The Employee Right to Know/Hazard
Communication Act requires a survey/inventory of
hazardous substances in your workplace. A hazardous
substance is defined as:
- All chemicals and products which contain chemicals listed in OSHA CFR 910.1200
- Subpart 2. This is a list of several hundred chemicals which the Federal OSHA Hazard Communication Standard considers hazardous.
- Chemicals or products which are hazardous by definition, i.e. are toxic, cause burns, are flammable or reactive, etc., or labeled with appropriate warnings.
- Chemicals listed in the NIOSH Registry of Toxic Effects of Chemical Substances.
- Any unknown or unlabeled chemical or substance.
The task of undertaking the inventory and keeping it current can seem overwhelming. However, the importance of conducting an inventory cannot be over-emphasized. Without knowing which chemicals are stored in your facilities, you cannot provide a safe work environment for your employees.
We continually get calls from clients throughout the United States about accidents/exposures/ spills of hazardous substances, sometimes very dangerous substances that should not be used in most facilities and can easily be replaced with less hazardous substances.
The following illustrates some of the problems associated with not managing or mismanaging chemicals:
- A custodian on a weekend shift noticed a strong chemical odor coming from a storage closet. The odor was so strong the custodian left the building and notified authorities.
- Further investigation determined that a shelf in the closet had broken, spilling chloroform, benzene and trichlorethylene - chemicals which are not recommended for use and storage in schools or most other facilities. A special hazardous materials handling team had to clean up the spill, resulting in tremendous expense.
- A number of very corrosive chemicals were stored on a wooden shelf. They spilled on the wood, corroding the shelf and causing it to break onto another shelf storing picric acid and potassium metal, two highly explosive compounds. Luckily, no explosion took place but, again, the costs for clean up were astronomical.
The following is a list of chemicals frequently found in schools and other facilities which should be disposed of:
- Arsenic Peroxide (KC)
- Arsenic Powder (KC)
- Arsenic Trichloride (KC)
- Arsenic Trioxide (KC)
- Asbestos (KC)
- Benzene (KC)
- Benzidinc (KC)
- Benzoic Peroxide (E)
- Cadmium Powder (PC)
- Cadmium Sulfate (PC)
- Carbon Disulfine (E)
- Carbon Tetrachloride (PC)
- Chloroform (PC)
- Chromium VCR Oxide (KC)
- Chromium Powder (KC)
- DiisoprofyL Ether (E)
- Ethyl Ether (E)
- Ethylene Oxide (PC)
- Lead Arsenate (KC)
- Nickel Powder (PC)
- O-Toluidine (PC)
- Perchloric Acid (E)
- Picric Acid (E)
- Potassium Metal (E)
- Sodium Arsenate (KC)
KC - Known Human Carcinogen
E - Explosive
PC - Probable Human Carcinogen
A quick survey/inventory can be done to determine if your school has any of these chemicals and, at the same time, you can make a note of unknown chemicals you have stored. (When dealing with unknowns, you have to assume the worst-case scenario.) Arrangements can be made to dispose of these chemicals.
Since disposal of hazardous waste is controlled by local, state and federal laws, consult authorities for guidance.
The survey and disposal will require some effort, but the result will be a safer workplace for employees and students - as in the commonsense statement, "The best way to deal with a hazard is to eliminate it."
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