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Summer Reading – A Classic in Worker Safety
Barbara Kanegsberg, SQRC

You probably had to read the “Bill of Rights” somewhere in your interaction with the educational system. If you work with chemicals, do you know what you ought to read or at least glance at 29CFR 1910.1200 “Hazard Communication”? While not as riveting as the latest “Harry Potter,” reading 29CFR 1910.1200 is actually not at all painful, and it’s very instructive. Hopefully, your employer provides a Hazard Communication program. While training programs are important, to be truly educated, it’s useful to get back to the source of requirements: for programs, for labeling, for MSDS.

Do a web search on hazard communications, and you will be presented with zillions of training programs (ok, maybe not zillions – but many). To progress beyond training to education, the legendary 29 CFR 1910.1200 is available on-line on the OSHA website. We have provided a link for your convenience.

The rule deals with chemical hazards and covers:

• Evaluating of hazards of chemicals, produced or imported
• Transmitting information about potential chemical hazards to employers and employees

Transmitting means comprehensive hazard communication programs. Such programs include:

• Container labeling
• Other types of warning
• Material Safety Data Sheets (MSDS)
• Employee training
• Significant updates

It is also important to be aware of what the rule does NOT cover. A few examples include:

• Hazardous waste
• Food and alcohol
• Drugs (eg. items covered by the FDA)
• Ionizing and non-ionizing radiation
• Biological hazards
• Hazard communication in languages other than English

Mixtures and blends
The term “chemical” means an element, a chemical molecule, or a mixture. There is an important proviso that if a mixture has not been tested as a whole to determine health hazards, it is assumed to present the same health hazards as components that are

• carcinogens at levels 0.1% or over (by weight or volume
• other components at 1% or over (by weight or volume)

There are some potential “gotchas” for you as an employee. Typically, the health hazards of blends are not evaluated, in part for economic reasons. However, there can be synergistic effects, where the performance, materials compatibility, and/or toxicity of blends are non-additive (Ref. B. Kanegsberg, “TANSTAAFL”*). Therefore, if you begin to work with any new blend on a regular basis, you should handle it with reasonable caution. If the blend appears to show enhanced performance, you might be particularly observant of chemical handling practices. In addition, it may not be valid to assume that there is no problem with non-carcinogens present at concentrations less than 1%, particularly for complex formulations. Those fractions of a percent can add up if large numbers of chemicals are blended. You don’t have to panic; just be prudent.

For another thing, “components” listed in an MSDS are taken to mean health hazards. A chemical may not present a hazard to workers, but it may interfere with product performance. This could lead to noise and/or stress hazards from superiors or customers.

Continuing education
In a recent issue of “Green Files,” we explained why allowable levels of chemicals in air can differ in the workplace and in the community. One important difference between worker safety and community exposure is that if you work with chemicals, you have to get educated.

I think that if you work with chemicals, 29 CFR 1910.1200 is your special Bill of Rights. It’s worth a bit of time to read it and to understand the implications for your facility. Find and dust off the official Hazard Communications book. Maybe it’s time for a refresher course, maybe even an update.

Disclaimer: The preceding is my best effort at summarizing and discussing 29 CFR 1910.1200. I am a chemist, not a lawyer.

Web link to 29 CFR 1910.1900

B. Kanegsberg, ‘Cal/OSHA PELs, Community Standards for Worker Exposure Limits?”, The Green Files, Vol. 2, issue 1, 2007.

B. Kanegsberg, “TANSTAAFL,” Clean Source, Vol. IV, no. 2, June, 2007.
*(‘There Ain’t No Such Thing as a Free Lunch’)

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