Safe Solutions

A wide assortment of potentially hazardous chemicals—and materials that contain potentially hazardous chemicals—can be found at job sites. The Occupational Safety and Health Administration (OSHA) requires these products and materials to have accompanying material safety data sheets (MSDSs) that detail the products' natures and related hazards. Making MSDSs available to workers is an easy part of complying with OSHA's hazard communication requirements; a more challenging aspect is making certain all roofing workers understand MSDSs so they can avoid or minimize chemical exposures.

Assessing hazards

OSHA regulates chemical hazard evaluation and transmittal of related information to employers and employees in its hazard communication standard, 29 CFR §1910.1200. The standard requires manufacturers to assess the hazards of the chemicals they produce; most manufacturers post current MSDSs on their Web sites for easy access. Chemical product distributors are required to provide MSDSs to employers who must maintain them in their workplaces.

OSHA requires MSDSs to be in English and contain the following information for each chemical product used:

• Chemical or common name of the substance or the component ingredients and name of the mixture
• Physical and chemical characteristics, such as flash point
• Physical hazards, such as risk of fire or explosion
• Health hazards, including signs and symptoms of exposure and medical conditions aggravated by exposure
• Routes of entry into the body, such as inhalation or absorption
• OSHA's permissible exposure limit or other exposure limit recommended by the product manufacturer
• Cancer-causing nature or potential of the product, if any
• Precautions for safe handling and personal protective equipment (PPE) and hygiene measures that apply
• Spill and leak procedures
• Engineering controls and work practices known by the manufacturer
• Emergency and first-aid procedures
• Emergency response telephone numbers

OSHA also mandates all MSDSs be "readily accessible" to workers. The standard does not define "readily accessible" in terms of a time limit, but in any situation where a worker has been exposed to a hazardous chemical, time must be considered important. Maintaining MSDSs at a job site where chemicals are being used will be most effective in minimizing the results of exposure, preparing a response or facilitating an emergency procedure.

Paper copies of MSDSs are not the exclusive format allowed by OSHA—MSDSs can be accessed electronically if critical information is not obstructed by server breakdowns, Internet connection difficulties or fax machine problems.

A training requirement

Even if MSDSs are readily accessible at job sites, workers should be trained regarding the chemicals' information and related hazards. In its hazard communication standard, OSHA specifically calls for such training to include, at a minimum:

• Methods and observations to detect the presence of hazardous chemicals, such as visual inspection and/or odors
• Potential physical and health hazards of chemicals in the work area
• Protective measures employees can use, such as practices to reduce exposures, PPE and emergency procedures
• Details of an employer's hazard communication program, labeling of hazardous chemicals and explanation of MSDSs

A useful provision

The hazard communication standard is one of the few OSHA regulations that include mandatory appendices to assist in compliance with the standard. You should review Appendix E for guidance in developing and implementing effective hazard communication procedures. In Appendix E, OSHA sets guidelines for conducting proper worker training in reading, understanding and using MSDSs. This may be the most useful provision of the hazard communication standard because it can help you convey critical information in MSDSs concerning products workers use daily.

Harry Dietz is NRCA's director of risk management.

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EXCLUSIVE

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• OSHA's hazard communication standard and Material Safety Data Sheet example
• NRCA's Hazardous Waste Management and Minimization Program