OSHA’s HazCom 2012 is unique in that it incorporates what is referred to as a downstream flow of information from chemical manufacturers, importers, and distributors to employers and, ultimately, to the employees using the products. Therefore, those who know the most about chemicals (i.e., the companies that produce, import, and/or distribute them) have the responsibility to determine potential hazards and to convey that information downstream.
In the context of HazCom 2012, a chemical manufacturer is an entity that produces hazardous chemicals. An importer is an entity that receives hazardous chemicals produced in another country for the purpose of supplying them to distributors or directly to employers within the U.S. A distributor is an entity other than a chemical manufacturer or importer that supplies hazardous chemicals to other distributors and/or to employers.
An employer is an entity engaged in a business where hazardous chemicals are either used (e.g., a dental practice), distributed, or are produced for use or distribution, including contractors or subcontractors. An employee is a worker (e.g., healthcare personnel) who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers who encounter hazardous chemicals only in non-routine, isolated instances are not covered.
Exposure or exposed to means that an employee, in the course of employment, is subjected (e.g., by inhalation, ingestion, skin contact, or absorption) to a chemical that is a physical or health hazard. Foreseeable emergency (i.e., accidental or possible) means any potential exposure such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.
It is the responsibility of manufacturers and importers to classify the hazards of chemicals they produce or import. To classify means they must (1) identify relevant data regarding the hazards of a chemical, (2) review those data to determine the hazards associated with the chemical, and (3) decide whether the chemical should be classified as hazardous. A hazardous chemical is any chemical classified as a health hazard, a physical hazard, or a hazard not otherwise classified.
Health hazard means that the chemical may have one or more of the following hazardous characteristics: it may cause acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration. These classes may be further divided into hazard categories.
Physical hazard means that the chemical may have one or more of the following hazardous characteristics: it may be explosive; flammable (gases, aerosols, liquids, or solids); oxidizing (liquid, solid or gas); self-reactive; pyrophoric (liquid, solid, or gas); self-heating; organic peroxide; corrosive to metal; gas under pressure; in contact with water emits flammable gases, or combustible (dust). These classes may be further divided into hazard categories.
Hazard categories are important because they are based on the severity of an effect. For example, there are four categories in the hazard class for flammable liquids (Table 1). These categories are based on flashpoints. The lower the flashpoint, the more severe the effect. Warnings are provided on the labels in the form of precautionary statements and the category itself is available in safety data sheets for the employer’s reference.
Table 1. Criteria for Categorizing Flammable Liquids.4
|Flash point < 23°C (73.4°F) and initial boiling point ≤ 35°C (95°F)
|Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F)
|Flash point ≥ 23°C (73.4°F) and initial boiling point ≤ 60°C (140° F)
|Flash point > 60°C (140°F) and ≤ 93°C (199.4°F)
Hazard not otherwise classified means that the chemical may produce an adverse health effect or physical event based on an evaluation of scientific data during the classification process. However, the evidence does not meet the specified criteria for a health hazard or physical hazard class. The effect either falls below the cut-off or threshold value/concentration limit of the hazard class or it is under a GHS hazard category that has not been adopted by OSHA.
The chemical manufacturer or importer must determine the hazard class, and when appropriate, the hazard category of each class that applies to the chemical being classified. They must also ensure that the containers of hazardous chemicals are labeled. The labels must be affixed to, printed on, or attached to the immediate container and to the outside packaging of a hazardous chemical conveying the hazards as well as recommended protective measures (Figure 2).
Chemical manufacturers and importers must also prepare safety data sheets (SDSs) for the hazardous chemicals they produce or import and they are responsible for providing SDSs downstream. Chemical manufacturers, importers, and distributors are responsible for ensuring that their customers (e.g., dental practices) are provided a copy of these SDSs at the time of the first shipment, and when an SDS is updated with new and significant information.
Furthermore, employers (e.g., dental practices) must ensure that the containers they received are labeled and that an SDS is provided for each hazardous chemical in the workplace. They must also establish a HazCom program for their employees (e.g., healthcare personnel). Employees must be trained on the hazards of chemicals in their work area before initial assignment and when new hazards are introduced. The responsibilities for HazCom are illustrated in Figure 3.