What the Standards Require

Both 1910.1200 and 1910.120 are critical to those working with hazardous chemicals and to their supervisors.

• By Fred Elliott
• Dec 01, 2017

Two important OSHA standards for anyone working with hazardous chemicals, such as acids and caustics, to be aware of are 29 CFR 1910.1200, the revised Hazard Communication Standard, and 1910.120, Hazardous waste operations and emergency response. Those training workers to handle such chemicals also need to be familiar with them.

The revised HazCom standard has been aligned with the Globally Harmonized System of Classification and Labeling of Chemicals, or GHS. The standard covers the issue of classifying potential hazards of chemicals and communicating information about their hazards and appropriate protective measures to workers. The HAZWOPER standard applies to cleanups done at hazardous waste sites and specifies that employers involved in these must develop and implement a written safety and health program that identifies, evaluates, and controls safety and health hazards and also provides for emergency response for the hazardous waste operations performed. Medical surveillance and training are required elements of the written plan.

A key section of the latter is 1910.120(c)(7), which concerns risk identification. It says employees must be informed about any risks that have been identified from specific hazardous substances, but for situations covered by the HazCom standard, training it requires does not have to be repeated.

Risks that employers should consider, 1910.120(c)(7) says, include:

• exposures that exceed PELs and published exposure levels
• IDLH concentrations
• potential skin absorption and irritation sources
• potential eye irritation sources
• explosion potential
• oxygen deficiency

The revised HCS standard spells out how to maintain a written HazCom program, how to properly label containers of chemicals and chemical containers that will be shipped to other sites, both preparing and distributing Safety Data Sheets to employees and downstream companies, and employee training programs.

At 1910.1200(h), the standard explains that employers must inform and also train their workers on hazardous chemicals present in their work area at the time of their initial assignment and whenever a new chemical hazard the employees have not previously been trained on is introduced into their work area. Information and training may be designed to cover the hazard categories or individual chemicals. Chemical-specific information must be available at all times through labels and SDSs. This section of the standard also directs that employees are to be informed about any operation in their work area where hazardous chemicals are present and about the location(s) and availability of the written HazCom program, including the required lists of hazardous chemicals and the required Safety Data Sheets.

OSHA's 29 CFR 1910.134, respiratory protection, also is relevant to those working with hazardous materials, and 29 CFR 1926 Subpart Z, toxic and hazardous substances, contains important information for construction workers.

PHMSA Distributes Hazmat Training Grants
There also are U.S. Department of Transportation hazmat regulations, such as a pending Federal Railroad Administration final rule that would require railroads to provide emergency escape breathing apparatus PPE for crew members on freight trains carrying poison inhalation hazardous materials and to train the crews to use the PPE properly. DOT announced in August 2017 that this rule has been delayed because FRA "cannot identify an economical means of compliance," and so it issued a guidance document that railroads will use to develop effective emergency escape breathing apparatus programs.

Another DOT agency, the Pipeline and Hazardous Materials Safety Administration, announced Oct. 5 that it had awarded a trio of hazardous materials training grants totaling $23,870,045. They consisted of:

• $20,470,045 in Hazardous Materials Emergency Preparedness grants to states, territories, and Native American tribes to improve their emergency responders' ability to protect themselves and the public when responding to hazmat transportation incidents
• $2,400,000 in Assistance for Local Emergency Response Training (ALERT) grants to non-profit organizations to train volunteer or remote emergency responders to safely respond to rail accidents involving crude oil and ethanol products; recipients included the Center for Rural Development ($950,000), the University of Findlay ($950,000), and the International Association of Fire Chiefs ($500,000)
• $1 million to the Commercial Vehicle Safety Alliance through the Community Safety Training grant program, which allows community organizations to help train state and local personnel responsible for enforcing the safe transportation of hazardous materials

"State, local, and tribal emergency officials are almost always the first to respond to hazardous materials incidents," said Drue Pearce, PHMSA acting administrator. "These grants are another important resource PHMSA offers communities and response officials to educate, plan, and stay prepared for transportation incidents, including those involving high-hazard flammable trains."

"The department's hazardous materials grants allow recipients to design and implement planning and training programs that meet their specific needs," added U.S. Transportation Secretary Elaine Chao. "Improving the response capabilities of our emergency responders is an integral part of our strong national safety program."

This article originally appeared in the December 2017 issue of Occupational Health & Safety.