OSHA Compliance and the MSDS
Is your heating and air conditioning (HVAC) company in compliance with hazardous communication standard 29CF1910.1200? If you are not, it could mean fines of $10,000 or more for unwary contractors. It’s simple. Your office and trucks must have Material Data Safety Sheets (MSDS sheets) for each and every chemical stored within them (including refrigerant, Freon®, anti-freeze and motor oil). If you do not, you may be subjected to work stoppage and fines of tens of thousands of dollars! Don’t take any chances.
Each of your vehicles, work locations, and office must have a set of Material Safety Data Sheets (MSDS) that readily accessible to your employees. You must have an MSDS for each chemical or substance that employees have access to or may use.
Where to Obtain MSDS
You can get material safety data sheets from the manufacturers and suppliers you do business with. You may also search and download them from the internet. Mr. HVAC sells an OSHA Compliance Kit that contains important OSHA MSDS information as well as hundreds of HVAC specific material safety data sheets.
Teaching Your Coworkers How to Read Material Safety Data Sheets
Eddie was applying a special air duct insulation adhesive when he started feeling nauseous and dizzy. He thought back to what his installation manager said: “Remember to check the MSDS, Eddie, and be sure you take the right precautions when using that glue.” So Eddie checked the MSDS but the technical stuff was too much to go through, so he thought heâ€™d just take his chances. It’ no big deal; it’s just glue. Unfortunately for Eddie, he needed to wear a respirator for this particular job; which he learned after he regained consciousness. Poor Eddie had passed out from breathing toxic fumes.
Training is the Key
The material safety data sheet (MSDS) is the key to communicating hazards and safe handling procedures of chemicals your workers use on the job. But, this information is only helpful if your employees are trained to understand the technical information contained in the MSDS. Your must train your technicians and installation crews.
According to OSHA: “Giving an employee a data sheet to read does not satisfy the intent of the standard with regard to training.” It is therefore your job to make sure the MSDS is understandable.
Have a Lesson Plan
Before you begin training your staff, you will need to organize the information and develop appropriate handouts. Since most companies use large numbers of chemicals, it is virtually impossible to train your employees on each one. Instead, group the chemicals by categories that make sense for your operation, such as refrigerants, solvents, gases, etc. Then you can deal with additional information about individual substances within each group.
Make copies of sample MSDSs for each chemical group and highlight the important information. Have on hand a corresponding container label. Have a second handout that provides a glossary of terminology used on MSDSs. If you can, make overheads of these handouts.
Start off by explaining what the MSDS is and why it is so important. Tell employees that these sheets contain vital safety and health information about each chemical in the workplace, such as:
- Exposure limits
- Health effects of overexposure
- Safe handling procedures
- Emergency procedures
- Personal protective equipment
- Engineering controls
- Explain that the chemical manufacturer is required to provide an MSDS with each chemical that arrives in the workplace. Tell your employees where these sheets are located and how to access them (additional training may be needed if your MSDSs must be retrieved from a computer database).
Section by Section
Next review the sample MSDS that you have just handed out. Ask what each term means and have employees look it up in the glossary handout. The following is a section by section description of the basic terminology that can help you develop your definitions:
Contains contact information about the chemical manufacturer, which can be important in the event of an emergency.
- Both the scientific name and the common name of the chemical are listed here. Also, the following exposure limits are covered:
- OSHA PELâ€”OSHA’ “Permissible Exposure Limit” – The maximum amount of the chemical that an employee can be exposed to without danger over a typical 8 hour day.
- ACGIH TLVâ€”â€œThreshold Limit Value” – Another safe exposure limit set by the American Conference of Governmental Industrial Hygienists.
- (Explain how you monitor exposure limits at your worksite)
Section IIIâ€”Physical/Chemical Characteristics
- What the chemical normally looks and smells like and possible danger signs
- Boiling Pointâ€”Temperature at which the liquid turns into a gas
- Vapor Pressureâ€”How easily the chemical evaporates (the higher the number, the faster it evaporates which can cause dangerous vapors in the air)
- Evaporation Rateâ€”Another measurement of how quickly a liquid or solid turns into a gas (the higher the number, the faster the rate)
- Specific Gravityâ€”Whether the chemical will sink in water (above 1â€”will sink; below 1â€”will float)
- Solubility in Waterâ€”How much of the chemical will dissolve in water
- Section IVâ€”Fire and Explosion Hazard Data
- What might cause a fire or explosion and how to put out a fire. Flash Pointâ€”The lowest temperature at which the vapors could catch fire if ignited by a spark or some other source Flammable Limitsâ€”The minimum and maximum percent of vapor in the air that could catch fire if ignited
- LEL and UELâ€”Lower and upper explosive limits – The minimum and maximum percent vapor in the air that could explode if ignited (Review safety procedures for minimizing risk of ignition, such as sparks)
Vapor Densityâ€”If the vapor will rise (below 1) or sink (above 1) in the air
Section Vâ€”Reactivity Data
Describes what could happen if the chemical mixes with water, air or other chemicals.
Stable or Unstableâ€”How easily the chemical changes or breaks up
- Incompatibilityâ€”If the substances listed here are mixed with the chemical, a hazardous reaction will occur.
- Hazardous Decomposition or By-products – Dangerous chemicals that can be formed when the substance breaks down or reacts
- How the chemical enters the body (such as inhaling, swallowing or through the skin) and what health problems it could cause.
- Acuteâ€”A reaction that shows up right after exposure, such as a rash
- Chronicâ€”A reaction that develops over time, such as cancer
- Carcinogenâ€”Substance known to cause cancer at certain exposure levels
Section VIâ€”Health Hazard Data
Section VIIâ€”Precautions for Safe Handling and Use
Explains how to properly handle, store and dispose of the chemical. Also, what steps to take if there is an accidental spill or release.
Section VIIIâ€”Control Measures
This section describes what type of respirator to use and how to maintain proper ventilation. It also recommends appropriate personal protective equipment, such as safety eye gear, gloves, and other protective clothing. This section should be emphasized and covered thoroughly.
Encourage your co-workers to take the time to read the MSDS and label before using any chemical. The detailed information will help them feel confident that they can safely handle these substances without harming themselves.
Portions of this article were taken from the Occupational Safety and Health Administration