Over the past several decades, employee injury or illness from chemical exposure has been a frontline issue for SH+E professionals. Regulation of chemicals by the Environmental Protection Agency, the Occupational Safety and Health Administration, the Department of Transportation, and the Department of Energy provides direction and guidance for chemical handling and use with the goal of an injury free work environment. Why then do we continue to have injury and illness cases related to chemical handling and use? This presentation will focus on the Hazard Communication Standard and how it can be enhanced to reduce these cases. By incorporating schemes similar to Control Banding, and standardization of terms and language as embodied in the Global Harmonization System (GHS), we can improve the effectiveness of the Hazard Communication Standard.

Is This Issue A Real Problem?

HazCom continues to be a significant safety and heath issue in both the workplace and the public safety setting. "More than 32 million workers are exposed to 650,000 hazardous chemical products in more than 3 million American workplaces. Moreover, each year emergency responders are seriously injured or killed because of deficient information about chemicals on site when they are addressing situations such as fires, explosions or transportation disasters."1 Further, the continued citations indicate the HazCom Standard 29CFR 1910.1200 is not being taken seriously or not being used as expected to safeguard employees. Table 1 data taken from the OSHA website tabulates HazCom citations, indicating this is a broad-based problem crossing industry boundaries.

Table 1. - HazCom Citations By Industry Segment Sept. 03/Oct. 04 (available in full paper).

In my state, New York, HazCom violations accounted for 17.3 % of private sector violations and 12.98% of public sector violations for this same period. "Failure to have a Written Plan" ranked number one in both sectors.

Given that the problem exists, how serious is it in terms of severity? Is this just a problem with minor exposures in small operations? As a member of the Society's Government Affairs Committee, I was present at an April 2004 meeting with the Chemical Safety Board which found that 12 of 19 investigations led to a similar conclusion: failure to properly implement the Hazard Communication Program was considered a major factor in events leading to the incidents (fire, explosion, major release, etc.). The incidents studied included catastrophic refinery fire and explosions, factory incidents with dust explosions, and incidents with major releases of material within the facility and to the surrounding community. From this I draw the conclusion that HazCom isn't being administered well in large or small enterprises.

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