By Arianne Corbett, RD 2013-12-30 15:56:26
Chemical Compliance Make sure your employees understand new OSHA-required reference materials for safe chemicals handling. As a 15-year-old hotel dishwasher, Jon Dickl, MBA, SNS (now child nutrition director for Tennessee’s Knox County Schools) learned a hard lesson about why you must understand the hazards of every chemical you work with. “One night, I was closing the dish area and the floors were filthy,” he remembers. In an attempt to clean them, Dickl poured bleach into a mop bucket already containing an ammonia-based floor cleaner. “It started bubbling up and putting off smoke. It was poisonous gas!” he exclaims. “We all ran out of the kitchen. If we had been in a closed environment, that mistake could have been deadly!” Foodservice staff training regarding hazard safety has come a long way since then, but this chain of events still could happen in any kitchen, anywhere. This frightening tale illustrates the importance of understanding the labeling and critical safety information of the chemicals and other hazardous materials school nutrition professionals use every day. A recent update to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard now is being implemented to improve the quality and consistency of hazard information, making it safer for employees to do their jobs and avoid dangerous incidents. What You Need to Know OSHA’s Hazard Communication Standard features two key changes: the use of new labeling elements and a standardized format for Safety Data Sheets (SDS), which will replace Material Safety Data Sheets (MSDS). The new label and Safety Data Sheet requirements have been designed to improve worker understanding of the hazards associated with the chemicals in their workplace. To help employers comply with the revised standard, OSHA is phasing in the requirements over several years (December 1, 2013 through June 1, 2016). Did you meet the first regulatory deadline last month? Safety Data Sheets Safety Data Sheets are documents that describe the safe use, storage and handling of chemical products. These sheets contain significantly more information than the labels on the product containers. An SDS most importantly contains emergency procedures, such as what to expect if usage recommendations are not followed, what to do if accidents occur and how to recognize symptoms of overexposure. A complete cafeteria health and safety program must include training on the SDSs for all chemical products used in the operation, and staff must have easy access to them at all times. By June 1, 2015, manufacturers must begin using the new, improved Safety Data Sheet format, which contains 16 sections to cover everything staff needs to know about the proper handling of a hazardous chemical product. The new uniform design is expected to help manufacturers organize SDS details and make the information easier for the reader to find. The information in the new sections must be provided in this standard format for all chemical products. Following is what you can expect to see: • Section 1: Identification—includes the product identifier, the manufacturer’s or distributor’s name, address and phone number, an emergency phone number, recommended use for the product and restrictions on use. • Section 2: Hazard(s) Identification— includes all hazards regarding the chemical and required label elements. • Section 3: Composition/Information on Ingredients—includes chemical ingredients and trade secret claims. • Section 4: First-aid Measures— defines important symptoms/effects related to exposure, both acute and delayed, and the required treatment. • Section 5: Fire-fighting Measures— lists suitable extinguishing techniques, equipment and chemical hazards from fire. • Section 6: Accidental Release Measures—details emergency procedures, protective equipment and proper methods of containment and cleanup. • Section 7: Handling and Storage— lists precautions for safe handling and storage, including incompatibilities. • Section 8: Exposure Controls/ Personal Protection—details OSHA’s Permissible Exposure Limits (PELs), Threshold Limit Values (TLVs), appropriate engineering controls and required/recommended personal protective equipment (PPE) as related to the product. • Section 9: Physical and Chemical Properties—defines the chemical’s characteristics. • Section 10: Stability and Reactivity— lists the product’s chemical stability and the possibility of hazardous reactions. • Section 11: Toxicological Information— includes all possible routes of exposure to the product, related symptoms, acute and chronic effects and numerical measures of toxicity. • Section 12: Ecological Information (non-mandatory)—details information on the potential environmental impact if the chemical(s) were released. • Section 13: Disposal Considerations (non-mandatory)—provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, as well as safe handling practices. • Section 14: Transport Information (non-mandatory)—provides guidance on classification information for shipping and transporting of the hazardous chemical(s) by road, air, rail or sea. • Section 15: Regulatory Information (non-mandatory)—identifies the safety, health and environmental regulations specific for the product that are not indicated anywhere else on the SDS. • Section 16: Other Information— includes the date of preparation of the SDS or the most recent revision. Hazard Communication Standard Labels As noted at the start of this article, in addition to changes in the SDS, OSHA also has updated the labeling requirements of hazardous chemicals. Thus, also by June 1, 2015, all chemical product labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier and supplier identification. Supplemental information also can be provided on the label as needed. The pictograms used on labels are intended to alert all users—regardless of literacy skills—of the potential chemical hazards to which they may be exposed. Each pictogram has a symbol on a white background framed within a red border and represents a distinct hazard. OSHA has designated eight different pictograms. New Training Requirements The deadline has come and gone for all employers using hazardous chemicals to have trained their staff on the new label elements and the SDS format. Although the new labeling and reference materials are not required for another 18 months, the December 1, 2013, training deadline was scheduled early in the transition process, so that employees are familiar with the new SDS reference and product labels throughout the implementation period. After all, some manufacturers will opt to make the transition immediately, rather than waiting until the implementation deadline. So, your team members may be exposed to both old and new formats. You don’t want to risk that employees don’t know how to review critical information to protect themselves. If you were unaware of these new training requirements, missed the deadline or just want to be sure you thoroughly covered all areas with your team, review the following training topics. New Label. Explain the type of information an employee should expect to see on the new labels. Review how she or he might use the labels in the workplace. For example, the label can be used to ensure proper storage of hazardous chemicals or how to quickly locate first aid information. Provide a general understanding of how the elements work together on the label. For instance, you can demonstrate that when a chemical has multiple hazards, different pictograms are used to identily the various hazards. Safety Data Sheets (SDS). Start by reviewing the 16 standard sections. For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) always will contain information about exposure limits, engineering controls and ways to protect yourself. General Training Considerations. OSHA requires employers to present information in a manner and language that employees can understand. For example, if you typically communicate workplace information to employees in a language other than English, you will need to provide this training in the same manner. By the same token, if you know or suspect that employees are not literate, instructing them to read the training materials will not satisfy your training obligation as an employer. Note that OSHA makes Spanish language materials available for training and to display in kitchens and other work areas. Make Training Fun and Engaging. John Dickl recalls one innovative chemical safety session provided by a local cooperative extension program. “They brought in small bags filled with different types of white powder, all of which could be found in the kitchen—items like baking soda, dish detergent, flour and cornstarch. Trainees played a guessing game in an attempt to identify the substances.” This simple activity can be a great demonstration of the importance of labeling. After all, while they look similar, you would not want to confuse baking powder and dish detergent! Safety First Training that is engaging usually is training that is effective. And when it comes to chemical hazards training, you never want to lose sight of the goal: ensuring your safety and that of those around you. The Center of Excellence for Food Safety Research in Child Nutrition Programs at Kansas State University recently completed some audits regarding HACCP Standard Operating Procedures. Researchers found that 85% of schools audited provided training employees on the proper use of chemicals. While that’s a laudable number, it should be 100%! Arianne Corbett is managing director of Leading Health, LLC, in Arlington, Va., and a former manager of nutrition advocacy at SNA. For More Information • OSHA’s Hazard Communication website http://tinyurl.com/hazardcommunication • OSHA Fact Sheet: December 1, 2013 Training Requirements for the Revised Hazard Communication Standard http://tinyurl.com/trainingfactsheet QuickCards and OSHA Briefs (to assist employers with the required training): • OSHA Brief: Hazard Communication Standard: Labels and Pictograms http://tinyurl.com/labelsandpictograms • OSHA Quick Card: Hazard Communication Standard Labels http://tinyurl.com/hazcommlabels • OSHA Quick Card: Hazard Communication Standard Pictogram http://tinyurl.com/hazcommpictogram • OSHA Brief: Hazard Communication Standard: Safety Data Sheets http://tinyurl.com/sdsbrief • OSHA Quick Card: Hazard Communication Safety Data Sheets http://tinyurl.com/sdscard
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