Carl O. Hilgarth's Commentary on "Occupational Health"
Author(s):
Carl O. Hilgarth
Don Hayward is correct in his concern when several workers
develop respiratory problems and complain about "those bad
smelling fumes from the hot metals". When he checks this out
with his superior Cal Brundage, he's told that the workplace is
in full compliance with OSHA guidelines. But Don learns that
only a small percentage of the chemicals in the workplace have
been tested, and that OSHA guidelines do not apply to materials
that have not been tested. What can he do? A lot!
To quote from Anton (1989) "In view of the increased
emphasis on toxicity, it is strongly recommended that when
chemicals are being purchased for plant use, processes, and
manufacturing, the manufacturer should supply a "Material
Safety Data Sheet" (OSHA Form 20).
The primary information shown in the data sheet for any
chemical will include trade and chemical names and synonyms;
chemical family, and possibly the formula; a list of hazardous
ingredients; physical data; data on fire and explosion hazards;
data on reactivity; proper procedures for cleaning up spills or
leaks; special protection needed; special precautions that
should be followed when using it; and first aid procedures in
the event of an accident.
Under the Toxic Substances Control Act, purchasers should
get this information from the supplier upon request. It is in
the best interest of employees to ask the supplier for the
Material Safety Data Sheet (MSDS) before the materials are
actually delivered into your plant.
The company or plant itself must have personnel (or at least
one person) who can understand and interpret the data and be
able to recognize any gaps where additional information or
technical expertise is required."
OSHA has a Hazard Communication Standard. Again citing
Anton(1989) this "is a 'performance standard,' which means that
it describes objectives that must be met, but without
specifying the method for accomplishing those objectives. The
method is up to the individual organization to choose.
The standard requires chemical manufacturers and importers
to assess the chemicals which they produce or import, and all
employers to use hazard communication programs to provide
information - to their employees - concerning hazardous
chemicals."
All the information that Don needs is available from the
chemical manufacturers under the Toxic Substances Control Act.
He should not drop the matter. Under this act, the
manufacturers must provide him the information he needs. He
doesn't need to waste his time trying to have the reference
librarian find this information. It's available free from the
manufacturers. He can also call the OSHA regional office, or
call his local congressman. Either can provide any information
about the about the OSHA Hazard Communication Standard and
Toxic Substances Control Act.
What Don has encountered is a typical management stonewall
of a fundamental industrial hygiene requirement resulting from
the fact that the supervisor obviously isn't knowledgeable of
OSHA requirements regarding chemicals in the workplace, and
doesn't want to take the time to find out about them.
Successful safety programs depend on leadership by the
employer, safe and healthful working conditions, and safe work
practices by employees. By ignoring the first two, ABC
Manufacturing is ignoring the purpose of OSHA "to assure so far
as possible every working man and woman in the nation a safe
and healthful working conditions and to preserve our human
resources." The OSHA inspection, when it comes, will find and
cite this violation. Solve it now and avoid the potential fine
and reinspection.
The best reference I have found for occupational health and
safety matters, and have cited in my commentary, is:
Occupational Safety and Health Management, 2nd edition.
Anton, Thomas J., McGraw-Hill, 1989