Recently I was working on updating our respiratory program, and training that both the employee and supervisor could easily understand and still meet OSHA 1910.134. How fortunate that on February 12, 2011 the DOL came out with a new training video.

The 33-minute video explains the major components of a respiratory protection program including fit-testing, medical evaluations, training, and maintenance. The video also discusses the difference between respirators and surgical masks, and features a segment on common respiratory hazards found in healthcare settings, including airborne infectious agents that cause diseases such as tuberculosis, pandemic influenza, severe acute respiratory syndrome (SARS), chicken pox, and measles.

Demonstrations also show how respirator use helps protect workers from exposure to airborne chemical hazards such as formaldehyde and glutaraldehyde, which are used commonly in hospital laboratories to preserve tissue samples for medical analysis. These toxic substances can cause eye and nasal irritation, headaches, asthma, and other symptoms. Additionally, formaldehyde is a carcinogen and has been linked to nasal and lung cancer, with possible links to brain cancer and leukemia.

“Employers can’t rely on respirators providing the expected protection if they don’t train their workers on how to use them properly,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “This video is an important training tool that teaches proper respirator use and discusses employers’ responsibilities under OSHA’s respiratory protection standard.”

Intended for both employers and employees, the 33-minute video covers the main components of a respiratory protection program, the difference between respirators and surgical masks, and common respiratory hazards in health care settings – including airborne infectious agents that cause diseases such as tuberculosis, according to an OSHA press release.

WASHINGTON - A proposed rule to align the Occupational Safety and Health Administration’s Hazard Communication Standard (HCS) with provisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS) will be published in the September 30 Federal Register.

The current HCS requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import and provide information to subsequent users. The current standard requires all employers to have a hazard communication program for workers exposed to hazardous chemicals. The program includes materials such as container labels, safety data sheets, and employee training.  A number of countries, including the United States, international organizations and stakeholders participated in developing the GHS to address inconsistencies in hazard classification and communications. The GHS was developed to provide a single, harmonized system to classify chemicals, labels and safety data sheets with the primary benefit of increasing the quality and consistency of information provided to workers, employers and chemical users. Under the GHS, labels would include signal words, pictograms, and hazard and precautionary statements. Additionally, information on safety data sheets would be presented in a designated order.

The proposal to align the hazard communication standard with the GHS will improve the consistency and effectiveness of hazard communications and reduce chemical-related injuries, illnesses and fatalities,” said acting Assistant Secretary of Labor for OSHA Jordan Barab. “Following the GHS approach will increase workplace safety, facilitate international trade in chemicals, and generate cost savings from production efficiencies for firms that manufacture and use hazardous chemicals.”

Under the Occupational Safety and Health Act of 1970, OSHA’s role is to promote safe and healthful working conditions for America’s men and women by setting and enforcing standards and providing training, outreach, and education. For more information, visit www.osha.gov.

It is interesting that in the 29CFR 1910, there are 2 parts that have similar, yet vastly different relationships.  Both parts deal with hazardous materials but the difference is only one (1) zero or is it?  1910 part 120 is the regulation for hazardous waste operations and emergency response, and 1910.1200 is the compliance regulation for hazardous communications. 

Hazardous communications almost always is in the top 5 of most frequently cited standards of OSHA violations.  The most common citation is for failing to have a written program 1910.1200(e) and failure to train employees 1910.1200(h).

So what does this mean?  Employers are required to have an updated MSDS (Material Safety Data Sheet) book on ALL hazardous chemicals/materials in the workplace.  The book should be available to all employees who work with these hazardous materials.  Each time a new or changed hazardous material enters the workplace the MSDS book should be updated.  In addition, all hazardous materials must be properly labeled with a similar 3 or 4 part hazardous label similar to the ones seen above.  Some labels include proper PPE (personnel protective equipment) to be worn when working with this hazardous material.

Another key part of the Hazardous Communication standard is the training.  The training 1910.1200(h)(3) shall include at least:

• Methods and observations to detect the presence or release of a hazardous material in the work area.
• Physical and health hazards of hazardous materials in work area
• Measures take for protection.
• Information including how to use the hazardous labels, MSDS sheets and where employees can get information.

To avoid compliance issues with the Hazcom standard, start with a hazardous materials audit and develop you policies and procedures.  Next write a Hazcom program that includes training, and then do the training.  Remember, every time a hazardous material changes or is introduced into the workplace, or a new employee is put into that environment you must train or retrain all involved.  Avoid the problems and avoid the fines.  Write the program and do the training.