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192 Safety Reference
Right to Know Laws* or
Hazard Communication Standards
1-800-452-1261
flinnsci.com
There is some confusion about the use of hazardous chemicals in academic institutions and about how the relevant “Right-to-Know” laws apply. The United States government has passed the Hazard Communication Standard (usually referred to as the “Right-to-Know” law) and the Laboratory Standard, but these laws do not extend coverage to state and local governments. However, almost all state governments have either passed their own version of the Hazard Communication Standard or put their stamp of approval on the federal laws and extended their jurisdiction to cover local and state govern- mental bodies—including public institutions. Federal jurisdiction does apply to all private institutions.
The purpose of these laws is to inform employees about any hazards associated with an employee’s work. Employees have the “right to know” about all the hazards they might deal with in the workplace.
• Chemical name
Flinn Scientific is Your Safer Source...
Flinn will help you meet all the requirements of the Right to Know laws with easy-to-use and affordable solutions. From the favorite Flinn Scientific Catalog/Reference Manual to the infor- mative Flinn website at flinnsci.com to our helpful staff scientists, you are never more than a phone call (800-452-1261) or e-mail ([email protected]) away from the best safety advice available. We have more than 40 years of experience helping teachers solve their safety problems, so let us help you meet your legal require- ments of the Right to Know Laws.
GHS Revision
In March 2012 OSHA published the first major revision to the Hazard Communication Standard since its inception. In announcing the revi- sion to incorporate what is known as GHS, OSHA stated that its goal was to transform the “right to know” into the “right to understand” chemical hazards. GHS stands for the Globally Harmonized System of Classification and Labeling of Chemicals. GHS is a document that establishes objective criteria for classifying and identifying chemical hazards. The overarching goal is to ensure the safe use of chemicals by providing practical, reliable, and comprehensible information on their hazards. GHS provides a set of objective criteria for classifying the physical and health hazards of chemicals. To remove ambiguity about the degree of risk inherent in using a chemical, GHS further specifies the use of standard symbols and language elements to convey the hazard information on chemical labels. Hazardous chemical labels will be required to include pictograms, a signal word, as well as specific hazard and precautionary statements.
Major Requirements
The federal and most state Right to Know laws contain the following six requirements or provisions.
1. Safety Data Sheets (SDS)
SDS are the primary way of communicating the hazards of a chemical to an employee or an employer. The SDS provision of the law requires the employer to acquire, update and maintain SDS for all of the hazardous chemicals used or stored in the facility and to make those SDS available to the employee for informational purposes.
The minimum standards for SDS include: • The SDS must be written in English
* The Right to Know law summary information listed here was obtained from reliable sources. For more information, go to www.flinnsci.com/safety for the name and address of the agency in your state that regulates these laws and standards.
• Hazards identification with GHS signal word, pictograms, hazard class, and applicable hazard statements.
• Hazardous components
• Physical characteristics (density, flash point, etc.)
• Physical hazards (fire, explosion, reactivity)
• Health hazards (both chronic and acute). All signs or symptoms of exposure must be listed. Carcinogens must be identified.
• Primary routes of entry and target organs
• Permissible exposure limits or TLV
• Any applicable precautions (gloves, goggles, fume hood, etc.)
• First aid and emergency procedures (chemical splash, spill handling, etc.)
• Date prepared
• Name and address of the manufacturer or SDS preparer including the phone number.
2. Hazardous Materials List
A list of all hazardous chemicals must be assembled. In most states this list is kept only by the employer and access is given to the employee on request. Some states require a copy of this list to be given to the fire department or some other state agency. See the state-by-state break- down of the Right to Know laws for further details.
3. Inventory
The hazardous materials list and an up-to-date inventory usually go hand in hand. Both the list and the inventory must be continually updated. An inventory of all hazardous chemicals is an essential requirement of most Right to Know laws. An inventory consists of the name of the chemical, how much you have, and where it is stored.
4. Notification
All laws require the employer to notify the employee of any potential exposure or actual exposure to a hazardous substance. This is initially accomplished by posting the Right to Know regulations or a poster where it can be easily read and will be noticed by the employee. Notification is also accomplished through training and employee access to SDS.
5. Training
Many state laws are very detailed and specific in the area of training requirements of employees. Most states require training to be done on an annual basis or when exposure to a new hazard is anticipated. Some states require this training to be in written form while others allow verbal training or some combination of both types. Training includes:
a. Learning to read labels and SDS
b. Providing the locations of hazardous materials
c. Learning the hazards associated with the materials in the work- place, both chronic and acute
d. Safe handling of chemicals
e. Use of protective equipment (fire extinguishers, respirators, etc.)
f. First aid and emergency procedures (spills, exposure, splashes, etc.)
RIGHT TO KNOW LAWS OR HAZARD COMMUNICATION STANDARDS continued on next page.