Every environment, health, and safety (EHS) manager is faced with the daunting and tedious task of ensuring that the hazardous chemicals in their workplace are correctly classified. And, every EHS manager is aware that the correct classification of chemicals and their hazards is the first critical step in ensuring the safety of the workers who handle these substances. Today we will review the Occupational Safety and Health Administration’s (OSHA) suggestions for getting ready for a hazard classification, and tomorrow we will provide an overview of the four main steps for conducting a hazard classification.
An OSHA guidance, recently updated to incorporate the 2012 revisions to the Hazard Communication Standard (HCS), is meant to help manufacturers and importers of chemicals identify and classify chemical hazards. The guidance is also useful to employers who decide to conduct hazard classifications to assure the accuracy and completeness of information provided to them by suppliers.
Note. Only chemical manufacturers and importers are required to perform hazard classifications on the chemicals they produce or import. Employers may also choose to conduct hazard classifications if they are concerned about the adequacy of the hazard information received for the chemicals used in their business or distributed to others.
Three primary resources are required for hazard classification. These are:
- Complete, accurate, most up-to-date literature and data concerning the hazardous chemical;
- The ability to properly understand and interpret the information retrieved in order to identify and document hazards; and
- The specific criteria for each health and physical hazard class and category defined in the HCS. (29 CFR 1910.1200, Appendix A provides the classification criteria for health hazards, and 29 CFR 1910.1200, Appendix B provides the classification criteria for physical hazards.)
Is the Chemical Hazardous?
OSHA notes that the definition for “hazardous chemical” in the HCS is very broad. The standard does not require the testing of chemicals—only the collection and analysis of currently available data. However, if no data are available or if the data are questionable, testing should be considered when hazardous properties are suspected.
Under the HCS, any chemical that is classified as a physical hazard, a health hazard, a simple asphyxiant, a combustible dust, a pyrophoric gas, or a hazard not otherwise classified is considered a hazardous chemical. The HCS definitions for “physical hazard” and “health hazard” are:
- Physical hazard means a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid, or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.
- Health hazard means a chemical that is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard.
For a hazard classification process to be complete, the classifier must consider all possible hazards and should document any hazards that are identified. In conducting the hazard classification, one should be cognizant of all types of physical and health hazards to properly identify the nature and severity of the chemical’s hazards.
In addition, OSHA regulates a number of chemicals as toxic and hazardous substances, such as lead, cadmium, bloodborne pathogens, and cotton dust. These substances and their specific classification requirements are found in 29 CFR 1910 Subpart Z. Furthermore, there are certain lists that can help the classifier identify chemicals that have been deemed hazardous by nationally and internationally recognized organizations, such as the American Conference of Governmental Industrial Hygienists’ threshold limit values, the National Institute for Occupational Safety and Health recommended exposure limits, the National Toxicology Program’s Report on Carcinogens, and the International Agency for Research on Cancer.
Tomorrow we will take a look at the four main steps involved in conducting a hazard classification.