OOD Chemical Management Surveillance Guide OSS-19.12

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Activity 1: Evaluate the general hazard communication program, including documentation and training, MSDS availability, worker exposure control, etc.

Is there a written hazard communication program which addresses labeling and other forms of warning, material data safety sheets (MSDS), and employee information and training? 29 CFR 1910.1200 (e) (1)
Is there a list of hazardous chemicals known to be present using a product identifier that also provides a reference to appropriate MSDSs? 29 CFR 1910.1200 (e)(1)(i); 29 CFR 1910.1200 (h)(2)(iii)
Are MSDSs readily available during each work shift to employees in their workplace for each hazardous chemical? 29 CFR 1910.1200 (g)(1) 29 CFR 1910.1200 (e
Is the hazard communication program available to all employees? 29 CFR 1910.1200 (e)(4)
Do employees receive effective information and training on hazardous chemicals in their work area or with which they work? 29 CFR 1910.1200 (h) (1) 29 CFR 1910.1200 (f) (1)
Does the training include measures employees can take to protect themselves from the chemical hazards (procedures, work practices, and PPE)> 29 CFR 1910.1200 (h) (3) (iii) 29 CFR 1910.1450 (f)(4)(i)(C)
Does the training include the physical and health hazards of the chemicals including exposure limits? 29 CFR 1910.1200 (h)(3)(ii) 29 CFR 1910.1450 (f)(4)(i)(C)
Does the training include the details of hazard communication program, including an explanation of labeling systems, MSDSs, and how employees can obtain and use hazard information? 29 CFR 1910.1200 (h)(3)(iv) 29 CFR 1910.1450 (f)(3)(v)
Have employees been informed of the location and availability of the hazard communication program, the required list of chemicals, and the location of MSDSs? 29 CFR 1910.1200 (e)(1)
Do employers ensure that employees do not exceed OSHA Permissible Exposure Levels (PEL) or American COnference of Government Industrial Hygienist Threshold Limit Values (TLV), whichever is more restrictive? 29 CFR 1910.1450 (c) DOE O 440.1 A , Section 4.1 Doe O 440.1 A, Attachment 2, Section 12.g
Do employers measure employee exposure to chemicals if it is believed that action levels or PELs may have been exceeded? 29 CFR 1910.1450 (d)(1) 29 CFR 1910.1450 (d)(2)
Do employers notify employees of monitoring results within 15 workdays of receipt of such information? 29 CFR 1910.1450 (d) (4)
Do employers have a Chemical Hygiene Plan for laboratory use of chemicals (laboratory use-laboratory scale, multiple chemicals/procedures, non-production chemical use, standard laboratory protective practices)? 29 CFR 1910.1450 (e) (1)
Is the Chemical Hygiene Plan capable of protective employees from health hazards associated with hazardous chemicals? 29 CFR 1910.1450 (e)(1)(i)
Does the Chemical Hygiene Plan provide provision for keeping exposures below limits? 29 CFR 1910.1450 (e)(1)(ii)
Is the Chemical Hygiene Plan readily available to employees? 29 CFR 1910.1450 (e)(2)
Does the Chemical Hygiene Plan identify standard operating procedures relevant to safety and health consideration for handling chemicals? 29 CFR 1910.1450 (e)(3)(i)
Does the Chemical Hygiene Plan provide criteria used to determine and implement control measures to reduce employee exposure of the hazardous chemicals? 29 CFR 1910.1450 (e)(3)(ii)
Does the Chemical Hygiene Plan provide requirements that fume hoods and other protective equipment function properly? 29 CFR 1910.1450 (e)(3)(iii)
Does the Chemical Hygiene Plan contain provisions for employee information and training relative to chemical hazards? 29 CFR 1910.1450 (e)(3)(iv)
Do training records substantiate that workers have received required training on hazard recognition and control related to chemical safety? 29 CFR 1910.1200 (h)(3)(i) 29 CFR 1910.1450(f)(1)

Activity 2: Observe Chemical storage locations and storage practices.

Is each container containing a hazardous chemical labeled, tagged, or marked with the identity of the chemical, and appropriate hazard warnings? (Labels are not required on portable containers into which chemicals are transferred from labeled containers and which are intended only for immediate use of the employee who made the transfer) 29 CFR 1910.1200 (f)(5) 29 CFR 1910.1200 (f)(7) 29 CFR 1910.145 (h)(1)(i)
Are the labels on containers legible and prominently displayed? 29 CFR 1910.1200 (f)(9) 29 CFR 1910.1450(h)(1(i)
Do portable tanks have one or more devices installed in the top with sufficient emergency venting capacity to limit internal pressure under fire exposure conditions to 10 psig or 30% of the bursting pressure of the tank, whichever is greater? 29 CFR 1910.106 (d)(2)(ii)
Do portable container meet the maximum allowable size of containers and portable tanks for flammable liquids? 20 CFR 1910 (d)(2)(III)(a)(2) Table: Maximum Allowable Size of Containers and Portable Tanks for Flammable Liquids Container Type Category 1 Category 2 Category 3 Category 4 glass/approved plastic 1 pt 1 qt 1 gal 1 gal metal (not DOT drums) 1 gal 5 gal 5 gal 5 gal safety cans 2 gal 5 gal 5 gal 5 gal DOT metal drums 60 gal 60 gal 60 gal 60 gal Approved portable tanks 660 gal 660 gal 660 gal 660 gal Category 1 shall include liquids having flashpoints below 73.4 F (23C) and having a boiling point at or below 95 F (35C) Category 2 shall include liquids having flashpoints below 73.4 F (23C) and having a boiling point above 95F (35C) Category 3 shall include liquids having flashpoints at or above 73.4 F(23C) and a boiling point at or below 140 F (60C) Category 4 shall include liquids having flashpoints above 140 F (60C) and a boiling point at or below 199.4 F (93C)
Do flammable storage cabinets contain less than 60 gallons of Class I or CLass II liquids or less than 120 gallons of Class III liquids? 29 CFR 1910.106 (d)(3)(i)
Are flammable storage cabinets conspicuously labeled "Flammable Keep Fire Away"? 29 CFR 1910.106 (d)(3)(ii)
Does the flammable storage cabinet meet the design requirements of 29 CFR 1910.106 (d)(3)(ii)(a)? Metal cabinets shall: **the bottom, top, door and sides of cabinet shall be at least No 18 gage sheet iron and double walled with 1.5" air space **Joints shall be riveted welded or made tight by some equally effective means ** Doors shall be provided with three-point lock, and the door sill shall be raised at least 2 inches above the bottom of the cabinet
Do flammable storage rooms meet the requirements of 29 CFR 1910.106(d)(4) for room design, quantiy of liquid stored, ventilation, storage spacing, electrical requirements, etc.?
Are suitable fire control devices, such as fire extinguishers, available at locations where flammable or combustible liquids are stored? 29 CFR 1910.106 (d)(7)(i)
Are incompatible chemicals/materials segregated to prevent accidental contact with another? (i.e. storing oxidizing acids and flammable solvents in separate locations) NFPA Standard 45, 7-2.3.4
Are safety showers and/or an eyewash stations provided within the work area for immediate emergency use? 29 CFR 1910.151 (c)

Activity 3: Observe work activities involving handling or use of chemicals.

Are users of flammable/combustible liquids familiar with the hazard classification of the liquid? 29 CFR 1910.1200 (h)(3)(ii)
Is bonding used when transferring Class I flammable liquids between two conductive containers of volume greater than 1.1 gallon? 29 CFR 1910.106(3)(6)(ii) NFPA Standard 45, 7-2.2.8
Has the maintenance work package or work activity been reviewed by representatives of the safety and/or environmental organizations for appropriate safety and environmental controls? 29 CFR 1910.132 (d)(1) 48 CFR 970.5204-2(b)(5)
Was an appropriate job safety analysis performed for the work activity, identifying the hazards and implementing controls? 29 CFR 1910.132 (d)(1) 48 CFR 970.5204-2(b)(5)
Do the work instructions address use of specific PPE such as safety glasses with side shields, rubber gloves, aprons, etc? 29 CFR 1910.132 (d)(1)(i) 29 CFR 1910.1200 (h)(3)(iii) 29 CFR 1910.145 (f)(4)(ii)
Do the work instructions include procedures in sufficient detail to ensure the safety and health of the workers? 29 CFR 1910.1200 (h)(3)(iii) 29 CFR 1910.1450 (e)(3)(i) 48 CFR 970.5204-2(b)(6)
Were potential chemical hazards discussed with workers during the pre-job brief? 29 CFR 1910.1200 (h)(3)(ii)
Are workers using the personnel protective equipment specified in the work instructions or procedures while performing the activity? 29 CFR 1910.132 (a) 10 CFR 830.120 (c)(2)(i)
Do workers follow instructions/procedures prescribed int he work package? 10 CFR 830.120 (c)(2)(i)
Can workers describe the chemical hazards associated with the work they are performing? 29 CFR 1910.1200 (h)(3)(ii) 29 CFR 1910.1450 (f)(4)(i)(B)
Were workers provided the opportunity to review and understand the MSDSs for chemicals associated with the activity? 29 CFR 1910.1200 (h)(1) 29 CFR 1910.1200 (h)(2)(iii)
Can workers describe the correct response to an emergency involving chemical hazards? 29 CFR 1910.1200 (h)(2)(iii) 29 CFR 1910.1450 (f)(4)(i)(C)