, SDS format, and various chemicals hazards is a further change the HazCom Standard. An employee must be informed of the hazards related to any chemical on the jobsite, as well as how to personal protection practices, any potential long-term illnesses that could result from exposure, and what if acutely exposed, Everett elaborates. “Do they immediately go flush their eyes? Do you induce vomiting? [Or] Do you call 911 immediately?” Considering “each chemical is going have a little different layout, as far as effects, protection from and treatment of exposure,” it’s crucial to know what to do.
“We have to communicate the hazards as it relates to chemicals,” Everett continues. That encompasses the initial training, as well as having proper labels and the SDS onsite. “If we’re working on a jobsite, or if it’s in your shop, you have to have that information. It can be an electronic version. It doesn’t have to be a hard copy, but it has to be readily accessible.”
Documentation provides proof of training, and keeps a company in compliance with the OSHA rules. However, the training itself is something Loftis in particular finds a bit dull. “It’s all information,” he explains. “It’s all about either watching a slideshow or some type of presentation, Powerpoint, or a video, and going over the main parts of the SDS Sheet.”
As most in the construction industry are more “hands on” people who prefer to work out problems on their own, he believes classroom instruction is not always the best way to convey information. “Everybody has the ability to learn,” he states, but “you’ve just got to find what works. If I gave [one of my best guys] the manuals, he’d look at me and go, ‘I’m not doing that. What do you want me to do? Show me.’”
Instead, Loftis believes his crew would be more engaged if he could incorporate different educational experiences like crossword puzzles, word searches, and hands-on activities. “If you have a cleaning chemical like NMD80, that’s a mild caustic. Have the guys go in there, read it, find what they have to have for PPE, and then maybe go get those items and put them on.” Loftis concludes that “it’s about knowing where those items are and how to find them, so that in an emergency situation, how can you find it, how can you treat that person, whether it’s an external burn or an internal swallowing, in the eyes … how to flush something out…”
OSHA does allow various training techniques, including audiovisuals and interactive videos, as long as the information is specific to the kinds of hazards found in the workplace and the particular protective equipment, control measures, and procedures that are necessary.
In order to be effective, training needs to be both ongoing yet engaging. “You have to have buy-in from every employee,” Loftis states. “You have to find some value in it for your guys, and convince them to have some ownership in it.” To encourage this investment, Loftis holds a team huddle every morning, which allows him to gather the crew and learn what each member has planned for the day. At that time, he can also conduct a quick job hazard analysis to alert his crew to the potential hazards they face. “There’s multiple things that you’ve got to be aware of and the first aid procedures are probably the number one thing that you should be aware of on a daily basis on any chemical that you come in contact with,” he states.
Consistency is an important aspect of training, as is follow-up. After evaluating his crew’s knowledge, Loftis repeats training every three months. “You have to go back over it with the people and see where they’re at, see what they’re understanding. So much of safety isn’t about the initial training, even though the initial training is highly important. It’s about being consistent with the guys, and when you see something that’s not right, that’s not correct, taking the time and going over with them and training and education.”
Communication and training should be emphasized every time a new chemical is introduced. “Every new hire that we bring on board, we train in Hazcom,” Everett says. “But you’re going to have specific things that come up on the job that you didn’t train for because you didn’t foresee that chemical.” For example, washdown detergents are used to clean dry mortar off masonry walls. Masons “use an acid compound. It is a weak acid, [but] you can get burns from it as well, and so that’s something that you will have to do some additional training and awareness on.”
Throughout the industry, many professionals have been left frustrated and confused by the changes to the Hazcom Standard. In some instances, Everett complains, suppliers are still providing old information. “Used to be, it was a Material Safety Data Sheet rather than an SDS. That may be splitting hairs, but it is still a rule that the MSDS’s should have been done away with years ago. We still see them come through, which basically means they are not staying ahead on safety,” he explains.
Similarly, the U.S. adopted the GHS in an effort to standardize a system of pictograms that would reduce the miscommunication of crucial Hazcom information between different countries. “Since now we trade internationally every day,” Everett says, the GHS offers “better ways to communicate the hazard even though you don’t speak the language.” While some companies are slow to adopt the practice, he remains hopeful that these changes will have their intended impact.
OSHA estimates that 32 million workers are potentially exposed to one or more chemical hazards in the workplace every year. With 575,000 existing chemical products and hundreds of new ones being introduced annually, it’s critical to remain current on HazCom regulations, which can be found at https://www.osha.gov/dsg/hazcom/.