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Kay Rowntree, CIH

Industrial Hygiene Sciences, LLCWisconsin Safety Congress

April 2015

� 1983 OSHA issued the Hazard

Communication Standard� Expanded and tweaked it in 1994

� Provided chemical users about the hazards of

chemicals

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� MSDSs & labels often…..

� Incomplete

� Incorrect

� Inconsistent

� OSHA did not require a common MSDS

format

� After 31 years, the HCS remains one of the most frequently cited OSHA standards

� The Globally Harmonized System of

Classification and Labeling of Chemicals� Used throughout the world

� Theory -classification leads to uniformity

which in turn leads to better comprehension and understanding

� The entire GHS system stands on the proper

classification of hazards� Classification, especially for mixtures, is a

complicated and very technical process

� Many chemical manufacturers still don’t get this

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� HCS 1994 was aligned with GHS in 2012

� Adopted most of GHS� Added some classes not covered under GHS

� Addressed some hazards not covered under

GHS� Established dates for compliance with the

changes

� The goals & basic requirements of the HCS

� The requirement that manufacturers, importers or distributors produce SDSs and labels

� The requirements for chemical users to

� Maintain a chemical inventory

� Obtain SDSs and make them available to employees

� Develop a written program

� Ensure containers are labeled

� Train employees

� Safety Data Sheets

� Name

� Consistent format

� Required elements

� Labels

� Consistent format

� Required elements

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� A statement assigned to a hazard class and

category� Describes the nature of the hazards of a

chemical, including, where appropriate, the

degree of hazard. � 72 individual and 17 combined

� Causes eye irritation� Causes mid skin irritation� Causes serious eye damage � Causes serious eye irritation � Causes severe skin burns and eye

damage � Causes skin irritation� Combustible liquid� Contains gas under pressure;

may explode if heated� Contains refrigerated gas; may

cause cryogenic burns or injury� Explosion; fire, blast or projection

hazard � Explosion; mass explosion hazard � Explosion; severe projection

hazard

� Extremely flammable aerosol � Extremely flammable gas � Extremely flammable liquid and

vapour � Fatal if inhaled � Fatal if swallowed� Fatal in contact with skin � Fire or projection hazard � Flammable aerosol� Flammable gas� Flammable liquid and vapour� Flammable solid� Harmful if inhaled� Harmful if swallowed

� A statement assigned to a hazard class and category� Describes recommended measures that should be

taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.

� Types of Precautionary Statements◦ General◦ Prevention◦ Response in case of spill or exposure

◦ Storage◦ Disposal

� 116 individual & 33 combined

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� Obtain special instructions before use� Do not handle until all safety precautions have been read

and understood� Keep away from heat/sparks/open flames/hot surfaces – No

smoking� Do not spray on an open flame or other ignition source� Do not allow contact with air� Keep away from any possible contact with water, because of

violent reaction and possible flash fire� Protect from moisture� Keep container tightly closed� Ground/bond container and receiving equipment� Use only non-sparking tools� Take precautionary measures against static discharge� Do not breathe dust/fume/gas mist/vapours/spray� Use only outdoors or in a well-ventilated area

� Used to indicate the relative level of severity

of hazard� Choice is driven by the hazard classification

and category

� Only 2

� 'Danger' is used for more severe hazard(s)

� ‘Warning' is used for less severe hazard(s)

� Some classes have no Signal Word

� A standardized visual symbol that conveys

the potential hazard(s)� Must be on the label and SDS

� Choice(s) are based on the classification

� There are classifications for which nopictogram is required

� These are not the same as the PPE

pictograms often seen on current MSDSs and labels

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� The first Haz Com 2012 compliance deadline

has passed!

� By December 1, 2013, all employees had to be trained in

▪ Label elements-what they are and how to use them

▪ SDSs-16 part format, where info is located and how the label info relates to the SDS

� If you have not done this yet, do it now!

� The deadline for manufacturers to prepare

complaint SDSs and labels is June 1, 2015� What does this mean to you?

� You will be receiving SDSs and newly labeled shipped products at an every quickening pace as the deadline approaches

� You will continue to receive SDSs beyond that date

� Distributors have until December 1, 2015 to ship GHS labeled containers so you may have more months of seeing old and new labels

� By June 1, 2016 all employers must

� Update alternative labeling system

� Update their written programs as necessary

� Provide training for any newly identified physical

or health hazards

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� Written program incomplete or doesn’t

reflect how things really work� Incomplete inventory

� Missing SDSs

� Lack of, incomplete or ineffective training� SDS access

� Unlabeled containers

“Hazard Communication: Small Entity

Compliance Guide for Employers That Use Hazardous Chemicals”

https://www.osha.gov/dsg/hazcom/

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� It is a requirement..……A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas (e)(i)

� It’s your way to � Ensure you have all relevant SDSs

� Assist employees in finding SDSs

� Determine what training is necessary

� Provide a framework for managing your SDSs going forward

� Product Identifier

� Must be exactly as it is on the label & SDS

� What should be included?

� Process/production/production support chemicals

� “Sales” or R & D samples

� Maintenance/housekeeping/grounds chemicals

� QC lab chemicals

� These are substances that a consumer could purchase off the shelf

� If the “use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose”, then it doesn’t have to be included in your HCP

� Best practice- list it on your inventory� These are often purchased outside of usual

purchasing chains so you may have to actively go looking for the SDS

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Article means a manufactured item other than a

fluid or particle:(i) which is formed to a specific shape or design during manufacture

(ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and

(iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical …and does not pose a physical hazard or health risk to employees

� If you are doing things to the articles that

could release hazardous substances that are “bound” up in the articles, you need to

include it

� Examples

� Heating

� Grinding, sawing, cutting, drilling, blasting, sanding, polishing

� Welding or thermal cutting

� Hazards may not require classification so you

may not see Pictograms, Signal Words and statements about them on the SDS or Label

� Look in the following Sections for info

� Section 2, Supplemental info

� Section 7, Handling and Storage

� Section 8, Exposure Controls

� Section 10, Hazardous decomposition products

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� Inventory your current chemicals and figure out what SDSs will be needed-this is a great time to clean up your inventory list

� As you receive SDSs, determine if you are actually using the product anymore

� External electronic systems problems� Establish an internal process for

� Removing the old and replacing them with new SDSs� Keeping track of which materials still need an SDS so

after the deadline passes you can get them

� In-plant labeling to ensure the labels have the correct product identifiers

� Just because the manufacturer calls their document a SDS, it may not meet OSHA/GHS requirements

� There are and will continue to be poor quality SDSs� Inadequate or incorrect classification

� No discussion of hazards that could be created during use

� Inadequate info on PPE selection & usage

� Incorrect exposure limits

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• Section 1 does not have

the correct name• Section 2

• No GHS

classification• No Pictograms

• No Signal Word

• No Hazard or Precautionary

Statements

• Chemical composition

should be in

Section #3• Section #3 contains

wrong info

� Revision/release date� 16 Section Format with the info in the correct

places� Use of pictograms that should not be used

together� Section 2-Look for classification

� Must be present OR

� Should state the material is not subject to classification OR

� The material is not hazardous under 1910.1200

� Chemical review

� Do you really want to use this chemical?

� Is one product “safer” than another?

� Identifying hazards

that employees must be informed of and trained

� Source of info for

� PPE assessments

� Proper work practices

� Control measures

� Proper storage

� IH sampling

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� Use the classification(s)

� The higher the category number, the lower the

hazard

� Use the pictograms

� Avoid substances with Skull & Crossbones

� Substances with Exclamation Points are

generally safer than those with the Health Hazard or Corrosive pictograms

� Avoid unstable compounds

� What does OSHA require?

� Where can I go for information?

� What do the Pictograms mean?

� What does the Signal Word mean?

� What are the hazards of the materials I handle?

� How do I protect myself?

� Are there special things I need to know about handling and storing the material?

� Are there ways to tell if I am being exposed?

� What if something does not have a label or I can’t read the label?

� What do I do in an emergency?

� General Info� OSHA requirements

� How to read an SDSs

� Where SDSs are located

� How to read a GHS label

� What pictograms mean

� What signal words mean

� What to do if labels are missing or illegible

� Emergency response-general actions

� Job/Task/Dept. Specific Info� Physical hazards of the

materials they are exposed to

� Health hazards of the materials they are exposed to

� What PPE should be used

� What controls should be used and what to do if they are not working

� Special handling and storage practices if applicable

� Special emergency response actions if applicable

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“Employers should provide employees with effective

information and training on hazardous chemicals in their work area at the time of their initial assignment,

and whenever a new physical or health hazard that employees have not been previously trained about is introduced into their work area”

Information and training may be designed to cover

categories of hazards (such as flammability or carcinogenicity) or specific chemicals. Chemical-specific information must always be available through

labels and material safety data sheets.

Training

� GHS pictograms & signal words make category training easier-make sure

employees understand them� Train at

� First hire

� New assignment

� Introduction of new hazards

Program

� SDSs must always be available (all shifts, no barriers)

� Labels cannot be removed, defaced and must remain legible

and visible

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Employees shall be informed of:

� the requirements of this section;� any operations in their work area where hazardous

chemicals are present;

� the location and availability of the written hazard communication program, including the required list of hazardous chemicals, and material safety data

sheets required by this section.

Training� OSHA does not expect

employees to be toxicologists or industrial hygienists

� Employees should know � where SDSs are kept

� how they can find/access SDSs� where they can find/access a

copy of the company’s written Haz Com program

� where they can find/access the list of chemicals

� about the hazards in their work area

Program� The inventory

� You have to have one

� It has to be available to employees

� Use the inventory to keep track of which SDSs you have received and which ones you still need to obtain

Methods and observations that may be used to detect

the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual

appearance or odor of hazardous chemicals when being released, etc.);

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� Detection� Any active or passive ways the employees can detect

the presence or the release of a chemical▪ Visual, odor are passive methods▪ Alarms are active methods

� In Section 9 of an SDS, the odor and appearance of the substance will be described

� While not stated, you may want to discuss odor & toxicity � One does not necessarily mean the other� Some chemicals are hazardous because they have no

odor or are toxic before you can smell them

The physical, health, simple asphyxiation, combustible

dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;

� Needs to address all of the types of hazards

� GHS pictograms, signal words, hazard & precautionary statements can be used to ID

training elements

� Don’t overlook the hazards that could occur during use

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the measures employees can take to protect themselves

from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate

work practices, emergency procedures, and personal protective equipment to be used;

Training� Cover any/all control measure

available� Engineering controls

� Enclosures

� Restricted areas

� Work practices

� PPE requirements

� Signage

� Emergency response actions should be addressed� What employees are expected to do

� How to recognize they need to leave the area and call for help

Program� Other required OSHA

training can supply more specific info or may overlap� Respirators

� PPE

� HAZWOPER

� Emergency Action Plans

� Substance specific standards (lead, hexavalent chromium, formaldehyde, cadmium, etc.)

The details of the hazard communication program

developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the

safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

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Training� Employee must know how

to read GHS labels & SDSs� The format of a GHS SDS

� How to find info on the SDS

� Pictograms and what they mean

� Signal words and what they mean

� Hazard and precautionary statements

� In-plant labeling systems

� SDSs and where they can find hazard info on them

Program� Establish who is

responsible for labels� Develop a plan for in-plant

labeling

� Employees should � be know about the hazard(s) he/she is exposed to� understand how to protect themselves� know what to do in an emergency

� where they can go to get further information� Don’t try to make everyone a chemist or

toxicology or safety professional� Provide supplementary info such as glossaries or

posters for the technical info� Focus on the Sections of the SDS and label that have

the most useful info

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�16 part format�Sections must be in the order listed in the

following slides � Several sections are not required by OSHA

(Sections 12-15) since they do not deal with workplace H & S

� If no relevant info is found for any Physical Hazard subheading, then it must be marked as “no applicable information found” or “not applicable” etc.-cannot leave the field blank

� SDSs may have the correct format but that

does not mean they will look the same or have the same information

� This is especially true for products exported

or prepared in the EU or other countries� The challenge:

� While the format is the same, the content AND content quality may not be

Correct format

Classification clearly spelled out

Label elements included

Hazard and Precautionary

Statements included

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Ingredients & CAS #s provided

Correct format

Comprehensive info

Correct format

Correct exposure limit info

Correct classification and formatting but visually different than the previous document

and more European information. Includes HMIS, Canadian WHMIS & NFPA info

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Content� Product identifier� Other means of

identification if applicable

� Recommended use of the chemical and restrictions on use

� Supplier's details (including name, address, phone number, etc.)

� Emergency phone number

Takeaways� Match the Product

Identifier (exactly) with the inventory list & in-plant labeling

Content� GHS classification� GHS label elements,

including hazard & precautionary statements, signal words & pictograms (red border not required on the SDS)

� Hazards not otherwise classified

� Supplementary hazard information

Takeaways� Spend the most time

teaching employees to look here for info

� Pictograms provide quick information about

the hazards� They are provided based on the classification

of the product

� There are 8 standardized pictograms that apply to physical and health hazards

� There is also 1 environmental pictogram

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� Applies to chemicals that may explode (blow up)

� Explosions could� create toxic or flammable gases� create shock waves� release projectiles

� Explosions can be set off by heat, fire, sparks, shock, impact, contact with moisture

� Chemicals with this pictogram must be properly stored and handled

� Read the label or SDS to learn about conditions to avoid

� Unstable explosive

� 1.1 Explosive-mass explosion hazard (DANGER)� 1.2 Explosive-severe projection hazard

(DANGER)

� 1.3 Explosive- fire, blast or projection hazard (DANGER)

� 1.4 Fire or projection hazard (WARNING)

� 1.5 May mass explode in fire (WARNING)

� Applies to chemicals that are flammable or combustible

� Some can heat up by themselves while others require a source of ignition to be a fire hazard

� These chemicals are fire and/or explosion hazards

� Chemicals with this pictogram must be properly stored, dispensed and handled

� Read the label/SDS to learn what how to handle, use and store these chemicals

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� Category 1:Flash point < 23°C (73.4°F) and initial boiling point ≤ 35°C (95°F) (DANGER)

� Category 2Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F)(DANGER)

� Category 3Flash point ≥ 23°C (73.4°F) and ≤ 60°C (140°F)(WARNING)

� Category 4Flash point > 60°C (140°F) and ≤ 93°C (199.4°F) (No signal word or pictogram)

� This is different than the flame pictogram. It has an “O” below the flame.

� It is used for chemicals that cause any combustible material to burn more rapidly or intensely

� They present fire and/or explosion hazards

� Chemicals with this pictogram must be properly stored, dispensed and handled

� Read the label/SDS to learn what to do and conditions to avoid

� Applies to cylinders that contain

a gas under pressure� Hazards include

� explosions if heated

� toxic gas releases

� freezing or burning of skin

� displacement of oxygen if the

contents leak into a confined or poorly ventilated space

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� Cylinders can become projectiles if the valve breaks-they always should be securely secured during storage and transport

� Chemicals with this pictogram must be properly stored, transported and handled

� Read the label/SDS to learn what to do or conditions to avoid

� This pictogram applies to chemicals that cause severe skin burns, damage to the skin, eyes and lungs.

� They have the potential to cause very serious damage

� Signal word is DANGER

� They can also damage metal containers which could leak and/or rupture

� Acids and caustics are common corrosives

� When you see this pictogram, you should know

� What protective measures such as gloves, goggles, protective clothing or respirators are needed

� What controls (e.g. ventilation) should be used

� Read the label/SDS to learn about other precautions

� These chemicals are the most severely toxic chemicals.

� They can cause serious and potentially fatal illness/injury and may do so quickly

� Always has the signal word DANGER

� Exposure may occur through

� Inhalation and/or

� Ingestion and/or

� Skin contact

� When you see this pictogram, you should know

� What protective measures such as gloves, protective clothing or respirators are needed

� What controls (e.g. ventilation) should be used

� What to do in emergency situations

� More specific training should/will be provided

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� This pictogram applies to chemicals are the less toxic than those with the Skull and Crossbones. It is never used with the Skull and Crossbones pictogram.

� It includes chemicals that are irritants to the skin, eyes or respiratory tract

� While less toxic, these chemicals can still be harmful

� Exposure may occur through� Inhalation and/or� Ingestion and/or

� Skin contact� When you see this pictogram, you should know

� What protective measures such as gloves, protective clothing or respirators are needed

� What controls (e.g. ventilation) should be used

� What to do in emergency situations

� Has acute toxicity but it is not severe (Skull

and Crossbones are for severely acute toxins)� May be a dermal sensitizer

� May cause skin and eye irritation

� Weak acids and bases that don’t reach the level of

corrosive may fit here

� Could cause narcosis� May irritate the respiratory tract

� These chemicals cause health effects after a single exposure or repeated exposures

� May have signal words of DANGER or WARNING

� These chemicals can� can damage organs such as the liver, brain,

kidneys, lungs� Cause respiratory sensitization

� cause cancer� affect the reproductive system or fetus� damage genes (DNA)

� Aspiration into the lungs

� Affects may follow a single exposure or with repeated exposures

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� Exposure may occur through

� Inhalation and/or

� Ingestion and/or

� Skin contact

� When you see this pictogram, you should know

� What protective measures such as gloves, protective clothing or respirators are needed

� What controls (e.g. ventilation) should be used

� What to do in emergency situations

� More specific training should/will be provided

� OSHA does not require this pictogram but you will still see it on containers

� These chemicals are acutely toxic to fish and other creatures living in the water or to aquatic plants

� These chemicals must be disposed of properly

Content

� Ingredient’s chemical name and CAS#

� Concentration (exact percentage) or

concentration ranges of all ingredients which are

classified as health hazard

� Where a trade secret is claimed a statement

that the specific chemical identity and/or exact

percentage (concentration) of composition has

been withheld as a trade secret is required

� Impurities and stabilizing additives which are

themselves classified and which contribute to

the classification of the substance must be listed

Takeaways� Probably not a

Section you

need to spend a lot of time

training on

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Content� Description of necessary

measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion

� Most important symptoms/effects, acute and delayed

� Indication of immediate medical attention and special treatment needed, if necessary

Takeaways� Probably not a Section you

need to spend a lot of time training on

Content

� Suitable (and unsuitable) extinguishing media

� Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products, dust combustibility)

� Special protective equipment and precautions for firefighters

Takeaways� This section is pretty

generic-spend time on it though if your employees are supposed to be involved in fire fighting

Content� Personal precautions,

protective equipment and emergency procedures

� Environmental precautions

� Methods and materials for containment and cleaning up

Takeaways� This section is pretty

generic-spend time on it though if your employees are involved in emergency response

� Especially important for things with the Flammable or Exploding bomb pictograms

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Content

� Precautions for safe

handling

� Conditions for safe storage, including any incompatibilities

Takeaways

� Spend time here if there are hazards with the product you use

� Especially important for things with the Flammable or

Exploding bomb pictograms

Content� Control parameters� Occupational exposure

limit values including OSHA PELs, ACGIH TLVs or manufacturers limits

� Appropriate engineering controls

� Individual protective measures, such as personal protective equipment (PPE)

Takeaways� This can be an

important Section to spend time on although sometimes info is pretty generic.

� Use this as an opportunity to explain what preventive and control measure YOUR employees will specifically be using

� Appearance (physical state, color, etc.)

� Odor� Odor threshold� pH� Melting point/freezing

point� Initial boiling point &

boiling range� Flash point� Evaporation rate

� Flammability (solid, gas)� Upper/lower flammability

or explosive limits� Vapor pressure� Vapor density� Relative density� Solubility(ies)� Partition coefficient: n-

octanol/water� Autoignition temperature� Decomposition

temperature

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Content� Chemical stability� Possibility of

hazardous reactions� Conditions to avoid

(e.g., static discharge, shock, or vibration)

� Incompatible materials

� Hazardous decomposition products

Takeaways

� Spend time here if there are hazards with the product you use

� Especially important for things with the

Flammable or Exploding bomb pictograms

Content� Information on the likely routes of exposure

(inhalation, ingestion, skin and eye contact)� Symptoms related to the physical, chemical

and toxicological characteristics� Delayed and immediate effects and also

chronic effects from short- and long-term exposure

� Numerical measures of toxicity (such as acute toxicity estimates)

� Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest edition), or by OSHA.

Takeaways� Probably not

a Section you need to spend a lot of time training on

� Section 12: Ecological Info� Ecotoxicity (aquatic and

terrestrial, where available)

� Persistence and degradability

� Bioaccumulative potential

� Mobility in soil� Other adverse effects

� Section 13: Disposal Considerations� Description of waste

residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging

� Section 14-Transport Info� UN Number� UN Proper shipping name

� Transport Hazard class(es)� Packing group, if applicable

� Marine pollutant (Yes/No)� Special precautions which a user needs to be

aware of or needs to comply with in connection with transport or conveyance either within or outside their premises

� Section 15: Regulatory Info� Safety, health and environmental regulations

specific for the product in question

� Section 16: Other information including date of preparation or last change� NFPA/HMIS will likely be here

Sections 12-15 will not be

enforced by OSHA

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� Labels must be� in English

� legible

� prominently displayed� Portable container exemption still applies but ask yourself if

you really want to have unlabeled containers sitting around� Pipes, piping systems, engines & fuel tanks or other

operating systems in a vehicle are not considered containers� Manufacturers must label their products� Users must

� ensure labels are not defaced

� address in-plant containers labeling

� train employees how to read labels

� Pictograms must follow GHS requirements and have a red border

� OSHA cannot require the Pictogram for environmental hazards but you will still probably see it on labels

� Shipped container required elements� Product identifier (must

match the SDS)

� Supplier information

� Pictograms

� Signal Words

� Hazard statements

� Precautionary statements

� Supplemental info allowed but can’t contradict GHS

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From: http://www.schc.org/pdf/fact_sheets/SCHC_GHS_FS2_Flammable_Liquid.pdf

� Requirements

� They must be in the shape of a square set on point

� The hazard symbol must be black on a white background

� They must have a red border

� There may be more than 1 pictogram on a label

� There may be no pictogram if the chemical is

not hazardous enough to require one

� Updates must be done within 6 months after receipt of info that hazards have changed� Any chemicals shipped after that time must have the new labels

� For solid metal, wood or plastic items that are not excludedas articles (f)(4)(i)� the required label can be transmitted at time of the initial shipment

� does not need to be included in subsequent shipment unless info on the label changes

� only applies to the solid material itself� this label exclusion does not apply if there are other hazardous

substances used in conjunction with or present with the item to which downstream users may be exposed

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� The goal is to convey information about the

hazard so employees can take the proper precautions

� If you use labels that are different from the

shipped container are you causing confusion?

� Labels on their own too generic

� Effective only if the overall HCS program is effective

� Employer bears the burden of establishing

that employees are aware & know what to do � HMIS label numbers do not correlate to GHS

numbering systems

“Employers may continue to use rating systems such as National Fire Protection Association (NFPA) diamonds or HMIS requirements for workplace labels as long as they are consistent with the requirements of the Hazard Communication Standard and the employees have immediate access to the specific hazard information as discussed above. An employer using NFPA or HMIS labeling must, through training, ensure that its employees are fully aware of the hazards of the chemicals used”.

(“OSHA Brief: Hazard Communication Standard: Labels and Pictograms” https://www.osha.gov/dsg/hazcom/)

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� Keep NFPA labels for their original purpose-informing ER personnel of hazards

� Keep HMIS but realize that……..� Many manufacturers are not going to put HMIS

info on SDSs and label so if you want to keep using them, you will have to figure out the correct numbers that should be on the label

� Having 2 labeling systems (GHS and HMIS) may be confusing to employees and create more work to train for both

� Designate a responsible person(s)

� Include in your written program how alternative labeling systems will be used and

how changes will be handled

� Train employees how to read labels� Make sure the label matches the Product

Identifier on the SDS

� Make sure all hazardous substances are labeled

� Two way street� You have to inform contractors about your hazards

and where they can obtain SDSs� Contractors have to inform you of hazards they

introduce with their work and have SDSs available � Think about who comes to your site

� Are they doing non-routine tasks that could expose your or their employees to hazardous substances?

� Are Haz Comm issues addressed in your contractor safety program?

� Designate a person responsible for interfacing with the contractors

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Thank You!

Kay Rowntree, CIHIndustrial Hygiene Sciences, LLC

602 Fox Knoll DriveWaterford, WI 53185

262-534-2554kayihs@tds.net

www.ihsciences.com