 EMSHA's hazard communication standard requires you to inventory your mines chemicals and to decide what your hazardous. If a chemical is hazardous, it must be included in your HAZCOM program. That means you must make sure it's labeled. You also have to keep a copy of its material safety data sheet, which we call an MSDS, and you have to train your miners about the chemicals hazards as well as how they can protect themselves from those hazards. We made this video to help you learn how to inventory the chemicals that you find and how to decide what your hazards. Your miners don't need to be afraid of chemicals. Millions of people work safely with them every day, but their health isn't steak and you have to provide a safe and helpful workplace. We realize that in any industrial environment exceptions can occur. Equipment can wear out, leaks can develop, machinery can run into containers. Where emergencies can happen or when chemical over exposures can harm your employees, they need to have the knowledge to protect themselves. That's what EMSHA's hazard communication standard or HAZCOM is for. Now what do you have to do to comply with HAZCOM and how does it work? If your operation is like most mines, compliance is not complicated. You have to inventory the chemicals at your mine and determine what your hazardous. Keep a list of the hazardous chemicals. Establish a written HAZCOM program. We have models that you can use for a pattern. Prepare a label and MSDS for your product. Make sure the containers of hazardous chemicals are labeled. Keep a file or book of MSDSs for the hazardous chemicals at your mine. Train your miners about the HAZCOM program and the hazardous chemicals they can be exposed to. Allow your miners to look at the HAZCOM information you have and give them a copy of it if they ask. Hazard determination is your chemical inventory. You must look at all the chemicals at your mine and decide which can be a physical or health hazard. Some chemicals are physical hazards. Some are health hazards. Some can be both and some are neither. Some chemicals are exempt from HAZCOM because they're already regulated by other federal agencies. HAZCOM has an entire section of exemptions from the rule and before you inventory your chemicals you need to know what chemicals you can exclude. If you buy an ordinary consumer product you do not have to include it in your mines HAZCOM program if you use it as a manufacturer intended and it does not expose the miner more often or for longer duration than ordinary consumer use. Here's an example of what we mean. You bought cleaner with ammonia for your truck drivers to clean their windshields. The drivers clean them two or three times each shift. Should you include the cleaner in your HAZCOM program? The answer is no. Your truck drivers are using it like an ordinary consumer would. Suppose you bought the same ammonia based cleaner for your janitor to use. He'd use the cleaner on counters, mirrors, windows, bathroom tile and other parts of your mill all day long. Should you include the cleaner in your HAZCOM program? Yes. The cleaner will be used as the manufacturer intended but the janitor is exposed to ammonia for a longer time than an ordinary consumer would be. Manufactured goods such as plastic pipes, conveyor belts, repair steel and tires are at every mine. For the purpose of HAZCOM such goods are articles. Even if they contain a hazardous chemical articles are exempt. There are two conditions though. They must release no more than insignificant amounts of a hazardous chemical and pose no physical or health risk to exposed miners. This galvanized pipe is perfectly safe under ordinary mine conditions and under ordinary conditions it poses no hazard and as an article is exempt from HAZCOM. Does anyone ever weld on galvanized pipe? It happens in a lot of places. Among other problems galvanized pipe is coated with numerous hazardous chemicals including lead. When you're welding on it, significant amounts of lead fume are created among other health hazards and the pipe is no longer exempt. You don't need to include personal items such as food, tobacco, drugs or cosmetics in either your hazard determination or your HAZCOM program. They are exempt if they are packaged and labeled for retail sale and intended for an individual miner's personal consumption or use. For example suppose you bought several gallons of a gel hand cleaner at an auto parts store for use in your mind's maintenance shop. The label says it is an eye irritant and it does not contain harsh solvents. The store didn't have an MSDS to give you but you get one through the products web page. The MSDS says that the product contains the following hazardous ingredients mineral oil, sodium hydroxide and ethanol. The product is safe and presents no immediate or long-term health hazard. Ingestion may require medical attention and OSHA standards and SARA Title 3 do not apply to this cosmetic product. Do you need to include this soap in your HAZCOM program? The answer is no. The FDA has classified soaps as cosmetics and cosmetics are exempt under HAZCOM definitions. Also you can rely on the manufacturers MSDS when it says that OSHA standards do not apply and you can infer that it also doesn't imply to HAZCOM. HAZCOM was designed to be fully compatible with the requirements of OSHA's hazard communication standards. If you're using a chemical product at your mind and it's not listed in HAZCOM's exemptions how can you tell if it's hazardous? First you should check the products label and MSDS. There you're most reliable source of information about the hazards a chemical can pose. But beyond the label and MSDS there are two questions that you'll ought to ask about chemical. Can it cause harm and can a minor be exposed to the harm under normal conditions of use or in a foreseeable emergence? If you answer yes to both of these questions considered the chemical hazardous under HAZCOM. The basic rule of thumb however is to consider a chemical hazardous if its label or its MSDS says it's hazardous. What do we mean by foreseeable exposure? If a minor cannot be exposed to a chemical or the risk of exposure is so slight that it's unperseeable the chemical should not be included in your HAZCOM program. Let's say that your truck drivers do not help with repairs on your trucks. Only mechanics perform this work. Your drivers therefore are not exposed to a solvent that's used to remove gasket material in the shop. For your drivers the exposure to the solvent is unperseeable but for your mechanics the exposure is foreseeable. You have to include the solvent in your HAZCOM program but you only need to train your mechanics not your truck drivers about the solvents hazards. So those are the basic ideas behind making a hazard determination. Let's look at some chemicals that are often found at mines and do a hazard determination on those. Diesel fuel is the most common of all mine chemicals. You have three pieces of diesel powered equipment at your open pit mine which you fuel with off-road diesel number two. The MSDS says this product is a combustible by Department of Transportation standards. The MSDS also says that long term repeated exposure of laboratory animals to hold diesel exhaust has resulted in an increased incidence of lung cancer in them. The National Fire Protection Association indicates no health hazard. Let's say one person is assigned to fuel your equipment. The operators of the machine do not help. Is this a hazardous chemical under these conditions? Yes. Diesel fuel is combustible in both the maintenance person and the machine operators have a potential for being burned and they must know of this hazard. There could be severe acute health effects from breathing the hot fumes if fuel were to spill on the engine. Exhaust fumes contain toxic gases and can be carcinogenic as well. What about motor oil? The label says there's no known hazard. The MSDS says that animal studies show used motor oil can cause cancer. Is motor oil a hazardous chemical? When new oils put in an engine it's not a hazardous chemical but used motor oil is hazardous and you must tell the employees who change the oil on your equipment about the potential of cancer hazard. What about your mind's product? Is it a hazardous chemical? All mining commodities are chemicals. Many mind products, though not all, are hazardous because they contain silica, a hazardous chemical. Other components can also make a commodity harmful. If your mind's product is hazardous you must include it in your HazCom program and prepare an MSDS and label to give to your customers. You probably already know how your product should be classified. If not you will have to review available scientific evidence to determine its hazards. HazCom is an information and training standard. It requires you to know about the chemicals in your mind and to tell miners about the risks associated with exposure to them, the methods you use to control exposure, and the safety measures to take. The inventory of mind chemicals is an important first step for cataloging mind hazards and informing your employees about them.