Regulatory Issues: HazCom 2012 Training for Mushroom Industry
One of the things we see every day in the [mushroom] industry is change. From time to time, we change tools, or team members, or even the way we do things. Most times, these changes are small adjustments. But they all usually happen for the same reason. We’re looking for a better way to meet our goals, whatever those goals may be.
Today we’re going to talk about some of the most important changes ever to come to your business. And this change is all about making your workplace safer, and to improve our impact on the environment.
Under the Right-To-Know law, your employer is required to provide you with access to this information, and they most certainly understand the importance and value in teaching you these new regulations. The material presented here is so important that your supervisors are paying you to attend this training session. You have an obligation to them, and to yourself, to pay attention and learn this material. Your safety and the safety of others depend upon it!
The Occupational Safety and Health Administration, or OSHA, is a government agency that’s designed to look out for your safety at work. It’s their job to examine and correct work rules and situations for your benefit.
As part of their new Hazard Communications or HazCom 2012 rules, OSHA has begun the process to update the way that workers like you learn about the chemicals including pesticide materials you handle every day. The changes being made are basic. In fact, the goal of the change is to make all that information even easier to understand by using one standard set of graphics, labels and forms.
The first of these changes is to update and simplify the graphics used to quickly identify potential hazards. These are also called pictograms. Let’s take a look at these pictograms that you may see on a new SDS or product label.
This graphic [AG1]for Health Hazards lets you know that this product can make you very sick if you inhale or swallow this chemical. It can damage your heart or lungs, even harm your internal organs or cause long term negative health effects.
This flame graphic should be obvious. It means this chemical can be flammable, or become flammable when reacting to other chemicals. Perhaps it can self combust, or give off flammable fumes or gases.
The pictogram of an exclamation point also alerts you to health hazards. It means this particular product can irritate your skin or eyes; it could have narcotic effects, or could irritate your ability to breathe.
A gas cylinder pictogram tells you that this product is stored and distributed as a gas under pressure. You’ll see this on items like oxygen or helium tanks, for example.
Flames over a circle indicates that this product is known as an oxidizer; a chemical that can quickly cause reactions with other chemicals.
A graphic showing corrosion should tell you that this product is very hazardous, as it can create severe damage to skin, or other materials such as plastic or metal.
The skull and crossbones pictogram is also an obvious one. This product can make you very sick, and could even cause death. This is a product to be used extremely carefully, and with all proper actions.
This graphic represents an exploding bomb, and should indicate to you that the product being described can explode, or be self-reactive. It should only be used or stored correctly, according to directions.
A pictogram showing the upside down fish tells you that the product is hazardous to organisms in the water, [AG2]and should be used cautiously in areas near bodies of water, and should never be disposed of in those areas.
These pictograms are not meant to provide in-depth information, but simply designed to make you aware of immediate concerns at a glance so that you may be prepared to use the product responsibly. If you require more detailed information, you’ll want to refer to the Safety Data Sheet for that information.
As always, if you ever have concerns or questions about information you’ve read, or you simply can’t understand the information provided, make sure to check with a supervisor. They can help you with proper procedures and responses.
Another significant change you’ll come across with the new OSHA regulations is the new consistent look to labels on hazardous chemical or material packages.
Like the SDS, these changes are also being made to create a standard look, in order to reduce confusion or difficulty in learning about the product.
In the top left, you’ll find the product name and code provided by the manufacturer; these are referred to as the product identifier.
Beneath that, you’ll find the supplier identification information. The company name, address, and emergency phone number are right there for instant access, in case you have a question about the product, if someone has been exposed to the product or there is an emergency situation with the product involved so you can get answers quickly.
To the right, you can easily see the OSHA-assigned hazard pictograms and signal words related to the product. These are the same pictograms and signal words we’ve discussed earlier.
Keep in mind, that with pesticide products, you’ll want to review the existing MSDS for more detailed signal words specifically assigned by Environmental Protection Agency and the Federal Insecticide Fungicide and Rodenticide Act.
Halfway down the right side, hazard statements provide further information about any concerns you need to consider when using the product so you can take precautions to avoid potential problems. For example, should you wear gloves when handling the product? Does it need to be stored in a special way, or kept away from an open flame, or even something that may just cause a spark?
The lower left side of the label is used for the related precautionary statements. These can include handling and storage concerns, the need for PPE and other necessary personal rules you may wish to follow like washing after usage and disposal requirements. This area will also point out what to do in case of fire involving this product, as well as first aid directions for those who may have been exposed.
The lower right is reserved for supplemental information. That is, any additional information that the user may need to know before handling the product.
These label changes should be the same as what you see on the SDS, but the SDS will have more complete and more specific information. All of the changes being made, in the pictograms, in the SDS, and on the label are being made so it is easier to find the information you need to make your job safer and easier to accomplish more carefully. This is why it is important for you to read, understand and follow this information whenever you are using anything that is considered a hazardous material.
In the past, many of you have seen or worked with the MSDS, or Material Safety Data Sheets, in order to learn more about a particular chemical or material you were working with.
You may even have noticed that the MSDS forms from one company often looked different from and MSDS from another company. Individual manufacturers or distributors might each have a different type of form or sheet, and this could sometimes make it confusing to find specific information you might need.
The other change in OSHA’s new HazCom 2012 regulations is to make all of these forms now look the same, each with sixteen specific sections that will be similar in the way the information appears for all chemicals and materials. That way, every time you need information, you can find it on what will be called the Safety Data Sheet or SDS. [AG3] However, one important point you need to understand, is that the EPA, which regulates the use and sale of pesticides, has not incorporated these changes into the laws that regulate pesticides under FIFRA. In other words, even with these new SDS forms on hand; to meet the EPA rules that govern pesticides you will need to keep both the old MSDS sheets and the new SDS forms [AG4]on file. These exceptions will be made clearer as you work with them more often.
Right now, let’s take a look at what information you will find in each of the sixteen sections of the new SDS forms, and see the changes that have been made.
Section one – Product and company Identification. This is simply the basic product name and where you got it from. It should tell you the name of the material as it is shown on the label, along with recommendations or restrictions on how it should be used. You should also be able to find out who supplied the product, including all contact information like company name, address and phone number. In addition, there will be a 24/7 emergency phone number in case of spills or other accidents.
Nothing is more important than being able to accurately identify a product, how it should be used safely, and contact information for the supplier and in case of emergencies.
Section two – Hazards Identification. This section lets you know about any possible hazards that the chemical or mixture may have. One of the main reasons for checking the SDS is to find out how hazardous a product may be. This section shows you what hazards you need to be aware of. One item is the hazard classification – this will tell you if the material is flammable or reacts to other chemicals; can it damage your skin, eyes or even your ability to breathe clearly? Can it make you sick or cause long-term negative health effects? Even whether it is hazardous for plants or animals in a water environment like a pond or the ocean.
Section two will also provide any signal words you need to know; as well as the pictograms we discussed earlier, like a flame, or skull and crossbones. It will also cover any other possible hazards not mentioned elsewhere. Again, learning about the hazards of a particular chemical or materials are one of the main reasons for checking an SDS in the first place.
Section two gives you that information.
This is one area that may be confusing if you are working with pesticide products. Based on current EPA rules, pesticide products will still use one of four signal words, Danger Poison with a skull and crossbones, Warning, or Caution and also the word Danger if the product is a skin and/or eye irritant. On the new SDS format, materials will only have either a Danger or a Warning signal word. Make sure to review the existing MSDS if you have any ongoing concerns.
Section three – Composition/Information on ingredients. This is essentially the chemical recipe for the product you’re looking at. What are the chemical names, or even common names used for the ingredients? There should be a Chemical Abstract Service, or CAS, number along with any other information that might normally be used to tell you what it is. Anything, or any ingredient, that is used to create this particular product should be listed here, especially those that could make you sick.
Section four – first aid measures. Just like the old MSDS, this is where you’ll learn what to do in case you’ve been exposed, or you know of someone else who’s been exposed to this particular product. Knowing proper first aid procedures for a chemical exposure can be critical. Responding quickly and properly makes all the difference.
Section five – Firefighting measures. Some substances can cause fires when used or stored improperly. This section describes the best way to handle those fires; is it safe to use water? Are there hazardous fumes to be aware of? What Personal Protective Equipment or PPE should be used when fighting a fire with this material? What procedures should be followed; and who needs to be contacted?
Section six – Accidental Release measures. Occasionally, a chemical or product gets spilled or applied somewhere it shouldn’t be. This section explains the best procedures and materials to use in responding to such an event. You can learn whether PPE is required, and what steps should be taken to avoid environmental damage.
Section seven – Handling and Storage. Even when a particular chemical or product is not being used, it needs to be taken care of properly. Handling and storing products are often the first line of defense in preventing accidental exposures. This section provides the details you need in meeting the requirements.
Section eight – Exposure Controls and Personal Protection. This section is critical because it will explain to you how to protect yourself from unnecessary exposures. You’ll learn about the amount of material you can be exposed to during an eight hour period, called the permissible exposure limit, or the threshold limit value. Additional restrictions regarding short-term exposure limits and materials that can be immediately dangerous to life and health are covered here. There is even information directing you in how to control exposure with precautions like PPE, ventilation and enclosure, or even ways to replace a toxic substance with one that may be less hazardous.
Section nine – Physical and Chemical properties. Here’s where you can learn more of what the actual chemical is like. What does it look like? What color is it? Does it have an odor? Is it a solid or liquid or gas? Will it melt? Or freeze? How hot can it be before it catches fire? Many of the important details used to describe the actual product are found in section nine.
Section ten – Stability and Reactivity. It’s very important to know how a particular chemical or product will behave when it comes into contact with air or water or other substances that might make it hazardous for you to be around. This section will explain the types of conditions or situations to avoid, or other materials that should be used near the product on the SDS. Make sure you know when and how its best to use the product by checking here.
Section eleven – Toxicological Information. The biggest concern workers have about any chemical or materials used is the possible health effects it may have. Section eleven offers the all the possible effects from how it can be absorbed into your body as well as symptoms of exposure, and what health effects can take place with short and long term exposure.
Section twelve – Ecological information. Just the same way that these products can have negative effects on the human body, they can also do great damage to the environment.
You can learn more here about what happens if this product is spilled on the ground, or in the water. How will it affect plants, the soil, or animals that may get exposed through these accidents?
Section thirteen – Disposal Considerations. Like most products you work with every day, once you’ve finished using it, there may be residue left over, or product packaging that requires throwing away. But in order to do this properly, you need to know how.
This section of the SDS will tell you how to clean it all up.
Section fourteen – Transport Information. Sometimes it becomes necessary to ship or travel with these products. You need to know how to do this safely, without endangering those who may be in the same vehicle as well as any environmental concerns along the travel route.
Sections fifteen and sixteen – Regulatory and Other information.
Pesticides are regulated by the Environmental Protection Agency (EPA) and therefore are subject to certain labeling requirements under the federal pesticide law known as FIFRA.
These requirements are different from the classification criteria and hazard information required for Safety Data Sheets, and for workplace labels of non-pesticide chemicals.
Information regarding any differences that are required under FIFRA that are not found on the SDS or conflict with information on the SDS will appear in these sections.
For example, signal words that are required on the pesticide label (Danger Poison with the Skull and Cross bones, Warning, Caution or Danger) may be different than what appears on the product SDS under the OSHA requirements that only list either Danger or Warning as a signal word. Once again, in cases of confusion regarding a pesticide product, make sure to carefully review the existing MSDS as well as the new SDS for complete details, or contact your supervisor for further information.
Using an SDS should be a part of your regular routine when working with chemicals or other materials that may be hazardous to you or others you work with. This should be your regular practice when working with a product for the first time. The more you know about these substances, the safer you will be.
Manufacturers will be changing over to the new SDS format over the next couple of years, When new chemicals or pesticides are purchased a new SDS should be requested from the company that sells you the product.
For pesticide products, employers must be sure to review the differences between existing MSDS and new SDS. When those differences exist, both the old and new sheets need to be maintained in order to remain in compliance. And again, if there are ever any questions or confusion about the information you see or read on an SDS, make sure you check with your supervisor in order to make the right decisions.
Once more, if you ever have concerns or questions about information you’ve read, or you simply can’t understand the information provided, make sure to check with a supervisor. They can help you with proper procedures and responses.
Work smarter. Work safer. Thanks for your attention today… [AG1]Should we reference Pictogram (versus interchanging between graphic and Pictogram)
throughout these next couple lines for clarity? I vote yes [AG2]Maybe change to “organisms in the water” [AG3]Redundant with previous sentence [AG4]If saying “both”, should we include both MSDS sheets and new SDS forms?