Proper management of hazardous chemicals is often overlooked by team members while management assumes proper information on the hazards was communicated. Facilities must pay attention to managing hazardous chemicals and management must afford the necessary resources. The Occupational Safety and Health Administration (OSHA) has specific requirements for handling Hazardous Materials in Subpart H-Hazardous Materials 29 CFR 1910.101-1910.126. OSHA Hazardous Materials is a subset of the OSHA Hazardous Chemicals as defined in Subpart Z-Toxic and Hazardous Substances 1910.1200. Below is a brief discussion of the regulatory aspects and hazardous chemicals.
Why Focus on Hazardous Chemicals?
OSHA Serious Violations for General Industry included three hazardous chemical-related citations. The number one cited serious violation was lack of a written Hazard Communication Program, the number three cited serious violation was lack of information and training and number six was due to improper management of Safety Data Sheets (SDS) as presented in the table below. In total these three categories accounted for 41.9% of the top 10 cited serious violations.
Most Frequently Cited Hazardous Chemical Serious Violations in General Industry 2019
Hazard Communication – Written Program
Hazard Communication – Information & Training
Hazard Communication – Maintain Copies of SDS
However, Hazardous Material citations were not in the 10 most cited in 2019. The top five serious violations for Hazardous Materials are shown in the table below:
Hazardous Materials [1910.101-.126] 2019
Compressed Gases-Handling Storage and Use
Flammable Liquids-Shall not be Dispensed Unless Bonded & Grounded
PSM Written Procedures
Flammable Liquids-Prevent the Ignition of Flammable Vapors
PSM-Employer Shall Document the Equipment
What is a Hazardous Chemical?
OSHA defines a Hazardous Chemical as: any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. The hazards for a chemical are found on the SDS. The hazards and amounts of hazardous chemicals often are necessary for Tier 2 reporting along with other Environmental Protection Agency (EPA) reporting, therefore proper management of the SDS data set is necessary for reporting purposes and lack of proper SDS is often identified as a Serious Violation.
OSHA organizes hazardous chemicals for General Industry into 11 familial categories for addressing operations. There are several more that are industry specific and will not be discussed. In general, one can view the 11 familial categories as an increasing progression of compliance complexity with Process Safety Management (PSM) of highly hazardous chemicals the most complex. Some state programs have lower threshold quantities for some highly hazardous chemicals, for example California uses a 500-pound threshold as opposed to a 10,000-pound threshold for ammonia. Threshold quantities for Highly Hazardous Chemicals are listed in Subpart H-Hazardous Materials 29 CFR 1910.119 Appendix A.
General Chemical Specific Information
The SDS is the best source for chemical hazard information. It should be noted that SDS’s are often updated to include newly identified hazards and or physical chemical properties, e.g. vapor pressure, Permissible Exposure Limits, etc. Periodically checking SDS’s for updates is suggested by looking at the issue dates and whether there are any update dates. Careful management of SDS’s is necessary to properly account for hazardous chemicals. Successful management of hazardous chemicals avoids many difficult facility situations including, spills, injuries from spills, lost time, and penalties. Successful management includes a written Hazard Communication Program, Hazard Communication and Training, and maintaining the SDS.
A successful hazardous chemical management program must start with the SDS which is the foundational piece of information. The program must then include following:
OSHA requirements including a written Hazardous Chemical Program,
Information and Training,
Management of the SDS,
Determining whether the chemical is also a Hazardous Material
Hazardous Chemicals are defined in 29 CFR 1910.1200, can further be defined as a Hazardous Material as defined in 29 CFR 1910.101-119 and could also be defined as a Highly Hazardous Chemical as listed in 29 CFR 1910.119 Appendix A. A general decision approach is presented on the next page A webinar will go into more details on management of hazardous chemicals, understanding the definitions for each, regulations, as well as industry standards, and good engineering practice based on industry experience.