Hazard Communication/ Right to Know Standard

1. Hazard Communication/ Right to Know Standard Title 29 CFR 1910.1200

2. Hazard Communication/ Right To Know Standard This standard states: • the employer must explain or describe any chemical hazards that an employee may be exposed to in the workplace (during the regular course of duty or during an emergency).

3. What Are My Legal Rights? • Short and long term health effects of exposure • Symptoms of exposure to chemical substances • Ways to minimize exposure; The common or trade name of the product • Its chemical ingredients • The level at which exposure may be hazardous • Flammability and reactivity of the product • What to do in case of fire, spill or medical emergency • Proper chemical waste disposal practice

4. How do chemicals enter our bodies? • Modes of entry/exposure: • Absorption (through the skin) • Penetration/Injection (parenteral/mucous membrane) • Inhalation (vapors) • Ingestion (drink/eat)

5. Types of exposure • Exposure may be: • Acute (short term health effect of exposure) • Chronic (long term health effect of exposure) • Hazard warning words: danger, corrosive, caustic, toxic, noxious, flammable, skull and crossed bones

6. The standard states: HAZCOM/RTK PLAN • The employer must have a written Hazard Communication Plan (HCP) • The employer must designate a program coordinator (Site Safety Officer)

7. Right to work with properly labeled products: • The common name of the product • The identity of the hazardous chemicals in the products • An appropriate health hazard warning • The manufacturer’s name and address

8. The Chemical Inventory • Current information concerning the chemicals that are in the building is an important tool in keeping the work environment safe • A chemical inventory of hazardous chemicals used, produced, or stored in the building must be updated annually • Chemical inventory must be kept in a file, in an easily accessible, centralized location • Hazard warning words: danger, corrosive, caustic, toxic, noxious, flammable, skull and crossed bones

9. Chemicals on your site to be removed? • Contact The Division of School Facilities (DSF) (718) 718-610-0166 • mercury spills-- DSF • large mercury spills-- contact 911! (FDNY, DOH, DEC)

10. Material Safety Data Sheets (MSDS) provide useful information: • the name, address, and telephone number of manufacturer • physical properties • health effects • what PPE to use • Exposure limits • CAS # • how to clean up spill (is training required?)

11. MSDS should be: • readily accessible to employees/ kept on file • available for chemicals used/stored in the building • made available in 72 hours after request

12. Right to refuse • To work with a product if the MSDS or other appropriate information is not provided within 72 hours.

13. MSDS may be obtained by: • Calling the 800 # on the label– request a fax • Using the form letter in the back of the plan • Online: search word: MSDS or msdssearch.com, msdsonline.com, msdsprovider.com, company’s website

14. MSDS may be obtained by: • Cornell Center for Materials Research Computing Facility http://www.ccmr.cornell.edu/helpful_data/msds.html • University of California http://www.ucop.edu/riskmgmt/ohp/msds.html • Lab safety http://www.che.ilstu.edu/chemsafety/msds.html

15. Information and Training • Your Employer must provide an educational program for you about the health hazards in your work site and ways to protect yourself • employees must be trained annually, upon hiring, and when a new hazard is introduced into the workplace • Training record must be maintained for three years

16. Personal Protective Equipment • Personal Protective Equipment must be provided by the employer • For the most part-- gloves

17. Record keeping • Your employer must keep records of your exposures • For the duration of your employment and 30 years after

18. SH 900, 900.1, 900.2 • SH 900, the Log of Work Related Injuries and Illnesses • SH 900.1, Summary of Work-Related Injuries and Illnesses • SH 900.2, Injury and Illness Incident Report

19. But Why the Change?? • 12NYCRR Part 801, is the portion of law on the books of New York State that determines how occupational injuries and illnesses are reported. • As there have been changes in the Federal Register, as required by the NY State plan agreement, Part 801 must also be revised.

20. SH 900, 900.1, 900.2 • SH 900, the Log of Work Related Injuries and Illnesses form is used to record occupational injuries and illnesses in each DOE facility. • SH 900.1, Summary of Work-Related Injuries and Illnesses “provides additional data to make it easier for employers to calculate incidence rates.” • SH 900.2, Injury and Illness Incident Report now includes more data about how the injury or illness occurred. • Copies of these records accompanied by supporting documents must be received by the Regional Operation Center Office by February 1 and by OOSH by February 15

21. Why keep these records? Record keeping provides many benefits: • It provides information to employers and employees on work related illnesses and injuries • It provides information about work hazards • For Employers, it serves as a management tool for developing safety & health programs • For Employees, is raises awareness of workplace conditions • Used to track industry illness and injury trends

22. Please Note: • PESH injury and illness record keeping and Worker’s Compensation are independent of each other. • Recording or reporting a work-related illness, injury, or fatality, is not an implication of fault • Does not mean that a PESH violation exists • Does not mean that the employee is eligible for Worker’s Compensation or other benefits

23. Changes have occurred in the following: As of January 2004, the SH 900, SH 900.1 and SH 900.2 forms have been revised.The SH 900-Log of Work Related Injuries and Illness: Section M has been renumbered. • The SH 900.1-Summary of Work-Related Injuries and Illnesses: Section 5 has been renumbered to reflect the SH 900 form. • The SH 900.2-Injury and Illness Incident Report-The instructions regarding when an employee may independently and voluntarily request their name be withheld have been limited to illness rather than either injury or illness.

24. What is Recordable?Recordable means that the injury/illness is reported on the SH 900, in addition to other reporting forms. Employers must record each fatality, injury or illness that: • Is work-related, and • Is a new case, and • Meets one or more of the criteria

25. Record on the SH 900General Recording Criteria An injury or illness is recordable if it results in one or more of the following: • --death • --days away from work • --restricted work activity • --transfer to another job • --medical treatment beyond first aid • --loss of consciousness • --significant injury or illness diagnosed by a PLHCP (Physician or licensed health care practitioner)

26. INJURY Any wound or damage to the body resulting from an event in the workplace Includes damage to muscles, joints, and connective tissue when resulting from slips, trips, and falls ILLNESSES Musculoskeletal disorders Skin disease or disorders Respiratory conditions Poisoning Noise-induced hearing loss All other occupational illnesses What is Recordable?

27. Decision Making Tree NO Did the employee experience an injury or illness? YES NO Is the injury or illness work related? YES NO Update the previous injury or illness entry is necessary. NO Is the injury or illness a new case? YES YES NO Does the injury or illness meet the general criteria or applicable criteria for case? Do not record the injury or illness. Record the injury or illnesses.

28. Work Relatedness • Injuries resulting from events in the work environment are generally presumed to be work related

29. Work-related Exceptions Certain injuries or illness, even though they occur at “work” or at the work site are not recordable some examples include: • Being present at the work site as a member of the general public (ex: before work time) • Symptoms arising in work environment but are due to a non –work related event or exposure • Voluntary participation in a wellness program, medical fitness or recreational activity • Consumption or preparation of “outside” food for personal consumption.

30. At Work but not Recordable Certain injuries or illness, even though they occur at “work” or at the work site are not recordable some examples include: • Personal tasks /errands • Personal grooming, self medication for non-work related condition, or intentionally self- inflicted • Motor vehicle accident in parking lot

31. At Work But Not Recordable • Common cold or flu • Mental illness, unless employee voluntarily provides a medical opinion from a physician or licensed health care professional (PLHCP) having appropriate qualifications and experience that affirms work relatedness

32. SH- 900– Log of Work Related Injuries and Illnesses • looks like a miniature of the old DOSH 900 • should not be posted • may be updated as the case is updated • is this a privacy case? • maintain records for 5 years following the year covered. For example, the 2003 SH 900 may be discarded as early as January 2009. • let’s get to know it personally

33. THE SH 900 & SH 900.1 • Group Exercises • Getting Familiar • Discussion

34. The SH 900.1– Summary of Work-Related Injuries and Illnesses • should be posted no later than February 1 • post from Feb 1-April 30 of the subsequent year the record is for • must be signed off by the highest ranking official working at the establishment (Principal) or place of maintenance of the records to certify the summary for accuracy and completion • should be not updated

35. The SH 900.1– Summary of Work-Related Injuries and Illnesses • Information, in part, comes from SH 900 • Calculations on the back of form must be brought over to the front side

36. The SH 900.2– Injury and Illness Incident Report --should have one for each recordable work injury/illness case --employee must sign to indicate if it is desirable to have name on SH 900, if they do not want name/do not sign, the other information is entered on SH 900 without the name. --do not post --do not update

37. SH 900.2– Injury and Illness Report • Contains information about employee health issues • Details what happened • Must be kept confidential • Filled out within 7 days after informed of recordable injury/illness • Employee must choose a disclosure option on the bottom • Employee is entitled to a copy

38. SH FORMS AND INSTRUCTIONSPACKAGE • INSTRUCTIONS FOR COMPLETING THE SH 900, 900.1, 900.2 FORMS • SH 900-LOG OF WORK RELATED INJURIES AND ILLNESS FORM • SH 900.1 CALCULATION SAMPLE FOR EMPLOYMENT INFORMATION • SH 900.1-SUMMARY OF WORK-RELATED INJURIES AND ILLNESSES FORM • SH 900.2-INJURY AND ILLNESS INCIDENT REPORT FORM

39. Right to be notified: • Your Employer must inform you of your rights by posting notices • In addition, you Employer must post notice of your rights and responsibilities under the Public Employees Safety and Health Act (PESH)

40. Please post: DOE/RTK poster PESH poster SH 900.1 (Feb.-April) DOL/RTK BBP Safety & Health Bulletin Board Please file: Chemical inventory MSDS SH 900, 900.1, 900.2 POSTERS

41. THE END • Questions and Discussion

42. VIDEO • LET’S GO TO THE VIDEO