Words: Steve Hansen
Effective communication is a key factor in success in so many areas of life and business. Hazard communication is no different, but it may not be obvious how to establish an effective Hazard Communication System in your company.
The Hazard Communication System (HCS) was developed and is mandated by OSHA, the Occupational Safety and Health Administration within the U.S. Department of Labor. The HCS mandates that chemical manufacturers and importers create labels and safety data sheets (SDS) for all users of their products. It also requires employers to make that information available to all employees and to train exposed workers in the safe use of all chemicals.
According to Bruce MacKinnon, Regional Health and Safety Manager for AGF Access Group, Inc., hazcom procedures are sometimes neglected in his experience. Each chemical comes with an SDS that details proper use and safety measures for each chemical as determined by the manufacturer. As always, it’s crucial to review the PPE—personal protective equipment—guidelines on the safety data sheet.
MacKinnon says this step is most frequently skipped. Employees need to know what chemicals they’re working with and the risks those chemicals pose to human health, along with the safety measures, which can vary substantially among different job site chemicals.
Emergency first-aid procedures are not intuitive and are specific to each chemical, and the SDS will provide specific instructions for each chemical. Many chemicals are caustic and quite harmful with skin contact, and even more harmful when ingested. For example, suppose a container under pressure ruptures and a nearby employee ingests a chemical.
“Most people’s natural reaction would want to be to try and vomit that material back up. But sometimes that’s more dangerous than immediately seeking medical attention,” Mackinnon adds, “so it’s important to understand those aspects of the chemicals” as detailed on the SDS.
In addition to reading and knowing the SDS for all chemicals in use, MacKinnon advises companies to keep a master list. “It’s best practice to keep a master list of all your chemicals. Make sure that the master list is updated annually,” he states. An updated master list must be based on the current SDS, which is a common problem. “I bet you there are still companies out there that have SDS that are 25 years old that need to be updated,” he adds.
Some companies end up with outdated or nonexistent hazcom because no one in the company “owns” hazcom, he noted. All companies should appoint at least one employee who has responsibility for hazcom and the master list. Those employees should go through the master list at least yearly, updating the SDS for all chemicals in use, including new chemicals added to the mix since the last yearly review.
All new chemicals should be introduced to employees before using, MacKinnon says, as required by the HCS, but often are not. “I think one of the biggest failings is when new materials or new chemicals are introduced to a company, and nobody is taking the time to do a quick overview or toolbox talk about that chemical. They’re kind of leaving it up to the employees to figure it out on their own.” New chemicals may have different ventilation or storage requirements, but employees won’t know that information if they don’t read the SDS or receive training on the new chemicals.
Disposal of chemicals
Disposal of chemicals is another component of effective hazcom, MacKinnon noted, and it’s another common problem. Partial containers, in particular, present a challenge over time as the company buys for the project after project and ends up with remnants that are unused or forgotten. Most companies would rather buy new products and have extra than run out in the middle of a project, so remnants fill the storage area and, again, without one or two employees who are responsible for those chemicals, they build up year after year. This is another component that MacKinnon sees often year after year. For example, cans of aerosol products commonly build up and present a challenge.
Stored chemicals should be separated from different chemicals as much as possible. Companies can, for example, remove the spray nozzle from aerosol cans and place them all in open-top drums to isolate them. Other materials, especially flammable materials, should be treated the same way or placed in a dedicated storage closet so if there were a fire, it can’t spread easily.
In addition, most chemicals have a useful life span, and those partial containers will expire and require disposal. MacKinnon suggests clearly labeling all chemical products in storage so they can be used when appropriate. Labeling expired chemicals and usable chemicals also aids storage organization. “I try to separate my use of my usable chemicals from the chemicals that I’m going to dispose of,” MacKinnon states. For the chemicals that have expired, companies should “reach out to a local disposal company to get some assistance if the company doesn’t have an internal disposal program,” he continues.
Seasonal storage and handling of chemicals can vary, MacKinnon notes. Having cylinders on a job site in Texas in summer can be dangerous, he said, due to extreme heat, while a jobsite in winter is less dangerous. Keeping flammable chemicals away from welding areas and other areas with combustion, and keeping all chemicals away from eating areas is necessary, also. Having an employee in charge of chemicals and storage, he noted, can help the company manage these types of risks. That employee would ideally also be in charge of purchasing chemicals, he adds.
When purchasing chemicals, MacKinnon suggests talking with suppliers about less-hazardous alternatives to commonly used chemicals. Xylene, for example, is flammable and harmful to human health and is one of the top 30 most-used chemicals in the U.S. If mineral spirits would also work for that job, the company has reduced the hazard with no penalty.
Silica products are another product that may have alternatives, he noted. Using crystalline silica requires the use of respirators and may require monitoring for silicosis, a condition that affects the lungs and makes breathing difficult. “If I can substitute a product that contains silica with a similar product that does not contain silica, I’m reducing the hazard,” he points out.
Daily safety plan
Creating a daily job safety plan is useful, MacKinnon said. Each morning, employees should review the work plan for the day. That plan should include a complete overview of chemicals needed for the day, where they’ll be stored and used onsite, who will be responsible for all chemicals, and what the emergency procedures are. Those emergency procedures should address spilling, fire, and injury to employees. It’s best to do this as a group so all employees hear the same information and coordinate their efforts.
Though often neglected in the construction industry, hazcom serves an invaluable purpose: health and safety. Companies can get their systems tuned up by following MacKinnon’s advice of appointing one or two employees to manage the effort with SDS, storage, disposal, and daily safety.