Magazine article Occupational Hazards

Hazard Communication for Small Plants

Magazine article Occupational Hazards

Hazard Communication for Small Plants

Article excerpt

There is plenty of confusion and misinformation surrounding OSHA's Hazard Communication Standard. What can a small manufacturing plant do to improve compliance?

Before the final version of OSHA's Hazard Communication Standard appeared in the Nov. 25, 1983, Federal Register, there echoed prophecies of endless litigation, and the fear that employees would use the standard to seek vengeance against their employers.

May 25, 1986, was the effective date for many industries, and it came and went without excessive lawsuits. In 1988, most other businesses were added to the scope of this standard, yet in the ensuing six years, Pandora's Box has not opened.

There are clues, however, that the Hazard Communication Standard is not effective.

* The most frequently cited OSHA standard for several years running is the Hazard Communication Standard. Clearly, the letter of the law is not being complied with in industry.

* If the goal of Hazard Communication is "to ensure that the hazards of all chemicals . . . are evaluated, and that information concerning their hazards is transmitted to affected employers and employees," then the spirit of the law is not being complied with either.

A critical examination of labels and Material Safety Data Sheets (MSDSs) shows that some information contained therein has limited value to the average person. In short, MSDSs are awful!

There is a definite lack of useful information on the typical MSDS, which often contains contradictory statements, or is so watered down by statements obviously worded to avoid litigation that it is practically useless.

For instance, what does "Provide sufficient ventilation to prevent exposure" mean? What does "Dispose in accordance with all applicable federal, state and local laws and regulations" mean?

How many times have you read, "This product contains no chemicals considered hazardous by OSHA," yet there are two pages of health warnings and first aid measures? How many times have you read, "No hazardous ingredients," or perhaps, "No ingredients are considered hazardous by OSHA," but under "First Aid for Ingestion," it says, "Seek professional medical help immediately." Makes you wonder, doesn't it?

* Employees have little interest in the program mainly because they do not understand MSDSs or labels. Mostly, employees rely on their supervisor to tell them how to safely use chemicals and do not even bother with MSDSs and labels. Even the proposed 16-section MSDS does not correct the problem: preparers are not giving meaningful information on MSDSs or labels, and "hazard determinations" are too often of dubious quality.

Take the case of a plant of 1,200 employees where, since the effective date of the standard, only eight persons - an average of one per year - have asked for copies of MSDSs. That's less than 1 percent of the plant's population!

Another plant employing 250 workers received about 30 requests for MSDSs the first year when there were ill feelings between the bargaining unit and management, yet the same plant has received exactly zero subsequent requests! Lawsuits feared by the latter plant's management (because of the flurry of requests back in 1986) never materialized.

MSDS Miscommunication

While MSDSs do serve many useful purposes, they miscommunicate as often as they communicate. For instance, many MSDSs provide health hazard information for pure chemicals but do not give information about the mixture itself.

Many times, the physical and chemical data are reported for one of the ingredients, but not the mixture. Vapor pressure and diffusivity coefficient are needed to estimate potential exposures, yet the former is often omitted and the latter is not even required by OSHA. Evaporation rate is commonly reported as being "slower than ether." What does that mean?

The goal of the standard will ultimately be realized sometime after the MSDS is required to contain standardized information about the actual compound to which it refers. …

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