 John Smith. I'm a compliance officer with OSHA, the Federal Occupational Safety and Health Administration. I'm at a construction site where a team from my office is performing a comprehensive inspection. We're looking at everything, but I want to talk to you about how we inspect for compliance with our Hazard Communications Standard for Construction, 29 CFR, 1926.59. Do that on every inspection now, no matter what, because we want all employers and employees to know the hazards of the chemicals at their work sites. We've been enforcing the standard at construction sites since March of 89. Some of you working in states that have state programs may be covered under a slightly different plan. State plans have to be just as effective as federal OSHA programs, so all of the basic requirements for HazCom will be the same. A lot of construction folks ask me why OSHA has applied this standard to construction. They say, why we all know about safety hazards, like falling from scaffolds and open-sided floors, but chemical hazards, we don't have them. They're all recognized in construction. Petroleum solvents can cause a fire, explosives can blow up on you at the wrong time, and compressed gas cylinders can turn into rockets if they fall over. And I guess what some construction workers and their employers don't realize is that while some materials have commonly recognized fiscal hazards, they have health hazards too. Take solvents, for example. You can get dizzy if you breathe the vapors or your hands can get white and irritated if you spill the solvents on them repeatedly. Solvents can have other health effects too. And then there are all kinds of other chemicals that can cause problems if not controlled, from the cement that goes into a foundation, to the pipe-dope used on plumbing, to the mastic used for the roof. A partial list of hazardous chemicals commonly found on construction sites is included in the package that accompanies this videotape. And hazardous chemicals will have labels with some hazard warnings put on them by the chemical manufacturer. Be sure to check the labels of materials you purchase. Trade associations, labor unions, and local or regional committees concerned with occupational safety and health can give you more help at identifying the hazardous chemicals on your job site. But let's get to the heart of this discussion. You want to know what to expect during a hazard communication inspection on a construction site, right? Let's see what Joe Castillo, the compliance officer leading the hazard communication part of today's inspection is doing. The first thing Joe does today to check for compliance with the hazard communication standard happens in the opening conference with the general contractor when he asks for the written hazard communication program. Later, Joe will talk to all subcontractors about their programs. On some large job sites, the contractors may arrange to have a common program for the entire site. Having one program for the entire site may be easier at some job sites, and it's okay with OSHA as long as a job gets done. On other sites, the contractors may have their own individual programs. Either method is acceptable as long as the required information is shared with all employers and employees. If not, each employer on site as well as a general contractor could be cited for noncompliance. It's important to remember that any employer who has employees that may be exposed to hazardous chemicals brought on site by any contractor needs to have a written program. Joe studies the written program for compliance with the requirements of the standard. He wants to see written down who's in charge of the program at the site, who checks containers for proper labels, who puts labels on portable containers, and checks material safety data sheets or MSDSs for short to see that they're completely filled out. Material safety data sheets, which contain lots of information about the hazards of the chemicals and protective measures to use usually come from your building supply distributor or the manufacturer of the chemical. You need to have an MSDS for every hazardous chemical your employees are exposed to. You might ask well if I'm just using some consumer products from the local discount store and it's got a label with the hazards on it why do I need the body to get an MSDS? The answer is that labels on consumer products are governed by another federal agency that doesn't require all the hazard warnings needed for workers covered under our hazard communication standard. So unless your workers use that product just the same way and for the same amount of time as an average consumer you need an MSDS so you and your employees can learn about the hazards of the material. The compliance officer also wants to see the list of hazardous chemicals on site. Every hazardous chemicals that's used on the site by the contractor's employees must be on that list and the employer must have an MSDS for each one before it is used. At a work site where two or more chemicals are mixed together additional requirements apply. Joe also asked to see the contractor's training program for hazard communication. He wants to know who's doing the training, what trained materials are used and whether the employees are being trained about each hazardous chemical separately or about the various categories of hazards that are discussed in the standard such as flammables, carcinogens or corrosives. Employees must be trained on how to protect themselves from the hazards of the materials they work with. He wants to know how employees are trained about the hazards of materials in any unlabeled piping and what to do in emergencies. Remember all training must be done before an employee uses a chemical. If an employee has received training before either by another employer or a union he or she doesn't have to be trained again. If the new employer determines the previous training has adequately covered all the hazards at the new work site. Of course these employees will still have to be told where and how the present employer keeps the MSDSs, what types of labels are being used and any detail specific to that employer's hazard communication program. Joe will also check that the written program includes how the contractor makes MSDSs available for the use of his employees and other contractors. Other contractors need these MSDSs to be able to train and provide protection for their workers who may be exposed. After all different trades may work in the same area at the same time and workers may be exposed to chemicals brought on site by other employers. Some generals provide space for all contractors to leave their MSDSs and the job trailer or some other central location on the job site. Other employers keep their own MSDSs separately and provide copies directly to each contractor on the site whose employees may be exposed to the hazardous chemical. Sometimes a contractor will decide to keep all the MSDSs at the business office and either fax the MSDSs to the site when needed or set up a computer terminal to provide the information. These options are okay with OSHA as long as the employees have access to the MSDS information in readable form about chemicals brought on site by both their own and other employers. Employees must be able to get the information when they need it during their own work shifts. After the opening conference with the general contractor is finished Joe meets all subcontractors to go over their written programs. After that he is ready to begin his walk around of the job site. On the walk around he checks to see if containers of hazardous chemicals are properly labeled and makes notes about several of them. Each label must have on it the chemicals name, its hazards and for ship containers the name and address of the manufacturer. If a portable container is filled and used by a single employee on a single shift that container does not have to be labeled. Joe interviews several employees to see if they know and have been provided training on the hazards of the chemicals they are working with and if they are using proper methods to protect themselves such as safe work methods or the right protective equipment. Be sure to check the MSDS for this information about the hazardous chemicals at your job site. After the walk around is completed Joe asked the employer to see several of the MSDS's for materials which he noted during his walk around. He also checked to see that the chemicals are on the master list of hazardous chemicals. He checks the MSDS's to see if they are completely and accurately filled out. Then if any of the requested MSDS's are missing or contain any blank spaces Joe is going to want to see any documentation you have of your attempts to get proper sheets. As with any OSHA inspection Joe's findings will be reviewed by his supervisor. Citations for alleged violations of the hazard communication standard if any are issued by the area director. So you can see a hazard communication inspection is really pretty straightforward. The compound officer wants to be sure that all hazardous chemicals on site have been identified, that all containers have been properly labeled, that MSDS's for the chemicals have been obtained, and that employees have access to them, and that all employees have been trained to know the hazards of the chemicals they work with as well as how they can protect themselves. If the construction site is a multi-employer job site, employees who are working exposed to hazardous chemicals from their own site by other contractors must also make sure that MSDS's are exchanged or otherwise available for access by all exposed employees own site. Also workers must be trained on the hazardous chemicals used by other contractors employees who work around them. And of course how the contractor will go about getting this done must be written down in the written hazard communication program. A copy of the hazard communication standard is included in the package with this videotape. There's also a copy of a short booklet called Hazard Communication guidelines for compliance, which has been prepared by OSHA to further explain how to go about complying with the standard. If you have any questions about hazard communication after reading these two documents, your local OSHA area office or regional office will be happy to answer them. OSHA also funds free consultation services in each state for employers needing more assistance. A list of these consultation services as well as the addresses of the OSHA regional offices is included in the guidelines. Of course persons in states with OSHA approved state programs should contact the state for details of its standard. Well I've enjoyed talking with you. I hope I have to get a better handle on what we'll be looking for if we show up at your site and want to know more about your hazard communication program.