Ethics & Compliance Exam 1 Content

OSH Act of 1970, Hazardous Communication Standard, Fire Extinguishers

The Occupational Safety and Health Act of 1970

“Safety Bill of Rights,” William-Steigler Act, signed into law by Nixon on 12/29/1970.

National Institute for Occupational Safety and Health (NIOSH)

Conducts research and determines permissible safety levels.

Occupational Safety and Health Review Commission (OSHRC)

Adjudicates enforcement actions by OSHA that are challenged by employers.

OSHA General Duty Clause: Employers

Responsibility to provide a workplace free from recognized hazards that are likely to cause death or serious injury, responsible for compliance promulged under the act.

OSHA General Duty Clause: Employees

Responsible for compliance promulged under the act, orders issued pursuant which are applicable to his/her/their own actions and conduct.

Hazard Communication Standard

Employees have a need and right to know the hazards they are exposed to when working and protective measures available to prevent adverse effects.

Hazardous Chemical

Any chemical classified as: health/physical hazard, simple asphyxiant, combustible dust, pyrophoric gas, or other.

HCS: Employee Benefits

Preventative/protective measures, recognition of symptoms of exposure, determining how exposure may affect preexisting medical conditions.

HCS vs. OSHA

HCS is more performance-oriented, allowing more room for discernment.

HCS: Manufacturer Requirements

Labels and safety data sheets (SDS) written in English.

HCS: Employer Requirements

Written hazard communication program, labels, correct forms of warning, SDS, employee info & training.

HCS Program: The 6 Steps

1. Learn the standard, Identify responsible staff

2. Prepare and implement a written HCS program

3. Ensure containers are labeled

4. Maintain SDS

5. Inform and train employees

6. Evaluate and reassess program

HCS Program Step 1: Learn the standard, identify responsible staff

Creates a standard that is a continuing program, assigns responsibility to staff to coordinate all initial and ongoing activities.

HCS Program Step 2: Prepare and Implement a Written HCS Program

A written plan that indicates how hazard communication will be addressed and to help ensure compliance, must include: labels, forms of warning, SDS, employee info/training, list of inventory, how workers will be informed of hazards outside of their normal work routine.

HCS Program Step 3: Ensure Containers are Labeled

All labels must be clearly legible, in English, and must contain: Product identifier that matches corresponding SDS, signal word, hazard statement, pictogram, precautionary statement.

Product Identifier

Name of hazardous chemical that matches the corresponding SDS, manufacturer contact information.

Signal Word

Indicates relative level of severity of the hazard. Ex: Warning, Danger.

Hazard Statement

Class, category, or degree of hazard. Ex: acute oral toxicity.

Precautionary Statement

Phrase that describes measures to prevent/minimize adverse effects resulting from exposure or improper storage/handling.

4 Types of Precautionary Statement

Prevention, response, storage, disposal.

Sensitizer

A substance that may cause you to be allergic to it due to prolonged exposure.

Pictograms: Health Hazard

Carcinogen, mutagenicity, reproductive toxicity, respiratory sensitizer, target organ toxicity, aspiration toxicity.

Pictograms: Flame

Flammables, pyrophorics, self-heating, emits flammable gas, self-reactives, organic peroxides, desensitized explosives.

Pictograms: Exclamation Mark

Skin/eye irritant, skin sensitizer, acute toxicity, narcotic effects, respiratory tract irritant, hazard not otherwise classified, hazardous to the ozone layer (not mandatory).

Pictograms: Gas Cylinder

Gases or chemicals under pressure.

Pictograms: Corrosion

Skin corrosion/burns, eye damage, corrosive to metals.

Pictograms: Exploding Bombs

Explosives, self-reactives, organic peroxides.

Pictograms: Flame Over Circle

Oxidizers.

Pictograms: Skull & Crossbones

Acute toxicity.

Pictograms: Environment

Not mandatory, aquatic toxicity.

HCS Program Step 4: Maintain SDS

Manufacturers must supply them, employers must maintain the current version readily and immediately accessible to workers or medical personnel (no barriers) when they are in their work areas during their work shifts.

SDS 16 Section Format: Item 1, Identification

Product identifier, manufacturer/distributor name, address, phone number, emergency phone number, recommended use, restrictions on use.

SDS 16 Section Format: Item 2, Hazard Identification

Hazards regarding the chemical, required label elements.

SDS 16 Section Format: Item 3, Composition

Information on chemical ingredients, trade secret claims.

SDS 16 Section Format: Item 4, First Aid Measures

Describes symptoms/effects (acute, delayed), required treatment.

SDS 16 Section Format: Item 5, Firefighting Measures

Lists suitable extinguishing techniques, equipment, chemical hazards from a fire.

SDS 16 Section Format: Item 6, Accidental Release Measures

Lists emergency procedures, protective equipment, proper methods of containment and cleanup.

SDS 16 Section Format: Item 7, Handling and Storage

Lists precautions for safe handling and storage, includes incompatibilities.

SDS 16 Section Format: Item 8, Exposure Control

Lists OSHA permissible exposure limits, ACGIH threshold limit values, manufacturer recommended exposure limits, PPE, appropriate engineering controls.

SDS 16 Section Format: Item 9, Physical & Chemical Properties

Contains chemical characteristics.

SDS 16 Section Format: Item 10, Stability & Reactivity

Lists chemical stability and possibility of hazardous reactions.

SDS 16 Section Format: Item 11, Toxicological Information

Contains the chemical’s toxicology info.

SDS 16 Section Format: Items 12-15, Non-Mandatory

Ecological information, disposal considerations, transport information, regulatory information, other information (includes date of preparation, last revision).

HCS Program Step 5: Inform & Train Employees

Should demonstrate that a good faith effort is being made to train and inform employees about HCS requirements, hazard locations, methods of observation, safety measures, designated person to handle employee training.

HCS Program Step 6: Evaluate & Reassess Program

All documentation must be current and periodically reviewed and updated.

OSHA HCS Fines: Serious Violations

$12,471 effective 8/1/16, adjusted for inflation thereafter.

Examples of Serious SDS Violations

Failure to have/provide SDS: at time of shipment, upon request, readily and immediately accessible, emergency backup system for electronic access.

OSHA HCS Fines: Willful Violations (Maximum Penalty)

$124,709, adjusts for inflation.

Hazard

The inherent capacity of a substance to cause an adverse effect.

Toxic Substance

Any substance that can or is suspected to cause injury or illness under some conditions.

Poison

Any substance that imperils health or life when absorbed into the body.

Lethal Dose/Concentration 50%

The concentration at which 50% of test animals will be expected to die.

Minimum Lethal Dose (MLD)

The smallest dose of poison or radiation on record that produces death.

Acute Hazards

Single, brief exposure, impermanent effects, develops quickly.

Chronic Hazards

Repeated exposure, long-term effects, permanent effects, develops slowly.

Carcinogens

Substances that are known to cause cancer in humans.

Irritants

Materials that cause reversible irritating effects on the eyes, nose, or throat that temporarily impair a person’s ability to take action to cope with the situation.

Acute Toxicity

Toxic, fatal effects that result from a single dose or short exposure to a substance.

Chronic Toxicity

Adverse effects resulting from repeated doses/exposures.

Narcotic Effect

Drowsiness, lack of coordination, dizziness. feeling stoned.

Corrosives

A chemical that causes visible destruction of, or irreversible alterations in, living tissue

by chemical action at the site of contact.

Mutagens

Causes genetic mutation through the alteration of cell DNA.

Teratogen

Can cause malformations/alterations in the appearance or function of a developing embryo.

Flammables

Gases, aerosols, liquids, or solids that will burn or ignite under certain conditions.

Reactive Hazards

Uncontrolled chemical reactions that can cause damage to the human body by the release of gases that will burn, explode, or produce high pressure that can inflict injury to a person nearby.

Pyrophoric

In small amounts may spontaneously ignite within 5 minutes of contact with air or moisture.

Self-Heating

A solid or liquid chemical, other than a pyrophoric liquid or solid, which, by reaction with air and without energy supply, is liable to self-heat.

Organic Peroxides

When heated, may cause fire or explosion; may be sensitive to impact or friction, and may react dangerously with other chemicals.

Oxidizer

A chemical other than a blasting agent or explosive that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.

Chemical Name

Given in the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS).

Trade Name

The trademark name or chemical trade name for a chemical.

Fire Extinguisher Notation: 1-A:10-BC

1.25 gal. of water in a 10 sq. ft. area.

Fire Extinguisher Letters (A, B, C)

Represents the types of fire for which the extinguisher has been approved.

Fires: Classification A

For ordinary combustibles, (wood, paper, cloth, rubber, certain plastics).

Fires: Classification B

For flammable liquids.

Fires: Classification C

For energized electrical equipment.

Fires: Classification D

For combustible metals.

Fires: Classification K

For grease fires, found in industrial kitchens.

Fire Extinguisher Notation: (#)A

This number represents how much water the extinguisher is equal to, represents 1.25 gal. of water per unit.

Fire Extinguisher Notation: (#)B

This number represents the area in square feet of a fire that a non-expert user should be able to extinguish.

Fire Triangle

Heat, oxygen, fuel.

Air-Pressurized Water Extinguishers (APW)

Large, silver container designed for class A fires only. 2/3 filled with water, 1/3 pressurized air.

Dry Chemical Extinguishers (CO2)

Designed for class B and C fires, not A, filled with CO2 under extreme pressure, extinguishes fires by starving the fire of oxygen. Do not use in a confined space, may put people at risk of respiratory issues.

Multi-Purpose Dry Chemical Extinguisher

Designed for class A, B, C fires. Coats the fuel of the fire with a thin layer of fire-retardant powder, separating the fuel from oxygen and interrupts the chemical reaction. Uses compressed, non-flammable gas as a propellant.

Class K Fire Extinguisher

Comprised of dry and wet chemicals designed to put out grease fires.

Fire Extinguishers: PASS Technique

Pull, aim, squeeze, sweep.