HazCom revisited: Don't slip up

OSHA’s Hazard Communication Standard (HazCom) has been around for a few years, but since it became law, a whole new generation of hvacr contractors has emerged.

If you don’t want to risk a potential violation and/or employee injuries, you’d better not take it for granted.

In a nutshell, the standard requires all contractors to educate their employees about hazardous chemicals they are exposed to in the workplace and the methods necessary to protect themselves.

“Hazardous chemicals” include liquids, solids, gases, vapors, fumes, and mists, whether or not they’re contained.

Examples of hazards on the jobsite include:

• Flammable substances (i.e., gasoline, kerosene, alcohol);
• Compressed gases (oxygen, refrigerants); and
• Toxins (dust from cement, paint, or cleaning fluid fumes).

Are you in compliance?

To be in compliance with the standard, you need to train all employees who may be exposed to hazardous chemicals about the dangers associated with those chemicals and the protective measures they need to take.

Under HazCom, there are four major elements of compliance:

1. Material Safety Data Sheets (MSDSs);

2. Labels;

3. Employee training; and

4. A written hazard communication program.

MSDSs identify hazards. To be in compliance, you must have an MSDS for every hazardous substance used.

Any product tagged or labeled with key words such as “danger,” “caution,” “flammable,” “warning,” etc., requires an MSDS.

An MSDS also should be received with every shipment of hazardous substance. Suppliers and distributors should provide MSDSs with the products they sell.

If an MSDS is not received with a shipment, request a written copy to show that a good-faith effort has been made to comply with HazCom (if the company is inspected).

OSHA urges all employers who have difficulty obtaining MSDSs from suppliers or manufacturers to contact their local OSHA office for assistance.

Once all of your MSDSs have been assembled, you must keep copies of them at a central location on all jobsites (for instance, in trailers, trucks, or the office). All employees must be trained on how to use the equipment.

Labeling hazardous products. All hazardous products must be identified with a label that lists appropriate hazard warnings. If a supplier ships a product with a warning label but no MSDS (or vice versa), request either the label or MSDS from the supplier. To protect yourself, document the request.

Labels serve as a synopsis of the MSDS, and should never be considered a substitute for one. The label will be the employee’s immediate source of information; the MSDS is the backup.

Safety training

Employees (such as service and installation techs) who risk exposure to hazardous substances during their routine job duties, unexpected releases, or emergency situations must receive training.

Generally, office staff will not be required to be trained because office products are not classified as hazardous substances.

Commercial products are only regulated when used in a manner greater than that of a normal consumer. However, employees who are principally responsible for handling copy machines must be trained about the dangers of the chemicals used in the machine.

In general, employees also should be trained to:

• Spot hazards;
•  Know the physical and health hazards of chemicals;
•  Respond in an emergency or accident; and
•  Locate and understand the company’s written hazardous communication policy.

Getting your program in writing

Under HazCom, employers are required to have a written hazard communication program that describes how they are complying with the standard. It must be made available to employees and their representatives if they ask to see it.

Employees must be trained on the program, and the written program must be maintained at all jobsites.

Employers’ written programs must contain the following specific information:

•  A list of the hazardous chemicals on the worksite as they appear on the MSDS (listing the chemical and common names of the substances also is recommended);
•  A description of how obligations under HazCom for labeling, MSDSs, and employee training will be met;
•  A description of how other employers will be informed of hazards they may encounter when they perform nonroutine tasks; and
•  An explanation of how other employers will be informed about hazardous chemicals that are used around their employees on multi-employer jobsites.

  Contractors must also state how other employers on the jobsite will:

•  Have access to copies of MSDSs;
•  Be informed of the precautionary measures to take to protect employees under normal working conditions and in emergencies; and
•  Be informed of the labeling system used on the worksite.

So, before beginning a job, contact other employers working on the site and ask them for the appropriate information needed to be in compliance with the written program.

Reprinted with permission from the Air Conditioning Contractors of America. For more information, contact ACCA at 202-483-9370; 202-234-4721 (fax); www.acca.org (website).

Links

• ACCA