Chemical Hazard Communication, OSHA HazCom, Emergency Equipment, and Hazardous Waste – Comprehensive Study Notes (EHSS)
Environmental Health and Safety Services Overview
Syracuse University Environmental Health and Safety Services (EHSS) office overview
- Team size: comprised of about people with various specialties.
- Two main focuses mentioned: occupational health and safety (Jen and Garrett) and environmental components (environmental protection and community impact).
- Jen Brown is a colleague who helps in the office; you may interact with her or Garrett in the future.
- The office handles hazards in workplaces, including university shops where classes or builds take place (e.g., spray paints, solvents, aerosols).
- They discuss safety and environmental responsibilities across campus, including fire safety and electrical hazards via a sister department (Firebase Firelight Safety Services).
Key hazard domains handled by EHSS
- Fire hazards and electrical hazards in shop environments.
- Airborne hazards from spraying paints or sanding; exposure to fumes and general airborne contaminants.
- Large chemical exposures in the shop environment.
- Health-related concerns, including potential risks to others (e.g., infection risk as discussed in the COVID context) and gray-area campus exposure issues.
- Hazard communication for building materials (e.g., silica in concrete and other construction materials).
- Hazardous building materials and construction activities that introduce potential hazards (e.g., silica exposure, silica-related diseases like silicosis; asbestos references are mentioned as context).
- Environmental concerns including air emissions from labs and fume hoods, and campus oil spills.
- Specific hazardous building materials and construction-related hazards discussed as part of ongoing hazard assessment.
Environmental and safety responsibilities
- Environmental responsibilities include protecting the environment and the surrounding community (air emissions and waste management).
- On the environmental side, they monitor and address air emissions from lab exhausts and fume hoods (exhaust goes up stacks).
- EHSS reported about the fiscal year: approximately oil spills on campus, with required reporting to state and federal agencies (New York State Department of Environmental Conservation and the U.S. Environmental Protection Agency).
- They emphasize a collaborative approach with shop staff and other campus departments to minimize environmental impact and hazards.
- Emphasized that while the campus does contribute to emissions, the goal is to minimize those emissions as part of a comprehensive environmental program.
Hazardous materials programs and building materials
- Hazardous materials programs address hazards in different contexts (e.g., silica in concrete, PCBs, and hazardous building materials).
- Silica risk discussion includes how silica-containing materials (e.g., concrete and pottery) can contribute to respiratory hazards; silica exposure can lead to silicosis.
- The discussion also touches on other hazardous materials such as PCBs and related exposure management.
Chemical hazard communication (HazCom) and OSHA framework
- OSHA acronym stands for Occupational Safety and Health Administration (also humorously called Occupational Health and Safety Administration/Occupation Safety and Hazards Association in a light moment).
- Historical timeline:
- OSHA founded in 1970.
- The HazCom standard (chemical hazard communication) became a formal requirement in 1983.
- 2012 revisions align OSHA with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
- Further revisions occurred around 2012–2016 to harmonize with the GHS and update training expectations.
- Global harmonization: GHS standardizes chemical classification, labeling, and safety data sheet (SDS) formats across countries; this reduces country-by-country discrepancies in hazard communication.
- Program components of HazCom:
- Classification of chemical hazards (health hazards vs physical hazards).
- Labeling requirements for containers (primary container labeling) and secondary containers.
- Safety Data Sheets (SDS) with standardized 16 sections.
- Training requirements for employees and student workers who may encounter hazardous chemicals.
- Purpose of HazCom: reduce or eliminate injuries from hazardous chemicals by standardizing identification, assessment, and communication of chemical hazards.
- Health hazards vs physical hazards: definitions are provided in context; health hazards affect human health (inhalation, dermal, etc.), physical hazards involve flammability, reactivity, etc.
Roles and responsibilities under HazCom
- Manufacturer responsibilities (chemical producers) include:
- Classifying chemicals according to GHS.
- Putting labels on containers with product identifiers, signal words, hazard statements, precautionary statements, and pictograms.
- Providing Safety Data Sheets (SDS) with standardized sections and hazard information.
- Providing information on hazard mitigation and appropriate protective measures (e.g., ventilation, respirators).
- Maintaining an inventory of hazardous chemicals.
- Ensuring that relabeling is done if chemicals are placed in secondary containers.
- University (employer) responsibilities include:
- Relabeling when chemicals are transferred to secondary containers with the product name and hazard information.
- Keeping an up-to-date HazCom program and making SDSs readily available to employees and students in the shops.
- Maintaining an inventory of chemicals and ensuring easy access to hazard information.
- Providing hazard mitigation procedures and training.
- Hazard communication training resources
- An online HazCom training resource is available on the department’s website (about minutes; humor noted as “30 minutes of pure bliss”).
- The university encourages staff and students to review the online HazCom training as a reference point alongside in-person training.
Chemical labeling and pictograms under GHS
- Labels must include:
- Product identifier (name of the chemical).
- Signal word: either or ; Danger indicates greater severity, Warning indicates lesser severity.
- Hazard statements (about hazards associated with the chemical).
- Precautionary statements (recommended protective actions and handling measures).
- Pictograms (9 standard hazard pictograms) with a diamond shape, red border, white background, and black symbol.
- Hazard statements (roughly ) and precautionary statements (roughly ) provide comprehensive hazard communication information.
- Example labeling considerations: pre-labeled containers supplied by manufacturers; if transferring to a secondary container, best practice is to label with at least the product name and hazard information; shops may use pre-labeled bottles for convenience.
- Example discussed in class: a Bayer paint product with a standard label showing signal word, hazard statements, precautionary statements, and pictograms; the presence of health and physical hazard pictograms is typical.
- In practice, if you transfer a chemical to a secondary container, the label should reflect at minimum the material name; comprehensive labeling is preferred to ensure safety and compliance.
Safety Data Sheets (SDS)
- SDSs are prepared by the manufacturer and are intended to be reviewed before use.
- SDSs must be readily available in the workplace; in shops, SDSs are kept in a red binder for easy access.
- SDS structure: 16 sections (1–16) with information about identification, hazards, composition, first aid measures, fire fighting measures, accidental release measures, handling and storage, exposure controls/personal protection, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal considerations, transport information, regulatory information, and other information.
- You do not need to memorize all 16 sections; they are reference material. Training and practical use focus on understanding the hazard information and how to protect yourself.
- The shop and EHSS team may help interpret SDS information and determine appropriate controls.
How to detect and manage hazards in the shop
- Hazards can be detected via product labels, SDS information, and on-site hazard assessments.
- Workplace training is provided to discuss hazards associated with specific tasks and products.
- Local supervision (shop head) and EHSS staff are key resources for hazard information and mitigation strategies.
- Emphasis on recognizing potential hazard signs, reading labels, and consulting SDS before using a chemical.
- Visual observations and listening for unusual odors or signals during work are important for hazard detection.
Hazard communication in practice: example and training resources
- The HazCom training is complemented by an online module (approximately minutes) that provides context and compliance guidance.
- The program emphasizes using engineering controls first (e.g., ventilation, spray booths) and substitution where feasible, followed by administrative controls and PPE as a last resort.
- When in doubt about a chemical or procedure, ask the shop supervisor or EHSS staff rather than assuming.
Understanding what constitutes a hazardous chemical vs hazardous waste
- Hazardous chemical: a chemical that poses a threat to health or physical safety (as defined by OSHA).
- Hazardous waste: a chemical product that, when disposed of, possesses certain properties that can harm health or the environment. There are two ways wastes become hazardous:
- Listed hazardous waste: materials that appear on the EPA’s list of hazardous wastes and require specific disposal management.
- Characteristic hazardous waste: wastes that possess certain properties (ignitability, corrosivity, reactivity, toxicity) that make them hazardous regardless of listing.
- Key characteristics used to classify hazardous waste:
- Ignitable: often liquids with a flash point < 140^{\circ}\mathrm{F} (the temperature at which vapor may ignite).
- A common point: flash point indicates the temperature at which vapors can ignite; this information is also found on the SDS.
- Corrosive: liquids with a pH or .
- pH scale ranges from ; 7 is neutral (like water).
- Reactive: chemicals that can vigorously react or explode under certain conditions.
- Toxicity: substances that can cause toxic effects; heavy metals (arsenic, barium, cadmium, chromium, lead, mercury, silver, selenium) are specifically noted as hazardous if disposed of improperly.
- Heavy metals list consequence: disposal of heavy metals requires special handling and is not allowed to be dumped down drains or into regular trash.
- The difference between listed and characteristic wastes affects how they are stored and disposed of.
Hazardous waste management and satellite accumulation areas (SAA)
- Definition of hazardous waste: any chemical product or waste that, due to its properties, can harm health or the environment.
- Satellite accumulation areas (SAA): areas near where waste is generated that allow accumulation of hazardous waste before it is transferred to a central accumulation point for disposal.
- Each SAA should have two signs that summarize labeling, spill procedures, and basic waste handling information.
- Waste containers in SAAs must be:
- Compatible with the waste material (material compatibility).
- Contained within secondary containment to manage spills.
- Labeled properly with the hazard contents.
- Sealed properly to prevent leaks.
- Pre-labeled containers: some containers and drums come pre-labeled for the waste (e.g., pre-labeled waste paints or aerosol cans).
- Aerosol cans: must be placed in the hazardous waste container; cannot be disposed of in regular trash—even when empty.
- Rags and debris contaminated with solvents or oils may be stored in dedicated containers labeled for solvent-contaminated waste.
- Waste disposal process: when a waste container is full, a service request is submitted to EHSS for pickup and disposal.
- If a waste is not part of the listed or characteristic categories, white labels are provided for organization and disposal points.
- The importance of asking questions: always verify waste status with shop staff or EHSS when unsure whether something is hazardous waste.
Eye wash and safety shower (emergency wash equipment)
- There is a dedicated demonstration video describing the emergency wash equipment available in campus facilities:
- Types: eyewash stations and safety showers.
- Function: designed to deliver water at about with hands-free operation.
- Flow: eyewash typically provides a substantial flow (the demonstration notes a rapid flush) and showers provide a larger flow to cover larger body areas.
- Operational details:
- Activate eyewash by engaging the control lever; position eyes under the stream and flush for at least while others call for help.
- For full-body exposure, activate the safety shower by pulling the lever; remove contaminated clothing and continue flushing for at least .
- After activation, a silent alarm notifies the Department of Public Safety (DPS) and safety personnel; an incident report is required after the event.
- Responders (supervisor and safety manager) secure the area and arrange for contaminated clothing to be collected and replaced.
- Post-incident requirements and maintenance:
- Pathways to the equipment must be kept clear (minimum of around the equipment).
- Eye washes are tested weekly by area personnel to verify proper function; showers are tested by dedicated facilities personnel.
- If the equipment is damaged or not functioning, contact EHSS immediately for repair.
- Practical tips:
- Location awareness is critical (where are the eyewash and shower sites in your shop or classroom?).
- Know how to operate the equipment and the criteria for its use (e.g., eye exposure, skin splash, etc.).
- Always wear appropriate PPE to minimize chemical exposure and be ready to move to the wash if needed.
Emergency notifications and safety culture
- Department of Public Safety is the primary contact for emergencies; the campus also promotes using the Orange Safe app to connect with safety resources and DPS.
- In a chemical exposure incident, it is critical to notify a supervisor and EHSS as well as DPS.
Practical implications and takeaways for students and staff
- Always ask questions if you’re unsure about a chemical’s hazards or proper handling; do not assume.
- Read the SDS before using a chemical and know where to locate the red SDS binder in your shop.
- If you have a chemical sensitivity or allergy, discuss it with the shop supervisor so they can review the SDS and determine safe alternatives or handling measures.
- Regularly check labeling on containers and ensure secondary container labels correctly reflect the product name and hazard information when transferring.
- Be aware of environmental responsibilities (e.g., oil spills reporting) and the need to minimize emissions and environmental impact in activities conducted in the shops or labs.
Summary of key regulatory and practical terms
- OSHA: Occupational Safety and Health Administration; HazCom standard (chemical hazard communication) established in , later aligned with GHS in with updates to HazCom training requirements.
- GHS: Globally Harmonized System for classification and labeling of chemicals; standardizes hazard communication globally.
- Hazard communication components: hazard classification, labeling, SDS, training.
- Hazard classes:
- Health hazards (e.g., toxic effects, irritants, carcinogens).
- Physical hazards (e.g., flammables, oxidizers, reactive materials).
- Label components: product identifier, signal word (Danger/Warning), hazard statements, precautionary statements, pictograms.
- Pictograms: 9 standard pictograms; diamond shape; red border; white background; black symbol.
- SDS: 16 sections; used to communicate hazard information; not required to memorize all sections, but understand where to find critical data.
- Hazardous waste vs hazardous chemical:
- Hazardous chemical: a substance with health or safety hazards.
- Hazardous waste: waste that has properties (listed or characteristic) that make it hazardous upon disposal (e.g., ignitable, corrosive, reactive, toxic).
- Waste management concepts:
- Listed wastes: materials on the EPA list of hazardous wastes.
- Characteristic wastes: ignitable (flash point < 140^{\circ}\mathrm{F}), corrosive (pH or ), reactive, toxic.
- Heavy metals (e.g., arsenic, cadmium, chromium, lead, mercury) require special disposal handling.
- Aerosol cans and other containers should be disposed of in the appropriate hazardous waste container, not in regular trash.
- Satellite accumulation areas (SAA): areas near the point of generation where waste is stored prior to final disposal; must be clearly labeled and maintained with secondary containment.
- Practical disposal guidance:
- Containers must be closed, compatible with contents, and free of cracks.
- Labeling of waste containers is required, with some pre-labeled options available on campus.
- Waste pickup requests are initiated via EHSS service requests when containers are full.
Final safety mindset for students and staff
- The overall goal is to minimize exposure to hazardous chemicals and reduce injuries through standardized hazard communication, proper labeling, accessible SDSs, and proper waste management.
- Always use the available emergency equipment appropriately and know when to use it.
- Maintain a culture of safety by asking questions, using available resources (shops’ red SDS binder, HazCom online training), and following proper procedures for labeling, storage, and disposal of hazardous materials.