Hazard communication

• The Occupational Safety and Health Administration (OSHA) hazard

communication standard (HCS), also known as the “employee
right-to-know” standard. HCS was developed to protect employees
from exposure to hazardous products and chemicals.

• This standard requires all employers to develop a written program

addressing labelling and warning requirements, material safety
data sheets (MSDSs) and employee training on hazardous
materials. The standard also requires employers to develop and
maintain a list of all hazardous substances in the workplace and a
description of the methods the employer will use to inform
employees of the hazards related to non routine tasks in the
workplace.
From the initial effective date of this standard, HCS violations have
been among the most frequent citations issued by OSHA in the
construction and general industries because it can be difficult to
comply with all of its administrative requirements.
 How to comply
The following is a six-step approach for complying with the standard. Although
there are only six main steps, each involves many smaller steps.

1. Know the standard: It is up to roofing contractors to understand the elements

of this fairly complex standard and become familiar with their responsibilities.
This is an employee-right-to-know law—employees have the right to know
about the standard, the hazardous chemicals and products found in the
workplace, and the methods of protecting themselves from chemical
exposure.
2. Develop a chemical inventory list: A chemical inventory list is included in the
sample written program following this chapter. An employer should walk
around the office, yard and project sites, recording the product names of all
chemicals, along with the manufacturers’ names, addresses and telephone
numbers. Something as simple as a tube of caulking compound is a product
that contains chemicals for which an employer must maintain an MSDS and
list the product on the chemical inventory. Each chemical’s location also
should be noted. (This is a good time to properly dispose of half-empty and
unneeded cans of paint, adhesive and other materials.) The completed
chemical inventory list should be kept with the written program because it
may need to be amended as new chemicals are purchased.
3. Label all containers. All containers should be labelled with at least the following
information:
1. Identity of the chemical
2. All potential hazards associated with the chemical
3. Manufacturer’s name, address and telephone number

• One common problem companies face is the use and labelling of portable
containers. Portable containers should be dedicated for one specific use and labelled
with the identity of the hazardous chemical inside and appropriate hazard warnings
so employees will have general information as to the hazards relating to the
chemical.
• The employer is not required to label portable containers into which hazardous
chemicals are transferred from properly labelled containers when the material
transferred is for the immediate use of the person performing the transfer.
• For example, if paint thinner is poured from a labelled original container into a
bucket for the purpose of cleaning some parts, the bucket does not need a label if
the person transferring the thinner is the one who will use it immediately.

OSHA states containers of this type do not need to be labelled if the entire contents are used in one shift by only one
person, with the contents being used completely or returned to their original containers. The containers cannot be
passed from one employee to another, and employees cannot leave un-labeled, partially filled containers overnight.
Labels are available from any safety supply company. For maximum employee comprehension, labels should be as
simple as possible. One style of labelling should be used consistently. Color-coded labels accompanied with numbers
and pictures or icons are helpful when there are crew members who do not read English.
4. Obtain MSDSs. An MSDS is needed for each chemical at the workplace. If an MSDS
is not received with a shipment, the manufacturer should be contacted to request
one for inclusion in the MSDS file.
• While OSHA has developed a preferred format for a comprehensive MSDS, the
format of those received from manufacturers and suppliers may vary. OSHA
requires MSDSs to be in English and, at a minimum, include the following
information:
• Product Identification
The name of the product, trade name or synonym, or chemical name used on the label. This can be the common
and chemical name of a single substance or the common and chemical names of a mixture.
• Physical and Chemical Characteristics
This information includes characteristics of a chemical, such as its vapour pressure or flash point.
• Physical Hazards
The chemical’s potential for fire, explosion or reactivity must be set out such as:
Flash point—the temperature at which the chemical gives off enough vapour that, when mixed with air, will ignite
if an ignition source is introduced. Examples of ignition sources are sparks, matches, hot kettles and radiating heat.
Extinguishing media—the material—whether water, fire fighting foams, dry chemical, dry powder or carbon
dioxide—that will put the fire out, along with those that are ineffective at extinguishing a fire of this type
Special fire fighting procedures—this information is only for fire fighting professionals with specialized training and
special fire fighting PPE. These procedures should not be attempted by the roofing company.
Unusual fire and explosion hazards—information regarding incompatibilities or the substance’s reactivity with
other substances
• Health Hazards
This information should set out the signs and symptoms of exposure to the hazardous chemical and any medical
conditions that may be aggravated by exposure to the chemical.
• Obtain MSDSs. An MSDS is needed for each chemical at the workplace. If an MSDS
is not received with a shipment, the manufacturer should be contacted to request
one for inclusion in the MSDS file.
• While OSHA has developed a preferred format for a comprehensive MSDS, the
format of those received from manufacturers and suppliers may vary. OSHA
requires MSDSs to be in English and, at a minimum, include the following
information:
• Primary Routes of Entry
Chemicals may enter the human body through different means, such as inhalation (breathing in the
vapors); ingestion (swallowing the chemical); injection (by some mechanical means under the skin); or
absorption (skin contact). Although all these methods can occur in a workplace situation, some are less
likely than others. Chemicals can be ingested accidentally through contact with food or drink, and material
can be injected by mishandling of pressurized equipment like airless sprayers.

• OSHA Permissible Exposure Limit (PEL)

This information details exposure limits, called PELs, set by OSHA and other entities detailing the quantity
of a chemical that a person can be exposed to without suffering ill effects. Some manufacturers may
include Threshold Limit Values (TLVs) for chemicals. These are limits developed by the American Conference
of Governmental Industrial Hygienists (ACGIH). It represents the maximum amount of a substance that
someone can be exposed to without experiencing any effects. The TLV can be expressed in three ways: as a
time- weighted average (TWA), based on an eight-hour exposure; as a short-term exposure limit (STEL),
based on a 15-minute exposure; and as a ceiling (C), which is an instantaneous exposure that, when
reached, means the exposure cannot be repeated for the rest of the day.

• National Toxicology Program (NTP)

If a chemical is listed in the NTP Annual Report on Carcinogens or has been listed as a potential carcinogen
by the International Agency for Research on Cancer or OSHA, that information must be part of the MSDS
for the chemical.
• Obtain MSDSs. An MSDS is needed for each chemical at the workplace. If an MSDS
is not received with a shipment, the manufacturer should be contacted to request
one for inclusion in the MSDS file.
• While OSHA has developed a preferred format for a comprehensive MSDS, the
format of those received from manufacturers and suppliers may vary. OSHA
requires MSDSs to be in English and, at a minimum, include the following
information:

• Precautions
Safe handling and use precautions known to the manufacturer must be included in the MSDS. This includes
hygienic practices, protective measures during repair and maintenance of contaminated equipment, and
spill and leak cleanup procedures.
• Control Measures
Engineering controls, work practices and PPE generally applicable to the use of the chemical and known to
the manufacturer must be set out.
• Emergency and First-aid Procedures
First-aid treatment for exposure must be set out.
• Date
The date the MSDS was prepared or last revised must be stated on the MSDS.
• Contact Information
The name, address and telephone number of the preparer or distributor of the MSDS who can provide
additional information on the chemical and appropriate emergency procedures to be followed must be
included.
The standard excludes a number of particular materials from all requirements of the Hazard
Communication Standard. Materials excluded from the requirements are:

• Hazardous waste under EPA, to include Resource Conservation Recovery Act (RCRA)
and Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA)
• Hazardous substances being remediated or removed
• Tobacco and tobacco products
• Wood and wood products (Note: Not exempt are wood or wood products that have
been treated with a substance considered hazardous under this standard and may
be sawed or cut or might otherwise generate dust.)
• Articles―that is, items―such as asphalt shingles that are manufactured and formed
to a specific shape or design, which have specific end-use functions dependent upon
their shape or design and do not release any hazardous substances under normal
use (Note: Steel I-beams may not fit this definition because welding on steel
releases a by product.)
• Food or alcoholic beverages for consumption
• Drugs, including over-the-counter items
• Cosmetics and consumer products
• Ionizing and nonionizing radiation
• Biological hazards
These items do not need MSDSs nor should they be included in the hazard communication
program.
5. Develop a written program. Many contractors either neglect to develop a written
program at all or fail to include the minimum requirements. Each written program must
contain the following information:
• Container-labeling information
• Material safety data sheets
• Methods of training
• Chemical inventory lists
• Hazards of non routine tasks
Some companies choose to incorporate the program’s written text, chemical inventory list
and all MSDSs pertinent to their operations together in one binder. For smaller companies
with limited types of roofing operations, this may be adequate. Larger, more diverse
companies may want to develop several written programs, each pertaining to a separate
roofing operation or application. In such cases, the written text will be the same for each
program, but the chemical inventory list and MSDSs will vary.

6. Provide training. The goal behind HCS training is to provide employees with information
and training about hazardous chemicals they may encounter in the workplace. Training
may address broad categories of hazards (e.g., explosives, flammable liquids,
carcinogens) or each specific hazardous chemical (by label and MSDS) that the employee
may encounter in the workplace. Employers are responsible for administering additional
training when the hazards for particular employees change or new employees are hired.
All training should be documented with the date of training, topics covered during the
training session and the trainer’s name
 Chemical Inventory Record
The following information should be gathered for
each product used

• MSDS on file? Y/n

• id no.
• Product name
• Manufacturer’s name
• Address, city, state
• Manufacturer’s telephone number and
emergency telephone number