Developing a Hazardous Chemical List

As part of a hazard communication written program, you will need to compile a list of all hazardous chemicals used, or present in your workplace. The list will eventually serve as an inventory of every substance that has an MSDS. At this point, however, preparing the list will help you complete the rest of the program since it will give you some idea of the scope of the program required for compliance in your workplace.

Add a Note HereAssess for workplace hazards
Add a Note HereThe best way to prepare a comprehensive chemical list is to perform a comprehensive assessment of your facility. This means a department-by-department search for every chemical present. It includes cleaning supplies, such as bathroom and window cleaners; grounds maintenance chemicals, such as weed killers and fertilizer; vendor samples being used on a trial basis; fuels; paints; as well as all chemicals used in your company’s daily operations.
Add a Note HereThe broadest possible perspective should be taken. Sometimes people think of “chemicals” as being only liquids in containers. The HCS covers chemicals in all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors which determine whether a chemical is covered. If it’s not hazardous and there is no potential for exposure, it’s not covered.

Add a Note HereWhat to look for
Add a Note HereIdentify chemicals in containers, including pipes, but also think about chemicals generated in the work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Some other suggestions include:
§  Add a Note HereRead labels provided by suppliers for hazard information,
§  Add a Note HereMake a list of all chemicals that are potentially hazardous,
§  Add a Note HereNote the storage and use location(s) of the products, and
§  Add a Note HereNote the hazards as found on the label.
Add a Note HereAs you are compiling this inventory, consider listing the substances separately by department. You will find that it makes it easier to conduct employee training to know which chemicals are used in which departments.

Add a Note HereTypes of regulated substances
Add a Note HereThe following list identifies some types of potentially hazardous chemicals that may be present in your workplace.
Add a Note HereAcids
Add a Note HereAdhesives
Add a Note HereAerosols
Add a Note HereAsbestos
Add a Note HereBattery fluids
Add a Note HereBenzene
Add a Note HereCatalysts
Add a Note HereCaustics
Add a Note HereCleaning agents
Add a Note HereCoal tar pitch
Add a Note HereCoatings
Add a Note HereDegreasing agents
Add a Note HereDetergents
Add a Note HereDusts
Add a Note HereEtching agents
Add a Note HereFiberglass
Add a Note HereFlammables
Add a Note HereFoaming resins
Add a Note HereFuels
Add a Note HereFungicides
Add a Note HereGasoline
Add a Note HereGlues
Add a Note HereGreases
Add a Note HereIndustrial oils
Add a Note HereInks
Add a Note HereInsecticides
Add a Note HereHerbicides
Add a Note HereJanitorial supplies
Add a Note HereKerosene
Add a Note HereLacquers
Add a Note HereLead
Add a Note HereLye
Add a Note HereOxalic Acid
Add a Note HerePaints
Add a Note HerePesticides
Add a Note HerePlastic resins
Add a Note HereProcess chemicals
Add a Note HereResins
Add a Note HereSealers
Add a Note HereShellacs
Add a Note HereSolders
Add a Note HereSolvents
Add a Note HereStrippers
Add a Note HereSufactants
Add a Note HereThinners
Add a Note HereVarnishes
Add a Note HereWater treatments
Add a Note HereWood preservatives
Add a Note HereXylene

Add a Note HereAny substance that presents a physical or health hazard, as defined by OSHA, is considered regulated under the HCS. However, OSHA has designated four separate lists of chemicals that comprise the “floor ”of regulated chemicals. There are about 1,200 chemicals specifically listed as regulated.
Add a Note HereHazardous and carcinogenic chemicals
Add a Note HereThere are two main categories of hazardous substances covered by OSHA — hazardous chemicals and carcinogenic chemicals. Carcinogenic substances are viewed to present a greater hazard so they are treated more stringently in the regulations.
Add a Note HereYou will find the list of toxic and/or hazardous substances in OSHA’s subpart Z, §1910.1000 and the ACGIH Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment. Any compound of a substance from these lists is considered part of the floor of covered hazardous chemicals.
Add a Note HereThe floor lists of carcinogenic substances can be found in OSHA ’s subpart Z, §1910.1000, the NTP Annual Report on Carcinogens, and the IARC Monographs.

Add a Note HereSubstances not covered by HCS
Add a Note HereCertain hazardous substances are regulated by other agencies; therefore, OSHA has exempted them from coverage by the Hazard Communication Standard. HCS does not apply to the following substances:
§  Add a Note HereAny hazardous waste, as defined and regulated under RCRA.
§  Add a Note HereAny hazardous substance, as defined and regulated under CERCLA.
§  Add a Note HereTobacco or tobacco products.
§  Add a Note HereWood or wood products, including lumber which will not be processed, where the chemical manufacturer or importer can establish that the only hazard the products pose to employees is the potential for combustion.
§  Add a Note HereFood or alcoholic beverages which are sold, used, or prepared in a retail establishment (such as a grocery store or restaurant) and foods intended for personal consumption by employees while in the workplace.
§  Add a Note HereAny drug as defined by the federal Food, Drug, and Cosmetic Act when it is in solid, final form for direct administration to the patient (e.g., pills), drugs packaged by the chemical manufacturer for sale to consumers (e.g., over-the-counter drugs), and drugs intended for personal consumption by employees while in the workplace (e.g., first aid supplies).
§  Add a Note HereCosmetics packaged for sale to consumers and those intended for personal use by employees in the workplace.
§  Add a Note HereAny consumer product or hazardous substance as defined in the Consumer Product Safety Act and Federal Hazardous Substances Act respectively, used in the workplace in the same manner as normal consumer use, and which use results in exposure which is not greater than exposures experienced by consumers.
§  Add a Note HereNuisance particles when they do not pose any physical or health hazard covered by HCS.
§  Add a Note HereIonizing and nonionizing radiation.
§  Add a Note HereBiological hazards.
§  Add a Note HereArticles.
Add a Note HereIf you have exempt substances, you must be able to demonstrate that the substance is subject to other regulations and produce the appropriate label (if required) and any required identification documents, should an OSHA compliance officer inquire.
Add a Note HereWeed out non-regulated products
Add a Note HereReview the completed inventory list and determine which chemicals are hazardous, as determined by OSHA. This involves checking each chemical against the OSHA-designated lists, reviewing the MSDS information sent by the manufacturer, as well as reviewing §1910.1200(b) to determine if any items can be eliminated from your list because they are exempted materials. Weed out those chemicals not regulated by OSHA.
Add a Note HereYou will also want to assess employee exposure as it relates to consumer products, such as window cleaner. The level of exposure will determine if the substance must be listed on your hazardous chemical inventory. For example, does the employee use window cleaner to wash windows for the most part of each day, or does the employee use window cleaner once every few months to keep the windows clean, as he or she would at home?
Add a Note HereWhen you are done with this assessment, you will have an inventory of hazardous chemicals. Keep this list current as part of your written hazard communication program.
Add a Note HereOnce you have compiled a list of the potentially hazardous chemicals used in your workplace, the next step is to find out if there are material safety data sheets for all of them. Check you files against the inventory you have just compiled. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by copying the letter or writing a note regarding telephone conversations. If you have MSDSs for chemicals that are not on you list, figure out why. Maybe you don’t use the chemical anymore. Or maybe you missed it in your survey. Some suppliers do provide MSDSs for products that are not hazardous. You do not have to maintain these.
Add a Note HereDon’t allow employees to use any chemicals for which you have not received an MSDS. The MSDS provides information you need to ensure proper protective measures are implemented prior to exposure.

Add a Note HereWhat is an “article”?
Add a Note HereItems considered “articles” are exempt from the requirements of the HCS. An article is defined as a manufactured item other than a fluid or particle which:
§  Add a Note HereIs formed to a specific shape or design during manufacture;
§  Add a Note HereHas end use function(s) dependent in whole or in part upon its shape or design during end use; and
§  Add a Note HereMust not release more than very small quantities (e.g., minute or trace amounts) of a hazardous chemical, or pose a physical hazard or health risk to employees under normal conditions of use.
Add a Note HereIt may be difficult to define what is considered “normal conditions of use.” You may have a manufactured item that meets the definition of an article, but if it is burned, it produces a hazardous byproduct. The question then becomes, is burning “normal use” for the product? If burning occurs in its normal use, then it cannot be exempted as an article.
Add a Note HereIf a hazardous chemical can be expected to be released only when the item is repaired, then that is not considered part of its normal condition of use. The item would be considered an article under the HCS, and thus exempted.
Add a Note HereStainless steel tables, vinyl upholstery, and tires are considered articles. Products that are not articles include:
§  Add a Note HereMetal ingots that will be melted under normal conditions of use;
§  Add a Note HereFabric treated with formaldehyde where downstream garment manufacturing employees will be exposed when making clothing; and
§  Add a Note HereSwitches with mercury in them when a certain percentage break under normal conditions of use.
Add a Note HereBasically, if the product will be processed in some way after leaving the manufacturing site — heated, welded, glued, sawed, etc. — and a hazardous chemical could be emitted, it probably will not qualify for the article exemption.

Add a Note HereWhat is a “mixture”?
Add a Note HereMany chemical products are mixtures or reformulations. If the mixture has been tested as a whole, the results of the test will be used to determine whether it is hazardous. If the mixture has not been tested as a whole and it contains:
§  Add a Note Here1 percent or more of an ingredient that is listed as a health hazard, or
§  Add a Note Here0.1 percent of an ingredient listed as a carcinogen,
Add a Note Herethen, the whole mixture is assumed to have the same health and/or carcinogenic hazards as its hazardous components.
Add a Note HereEven if the mixture contains less than these percentages, but evidence indicates that a hazardous/carcinogenic component could be released in concentrations above an established PEL or TLV, then the mixture again must be assumed to present the same hazard.
Add a Note HereThe manufacturer, importer, or employer may use whatever scientifically valid data is available to evaluate the physical hazard potential of the mixture. For example, benzene is a carcinogen. If you have an untested mixture containing benzene, and you know there is more than 0.1 percent benzene in the mixture, you must regard the whole mixture as a carcinogen.
Add a Note HereIf you assume the mixture has the same hazards as its hazardous components, the individual data sheets for the hazardous components will satisfy MSDS requirements (there can be multiple data sheets for one mixture). However, if you decide to test the mixture, a full range of tests need to be performed to determine both the physical and health hazards of mixture.

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