AFS Environmental Health & Safety Conference Nashville, TN August 24, 2010

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1 AFS Environmental Health & Safety Conference Nashville, TN August 24, 2010

2 Protect employees from illness and injury associated with the use of hazardous substances A generic and performance oriented standard MSDSs and labels are required to transmit information to employees What do foundries have to do? Obtain MSDSs for chemicals used in workplace Provide MSDSs to end users of castings Prepare a written program Ensure that all chemicals covered under the standard have labels Train employees Canada has a similar regulation-workplace Hazardous Materials Information System (WHMIS)

3 Continues to be one of the most frequently cited OSHA Standards Failure to develop and maintain a written program Failure to have a material safety data sheet for each hazardous chemical Lack of employee training or failure to maintain training Inadequate labeling If you are inspected for almost any reason it is likely that your written program will be reviewed

4 Prepare a list of all chemical substances- liquids, solids and gases Organize the list Don t overlook.. Materials that create hazards during use Substances brought in by outside contractors or vendors Substances used in QC labs Items for which you don t already have an MSDS The stuff lurking in closets, cabinets, storage buildings/rooms Samples Cleaning chemicals or substances bought at local stores Chemicals used only occasionally Develop a system to ID new chemicals and ensure they are included in the program

5 Compare the inventory list to the MSDSs you already have and. Pull out the ones for products no longer used or outdated MSDS but save them Check the dates on the MSDSs; obtain new ones especially for compounds containing VOCs Canada requires that MSDS must be updated every 3 years or when formulations change Don t assume that the manufacturer will send an updated MSDS when changes are made-you may need to seek them out The MSDSs must be readily available to all workers at any time Develop a system for obtaining and organizing MSDSs

6 The program should explain how your facility will comply with the standard and who is responsible for making it happen It should be site-specific Required elements List of chemicals How labels will be handled How MSDSs will be obtained and maintained How training will be done How employees will be informed of hazards of nonroutine tasks How contractors/vendors will be advised of your hazards and how they will advise you of hazards they bring into your workplace

7 Your program should Designate who is responsible for ensuring labeling of in-plant containers Designate who is responsible for ensuring there are labels on incoming containers Describe the labeling system(s) used You can rely on manufacturer s labels but Be sure they are visible Be sure they are legible

8 What has to be on a label? Identity of the material-must match the MSDS Appropriate hazard warnings Portable Containers Definitions OSHA Requirement vs. Best Practices Stationary Containers & Piping Labeling Systems NFPA HMIS The key to evaluating the effectiveness of any alternative labeling method is to determine whether employees can correlate the visual warning on the in-plant container with the applicable chemical and its appropriate hazard warnings.

9 Provide in a language & vocabulary the employee can understand (OSHA 4/28/10) Shared responsibility with temps When? Before assignment or when a new hazard is identified Good training. Develops competency Teaches employees how to reduce their exposures Does not overwhelm with information that does not reduce risk Focuses on the most important hazards Shows where to go for more information Instructs employees on what to do in an emergency It cannot be expected that employees will recall all information provided in the training and be able to repeat it. Employees must be aware of the hazards to which they are exposed, know how to obtain and use information on labels and MSDSs, and know and follow appropriate work practices. OSHA Haz Comm Directive

10 Info about the standard Operations where hazardous chemicals may be present Location of the written program, list of chemicals and the MSDSs Methods and observations employees can use to detect the presence or release of chemicals Physical and health hazards of chemicals in their work area including by-products of processes Focus on the important stuff Corrosiveness Fire hazard Target organ hazards What to do in an emergency Measures employees can take to protect themselves Explanation of labeling systems How employees can obtain & use hazard information

11 While castings are articles, if they will be used in a manner that will generate hazardous substances under expected conditions of use, you need to provide an MSDS Examples Welding, thermal cutting Machining Grinding or sawing

12 OSHA is proposing to align the standard with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) This is projected to occur sometime in 2011with a 3 year phase in after that to update MSDSs & labels Changes to expect MSDSs will be more uniform The GHS requires a 16 section MSDS format with specified sequence and minimum required contents. Hazard warnings will be right up front on the MSDS Labels will change GHS labels have pictograms, as well as specified signal words, and hazard statements Employee training will need to be updated

14 Obtain updated MSDS as they become available Many global manufacturers are already issuing GHS compliant MSDSs Review MSDSs to determine if the hazards are different that those employees have already been trained on Train employees on updated hazards & reading new MSDSs Train employees to understand the GHS labeling system Provide GHS compliant labels for containers Provide customers with GHS compliant MSDSs

15 General Requirements for PPE ( ) Specific PPE standards Eye and Face Protection Respiratory Protection This standard is more complex than the others and will not be covered in detail here Head Protection Foot Protection Hand Protection Other Standard Specific PPE

16 Perform a "hazard assessment" of the workplace to identify and control physical and health hazards. Identify and provide appropriate PPE for employees. Train employees in the use and care of the PPE. Maintain PPE, including replacing worn or damaged PPE. Periodically review, update and evaluate the effectiveness of the PPE program.

17 Identify the physical & health hazards in the following categories Impact including flying, falling or dropping objects Penetration including sharp objects Compression (roll-over) Chemical High temperatures Heat/cold Harmful dust Light (optical) radiation Biological hazards Assessment must be in writing, dated and certified Don t forget non-routine operations!

18 stories/ehs/ppe05bk_no%20copy right.pdf It is free!! OSHA has used the PPE recommendations in this book when issuing citations

20 PPE should meet minimal standards Eye and Face Protection: ANSI Z (USA Standard for Occupational and Educational Eye and Face Protection) Head Protection: ANSI Z Foot Protection: ANSI Z Gloves Based on tasks performed and the performance and construction characteristics of the glove material For protection against chemicals, glove selection must be based on the chemicals encountered, the chemical resistance and the physical properties of the glove material Respirators Based on hazard NIOSH Certified

21 Employees need to know. When PPE is necessary What PPE is necessary How to put on, take off, adjust and wear PPE The limitations of the PPE Proper care, maintenance useful life and disposal Employees must be able to demonstrate that they understand the training before performing work where PPE is required Retaining required if employee does not appear to understand- Must verify that the employee has received and understood the info provided To fulfill these requirements periodic observations and intervention is necessary

22 Eye & Face Protection Provide side protection required if there are flying objects If employee needs prescription eyewear, the eye protection provided must incorporate the prescription in the design or be able to be properly worn over prescription lenses For protection against light radiation (thermal processes including lasers), selection needs to be based on shade numbers (tables are in the standard) If chemical splashes could occur, provide goggles and/or a chemical resistant faceshield-glasses are not enough Head Protection If employee can encounter exposed electrical conductors, the protective helmet must be designed to reduce electric shocks Select helmets that Resist penetration by objects Absorb the shock of a blow Be water-resistant and slow burning Have clear instructions explaining proper adjustment and replacement of the suspension and headband

23 Hand Protection Considerations Type of chemicals handled Nature of contact (total immersion, splash, etc.) Duration of contact Area requiring protection (hand only, forearm, arm) Grip requirements (dry, wet, oily) Thermal protection Size and comfort Abrasion/resistance requirements MSDSs for chemicals often do not contain useful information on chemical resistant gloves. Vendor websites can be helpful.

24 The employer pays.. when PPE is required for replacement PPE unless the employee has lost or intentionally damaged PPE issued to him or her for PPE required under substance specific standards Employers are not required to pay for non-specialty safety-toe footwear or non-specialty prescription eyewear, as long as the employer allows the employee to wear these items off the job site and the items are such that they can be used outside the job site. ordinary clothing, such as long sleeves, long pants, street shoes, etc., that may serve as PPE ordinary clothing, such as winter coats, gloves, etc., or items such as skin cream or lotion used solely as protection from the weather voluntarily used respirators

25 Questions? Kay Rowntree, CIH Industrial Hygiene Sciences, LLC 602 Fox Knoll Drive Waterford, WI com

University of Wisconsin-Madison Hazard Communication Standard Policy Dept. of Environment, Health & Safety Office of Chemical Safety

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