Page 72 - Root Cause Failure Analysis
P. 72

Regulatory Compliance Issues   63

                   WORKER EDUCATION AND COMMUNICATION
                   Employers must ensure that their workers know the potential hazards of the chem-
                   icals they  work with,  how to protect  themselves against those hazards  (e.g., safe
                   practices, personal protection equipment), and what to do in case of an emergency.
                   Accordingly, OSHA has established basic communication requirements under the
                   Hazard Communication Standard to inform workers about chemicals in use in the
                   workplace.  Under  this  standard,  chemical  makers  must  meet  the  following
                   requirements:

                           Manufacturers  must  determine  the  physical  and  health  hazards  of  each
                           chemical they produce.
                           Users must be informed of the hazards through container labels and Mate-
                           rial Safety Data Sheets (MSDSs).
                           A  written hazard-communication program  must  describe  the  employer’s
                           efforts to tell employees about the standard and how it is being implemented
                           at the work site.



                   PREVENTION
                   Preventive  measures  include everything from  safe  work  practices  to  training  pro-
                   grams, good housekeeping, regular audits, administrative and engineering controls.
                   and chemical-protection equipment.

                   Workers must be properly trained to handle the responsibilities assigned to them, with
                   members of  a designated spill team  undergoing  more specialized training than  the
                   average  employee.  All  worker  training  should  include  the  basic  instruction  that
                   employees  not  involved  in  cleanup must  stay  away from a  spill. This  is important
                   because  of  risks  such  as  inhaling  chemical  vapors  or  fire  or  explosion  hazards.
                   Another  important lesson to  teach  workers  is how  to prevent  a  spill or leak from
                   becoming worse. Proper containment can mean the difference between a small prob-
                   lem and a huge, dangerous mess.


                   RECOMMENDED SPILL RESPONSES

                   The following steps are recommended responses when a chemical spill occurs.
                          1.  If necessary, evacuate the area of untrained spill-response personnel.
                         2.  Check labels, MSDSs, and other key documentation to identify what has
                            spilled.
                         3.  Assign at least two qualified individuals to the cleanup. They may be inter-
                            nal staff or from an outside firm that you have prearranged to handle this
                            task. Two workers are needed in case one is overcome or injured.
                         4. Promptly clear the spill area by ventilation.
                         5.  If the spilled material is on fire, douse the flames in a safe manner.
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