Safety Tidbit #2.3 – Workplace labeling and containers for immediate use
Ironically, just about a year ago, in Safety Tidbit #9 I wrote about a similar issue to what I wish to discuss today (see - back then it was Safety Brief #9 – Hazard Communication Labeling). Although this time I have a slightly different twist on labeling. See if you can catch the underlying problem.
While doing an audit, I noticed a container of hazardous material at a workstation. The container had the word “oil” in magic marker on it. I asked my escort who worked in the area, and a person was flagged to come over. I proceeded to quiz the worker on the contents of the container which she knew that it was oil. She also knew the purpose with which she needed to apply it to perform her job. However, when I asked if it was hazardous to her and what effect it might have on her, she was clueless. Although, she did say they typically use rubber gloves when they apply the oil since the container leaks down the side, and the regular label always comes off, and also it takes her nail polish off (a dead give-away that the chemical is hazardous!). She told me that the magic marker worked much better. I further inquired if she knew how or where to get more information about the contents of the container – deer in the headlights look!
Well, as you can imagine, I took a little time to explain about the safety data sheets … but I digress. Back to our topic. OSHA’s hazard communication standard specifies “the product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical [1910.1200(f)(6)(ii)].” The standard also states “the employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. [1910.1200(f)(8)] OSHA further clarifies its intended use of this exemption to labeling in the second half of the paragraph: “For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for direct administration to a patient are exempted from labeling.
The employer explained that the container was filled by the employee and is only being used by that employee, so they felt they were in compliance with the 1910.1200(f)(8). I believe if a compliant label had been on the container the worker would have been able to answer my questions about the hazards of the material just by looking at the appropriately labeled container. Also, there were other employees in the area so could the employer really say that only this one person uses the bottle?
Did you guess the underlying issue with this scenario? OSHA requires “Employers shall provide employees with effective information and training on hazardous chemicals in their work area …” The company did not give very “effective” training as the worker gave me the deer in the headlights look. So, I cited the employer for both 1910.1200(f)(6)(ii) and 1910.1200(h)(1).
Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan
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