WRITTEN BY GARY SMITH, APARTMENT BUILDING MANAGEMENT WORKERS COMPENSATION SELF INSURED FUND
Michigan’s Right to Know Law, signed into law on April 7, 1986, applies to all Michigan employers. Recent amendments to the hazard communication standards align them with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). As a result, MIOSHA revised its compliance guide, SP #22 (see References), to assist Michigan employers with updating their hazard communication programs.
Employers are required to provide information to employees about the hazardous chemicals to which they are exposed by means of:
Written Program – Employers must develop, implement and maintain at the workplace a written, comprehensive Hazard Communication Program that includes provisions for container labeling, employee access to Safety Data Sheets (SDS) and an employee-training program. The plan must contain an inventory of the hazardous chemicals present in the workplace. Examples of typical hazardous chemicals include gasoline, diesel fuel, motor oil, lubricants, wood preservatives, wood finishes, solvents, parts cleaners, pool chemicals, etc. Additionally, when outside contractors work at a facility, the resident company must ensure their safety from hazardous chemicals.
Labels – Containers housing hazardous substances are required to be labeled to ensure that employees are fully informed as to the identities of the materials they are exposed to, and any inherent danger when that substance is handled. Labels provide employees with an immediate source of information and should not be removed or defaced. If a hazardous chemical is transferred from a large container to a smaller (secondary) container, or a label falls off, you may find it necessary to produce or update a label.
Safety Data Sheets (SDS) – The Hazard Communication Standard requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products to their customers. As of June 1, 2015, the Standard will require new SDSs to be in a uniform format. Copies of these SDSs for hazardous chemicals or products need to be readily accessible to employees in each work area and during each work shift. If you do not have a current SDS, you can request one from the manufacturer.
Training – Training is a critical part of the program. Employers need to provide exposed employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Employee training shall include at least:
• Methods and observations to detect the presence or release of a hazardous chemical such as use of monitoring devices, visual appearance or odor of chemicals when being released, etc.
• The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.
• The measures employees can take to protect themselves from these hazards such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
• The details of the program developed by the employer including an explanation of container labels, the workplace labeling system, the safety data sheet and employees can obtain and use the appropriate hazard information.
Should you require assistance with your Hazard Communication Program, please contact Gary Smith, CRM, at (517) 338-3367 or Gary.Smith@cmi-yorkrsg.com. n
References:
1. MIOSHA Employers’ Compliance Guide, SP-22: http://www.michigan.gov/documents/lara/lara_miosha_cetsp22_379146_7.doc
2. MIOSHA Hazard Communication Standards at:
http://www.michigan.gov/documents/CIS_WSH_part_42_47164_7.pdf