OSHA Standards for Farmers
Hazard Communications MSDS & Chemicals
by Chris E. Marsh, M.Ed.
Part 2: Hazard Communications
This is the second in an ongoing series of monthly web exclusive features about our industry and OSHA regulations.
Check out Part one HERE.
This report is on Hazard Communications for farmers and comes from the General Industry section of the OSHA standards. Employers, including vegetable, fruit and nut tree farmers, must develop, implement and maintain a written Hazard Communications program at each workplace that describes how the criteria will be met that are part of the standard for labels and other forms of warning, the Material Safety Data Sheets (MSDS), and employee information and training. There must also be a list of the hazardous chemicals known to be present, using an identity that is referenced on the appropriate MSDS and can be cross-referenced with the files and containers. The employer must also describe the method to be used to inform employees of the hazards of nonroutine tasks and the hazards associated with the chemicals contained in unlabeled pipes in their work areas. Remember, all training must be done or provided in a language that each worker understands.
Many different chemicals are used in agriculture. What one farmer uses, the farmer next door may never buy, so if a new group of employees come on your farm or orchard, they should receive this training. Do not depend on memory or hope that everyone knows what an MSDS is and how to read it.
Employers must obtain an MSDS for each hazardous chemical in the workplace and ensure that each sheet is available to the employees for immediate access during each work shift. You can obtain the MSDS from your chemical supplier or over the Internet. One thing that many people forget is that if you store diesel, gasoline or oil at your workplace, these are chemicals, have the potential to harm people or the environment through a spill and require an MSDS. Immediate access does not mean a computer in a locked office. It would mean that someone must be able to find the chemical dangers in a very few minutes for the safety and well being of the employee.
Each hazardous chemical container must be labeled and marked with the identity of the chemical and appropriate hazard warnings. The label must not be removed, defaced or unreadable. If you transfer a hazardous material to another container, you must provide the same label as the original container, or a readable label that is large enough to let the worker know what is in the second container.
Employees must be trained at the time of their initial assignment and whenever a new physical or health hazard is introduced into their work area. Training must include information on the hazardous chemicals present in the work area, protection against the hazardous effect of the chemicals, the requirements of the Hazard Communication Standard, the employer's Hazard Communication program, and the contents and use of MSDS. Training should be documented with the date of the training, the trainer's name and credentials, the name and social security number or work permit of each participating employee, and the subject of the training given.
Why is the MSDS important?
The main reason to have an MSDS available is that chemicals have different ingredients. The combination of ingredients used to make the chemical can cause different reactions. Some chemicals are flammable, some are health hazards, some are corrosive, and some are reactive. There are also instructions to follow if you have a spill. The chemicals follow the Department of Transportation (DOT) placards with the 1-4 numbering system to denote danger.
Having this information available for other workers or for EMTs or other rescue personnel could mean the difference between life and death. If they have to be called because of contact with a chemical, the most helpful thing that can be done upon their arrival is to give them a copy of the MSDS so they can determine what type of treatment the injured or poisoned person needs. This means they can start treatment immediately and alert the ER to what is going on.
Remember that each different operation you have is required to have the training and MSDS for all chemicals. For example, let's assume you have a vegetable operation and an orchard. You also have a mechanic that welds and does mechanical work on engines and machinery. You also own a roadside stand and kitchen where you process your vegetables into value-added products for sale. You need several different sets of MSDS sheets. For example, you need them for any chemicals used in the vegetable operation and a separate set for the chemicals used in the orchard. The mechanic would be exposed to a different set of chemicals, while the employees at the roadside stand and kitchen would be involved with a completely different set of chemicals. So, for each part of the operation you need the appropriate MSDS. Also, the layout of the MSDS has changed. U.S. OSHA and the Labor Department have decided to go with the European Union on how an MSDS sheet is arranged, so unless you have gotten new MSDS since February 2012, you may not have the current ones.
One final note:
First aid kits must be available and employees trained to provide first aid. If any chemicals are dangerous if spilled, you should also have some type of containment process and the employees should know what it is.
Hazard Communications is one of OSHA's top 10 cited standards year after year. It is also one of the standards that, outside of construction, generate a lot of money in fines. It is in your best interest and the best interest of your employees that you follow the OSHA standard.
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