Hazard Communication Standard (HCS) - Background[LINK http://www.osha-slc.gov/OshStd_data/1910_1200.html]
The Community Right-To-Know reporting requirements builds on the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS). The hazardous chemicals defined by the HCS are the hazardous chemicals of Sections 311 and 312. Initially, the HCS applied only to manufacturers (designated by the Standard Industrial Classification (SIC) codes 20-39). However, in 1987, OSHA amended the regulation to incorporate all businesses, regardless of classification or size. As a result, any small business may now be subject to Community Right-To-Know reporting.
Under the Hazard Communication Standard (HCS), chemical manufacturers and importers must research the chemicals they produce and import. If a substance presents any of the physical and health hazards specified in the HCS, then the manufacturer or importer must communicate the hazards and cautions to their employees as well as to "downstream" employers who purchase the hazardous chemical. The goal behind the HCS is a safer workplace for workers, who when informed of the hazards they encounter on the job, can then help create a safe work environment.
Employer failure to comply with the Hazard Communication Standard causes the most OSHA citations. 50% of OSHA's citations relate to a failure to implement the Hazard Communication Standard.
MATERIAL SAFETY DATA SHEET:
One of the required tools of hazard communication is the Material Safety Data Sheet (MSDS). These documents provide many valuable details on the hazardous chemicals regulated by OSHA. Quite likely, facility owners and operators are already familiar with these useful documents. If not, they must become so. The MSDS contains health and safety information for facility owners and operators, and due to the relationship of Title III and the Hazard Communication Standard, having an MSDS indicates that the facility has a hazardous chemical which may require reporting under Sections 311 and 312.
Though the Hazard Communication Standard contains no formal list of chemicals, any of roughly 600,000 products may trigger the requirement. The responsibility for issuing current MSDSs rests with the chemical manufacturers, distributors and importers, but the chemical user must ensure proper and complete maintenance of MSDS files. This will help facility owners and operators to comply fully with SARA Title III.
The Material Safety (MSDS) serves as the indicator of hazardous chemicals at the facility. If the facility is not required to prepare or keep any MSDSs, then the facility has no hazardous chemicals, as defined by the Hazard Communication Standard, at the facility. The facility in this situation does not need to report. If, on the other hand, if the facility has MSDSs that were prepared at the facility because the chemicals were manufactured at the facility, or if the facility has MSDSs that were received as a result of incoming shipments of chemicals then the facility may need to report if reporting thresholds have been met. The threshold for all chemicals except those specifically listed as Extremely Hazardous Substances (EHS) [see EPA's free publication "List of Lists"] is 10,000 pounds, or approximately twenty 50 gallon barrels.
The data about a chemical or mixture of chemicals used at a facility is presented on a Material Safety Data Sheet, or MSDS. While there is not a specific format required by OSHA for MSDS sheets, many follow a common format. OSHA provides guidance for the subjects that must be covered, and having the specific information about EPCRA (SARA Title III) requirements is not covered at all by OSHA. There is no single mandatory form for the MSDS, so workers and the public will see many different types. What is consistent about MSDSs is the type of information included on each form.
OSHA developed the MSDS form as part of the Hazard Communication Standard, or Worker Right-To-Know regulation. OSHA wanted to make sure workers had one easy reference for most of the information on a hazardous substance. An MSDS tells:
What conditions would increase the hazard.
Keeping incompatible chemicals apart. If they are accidentally combined, they could ignite, react or explode. Factors that can cause chemical vapors to ignite include temperature, flashpoint, auto-ignition rate, Lower Explosion Limit (LEL) and the Upper Explosion Limit (UEL). The latter two factors concern the concentration of chemicals in the air. At concentrations below the LEL, the air/chemical mixture is to "lean" to ignite. At concentrations above the UEL, the air/chemical mixture is to "rich" to ignite. Anything in between the LEL and the UEL is ripe for ignition/explosion given an ignition source. The LEL and UEL is different for different chemicals and the MSDS for particular chemicals and mixtures should include these important factors.
How to handle the substance safely.
Special safety and handling precautions - avoid prolonged exposure to vapors, ventilate rooms well.
The MSDS information that the OSHA guidance requires first examines if the chemical is a single substance or a mixture. If it is a single substance, the chemical and common name(s) of the chemical are required.
If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself must be provided.
If the hazardous chemical is a mixture which has not been tested as a whole, the MSDS must provide:
But there are problems with MSDSs. Not all of the information is presented in the same way because there is not one specific format. There is often disagreement on the data on the different MSDSs. A review of several different MSDSs for the same chemical can show different information.
To better understand what a chemical is and what its properties are, try these Internet sites for MSDSs. These web-sites are maintained by universities and trade associations.
(LINK http://www.ilpi.com/msds/index.chtml )
There is nothing that requires a detailed accounting of all information on an MSDS. Some are "bare-bones," others have more information. There can be disagreement about what constitutes safe levels of exposure or the instructions for medical attention.
Congress chose to link SARA Title III's community Right-To-Know rules to the Hazard Communication Standard because both share a common goal of safety; Title III for the community and the HCS for the workplace. Understanding that connection is helpful. Although the community Right-To-Know rules are associated with the HCS, the Title III extends the information sharing of workplace Right-To-Know to the entire community, especially to emergency response personnel.
Employers are responsible for the safety and health of their workers. Some corporations, like Intel, have put together exceptional worker health and safety programs. OSHA tracks and reports the figures for recordable injuries (Recordable Rate, or injuries requiring treatment beyond first aid) and lost worker time (Lost Day Case [LDC], or injuries resulting in restricted duty or workers staying at home). The 1997 OSHA figures are available. The 1997 Recordable Rate for General Manufacturing was 10.3 per 200,000 hours worked, for the Electronics industry was 6.6/200,000 hrs, and for Intel worldwide was 0.26/200,000/hrs. The 1997 LDC Rate for General Manufacturing was 4.8 per 200,000 hours worked, for the Electronics industry was 3.1/200,000 hrs, and for Intel worldwide was 0.09/200,000 hrs.
Intel's OSHA figures for worker injuries and lost worker time due to injuries on the job site are among the best in the world. This did not happen by accident, but rather by having robust safety programs in Intel's EHS (Environmental Health and Safety) Program, discipline, and management and employee commitment. As part of Intel's commitment to a safe workplace, Intel utilizes a comprehensive EHS Workstation that melds seamlessly with the "injury-free" philosophy in place at Intel. This Workstation offers a centralized location to collect, maintain, and analyze all EHS-related data. The EHS Workstation has proven to be an effective tool for proactive reduction of accidents, injuries, and related expenses. Immediate access to all health and safety information increases your ability to make informed and effective decisions.
Intel XL EHS Workstation Overview
Intel has posted an overview of its EHS Workstation Overview on its XL web
http://www.intel.com/intel/other/ehs/projectxl/ at the heading
Intel EHS Workstation Overview.
Click here to go to the Intel XL EHS Workstation Overview.