By Gregory Havel
In today’s world, hazard communication is no longer a topic that interests only the technicians employed by chemical manufacturers and the hazmat specialists employed by emergency response agencies. The hazard communication standards contained in the Occupational Safety and Health Administration’s (OSHA’s) 29 CFR 1926.59 and 1910.1200 [and similar to Environmental Protection Agency and Department of Transportation regulations] are now of interest to managers in health care and educational facilities, to corporate risk managers, and to building contractors.
Container labeling and safety data sheets [SDSs, formerly material safety data sheets (MSDSs)] are the foundation for hazard communications under statutes and their supporting regulations. Many health care facilities and schools require contractors to provide SDSs for all products used in a new construction or remodeling project. These are kept on file to provide reference materials if an issue arises with construction quality, materials, or components such as asbestos, lead, and polychlorinated bi-phenyls (PCBs).
Some construction projects, especially government, health care, and educational facilities will not permit any product to be brought on site without proper labeling and without the SDS and other technical information being provided to the facility or construction manager. These often become part of the permanent record of that project in that building on that campus.
Photo 1 shows one bag on one of several pallets of bags of a construction material. Thirty-five bags per pallet at 80 pounds (36.3 kg) each equals 2,800 pounds (1,273 kg) per pallet. Five pallets equal 14,000 pounds (6,364 kg). The only label on these bags is on one side stating the health concerns of one of the ingredients, the warranty information, and the manufacturer’s name and address. The other five sides of the bags are blank brown paper. This is not sufficient labeling under OSHA’s Hazard Communication Standard for an employer to permit employees to use, is not sufficient to connect the product to its SDS or MSDS, will not be sufficient for the permanent building record at a health care or educational facility, and is not sufficient information if the material is spilled during an emergency response.
(1) Photo by author.
If this product had been properly inspected at the time of delivery, the shipment should have been rejected because of a lack of labeling. Now that it is in the contractor’s warehouse, it must be held unused until the manufacturer or supplier provides labeling information and labels and the proper SDS. This procedure is time consuming for the contractor and the supplier or manufacturer. And, on some construction projects, the owner would not accept this procedure since the labels were not applied to the packages at the time that they were filled. Although the packages probably contain what the new label states, the probability could be less than 100-percent certainty. That lack of certainty can make the presence of the product on site and its use unacceptable to the owner, who is entitled to the materials, products, and workmanship as stated in the contract.
This kind of record keeping by building owners and managers can provide valuable information to emergency services responders in the event of a fire, explosion, or structural collapse. If building records show that the structure was completed using materials that did not include asbestos, lead, other heavy metals, and PCBs, it can eliminate responders’ natural concern about their possible exposure to these toxic, hazardous materials. If the building involved was a storage occupancy and all of the stored materials had proper labeling, SDS, and other documentation, it would also eliminate responder concerns.
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Gregory Havel is a member of the Town of Burlington (WI) Fire Department; retired deputy chief and training officer; and a 35-year veteran of the fire service. He is a Wisconsin-certified fire instructor II, fire officer II, and fire inspector; an adjunct instructor in fire service programs at Gateway Technical College; and safety director for Scherrer Construction Co., Inc. Havel has a bachelor’s degree from St. Norbert College; has more than 35 years of experience in facilities management and building construction; and has presented classes at FDIC.
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