This month’s Q&A corner focuses on questions regarding Hazard Communication and the new Respirable Crystalline Silica standard.
Hazard Communication Q: How often do we need to do Haz Com training?
A: Haz com training is required:
At the time of their initial assignment, and
Whenever a new hazard is introduced into their work area.
NOTE: Some companies provide refresher training annually as a best practice.
Q: Does HazCom training only cover chemical hazards?
A: No. HazCom training covers any physical and health hazard in a work area. Due to labeling requirements, we tend to get conditioned to think that HazCom only applies to the chemicals in our work areas.
Q: Is combustible dust a hazard that we need to train on?
A: Combustible dust is identified as a physical hazard, and if present in your facility you will need to train on combustible dust hazards.
Q: Do you need to keep SDSs for commercial products such as "Windex" and "White-Out"?
A: OSHA does not require that SDSs be provided to purchasers of household consumer products when the products are “used in the workplace in the same manner that a consumer would use them.” [i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience].
This exemption in OSHA's regulation is based, however, “not upon the chemical manufacturer's intended use of his product, but upon how it actually is used in the workplace.” Employees who are required to work with hazardous chemicals in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience would need to be trained in those hazards.
For example, if a manufacturer uses Windex to clean stainless steel panels all day long, this could be considered as a duration and frequency condition (exposure) much greater than the average home owner (consumer). As a result, companies would need to have the SDS for Windex, and train their employees on its hazards.
Q: What about janitorial use of chemicals?
A: Janitorial use of chemicals is not considered to be the same duration and frequency of exposure scenario as a consumer (home owner). Janitors use the chemicals during extended periods and likely have a higher exposure. Chemical SDSs used for janitorial purposes should be maintained at the facility by the employer in charge of the janitorial services.
Information on interpretations of OSHA’s hazard communication standard can be found here.
Q: What kinds of operations present a crystalline silica hazard?
A: According to OSHA, industries and operations in which exposure to crystalline silica can occur include, but are not limited to:
Structural clay products
Paintings and coatings
Cut stone and stone products
Refractory installation and repair
Railroad track maintenance
Hydraulic fracturing for gas and oil
Abrasive blasting in
Q: What is the Silica Compliance Schedule?
A: The final rule took effect on June 23, 2016. Industries have 1 to 5 years to comply with most requirements, based on the following schedules:
Construction - June 23, 2017, one year after the effective date.
General Industry and Maritime - June 23, 2018, two years after the effective date.
Hydraulic Fracturing - June 23, 2018, two years after the effective date for all provisions except Engineering Controls, which have a compliance date of June 23, 2021.
Information on OSHA’s Silica rule can be found here.
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