Hazard Communication

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*Hazard Communication*
	Were you looking for my HazMat Quiz?	Or were you looking for my HazMat page index?

Caveat: I've made the following information as useful and accurate as I can... but I won't be held responsible for your actions or inactions. YOU need to know the regulations which apply to you and the resources that you have available; use what I give you as a starting point. I've used my free time to create this page, and I'm offering it freely - remember that what you get may be worth what you paid for.

Hazard Communication - Table of Contents

Transportation Hazard Communication

Hazard Communication Overview

Worker Hazard Communication

Environmental Hazard Communication

Transportation Hazard Communication

Other Government and Private Resources

Canadian WHMIS Labels

Material Safety Data Sheets (MSDS)

US EPA RCRA Waste Codes

Shipping Papers

Sample Labels & Placards

North American Emergency Response Guidebook (NAERG)

For further information consult the additional tables at the Hazard Communication Definitions page. The HazCom Definitions page also has my comments on how the regulations of various agencies interact.

Hazard Communication Overview

What is Hazard Communication?

"Hazard Communication" means communicating the hazards of a dangerous chemical to people who need to know, such as workers or emergency responders. It includes workplace right-to-know initiatives such as Canada's Workplace Hazardous Materials Information System (WHMIS) and the US Occupational Safety and Health Administration's Hazard Communication Standard. It also includes transportation initiatives such as the Canadian Transport of Dangerous Goods Act and Regulations, the US Hazardous Materials Regulations, and the North American Emergency Response Guidebook.

In the following sections I will discuss what I know of Hazard Communication issues in Canada and the US; I will also mention what I know of Mexico's Secretariat of Labour and Social Security's (STPS's) worker health and safety requirements. Please note that my knowledge of Mexico's regulations is limited: I have not taught there in several years, and Mexico has recently implemented many new transportation regulations as a result of agreements with Canada and the United States.

History of "Right-to-Know" Regulations

Hazard communication initiatives came from two sources. On Saturday, July 10th, 1976 a cloud of dioxin was released from a chemical plant in Seveso, Italy, near Milan, causing several thousand people to develop a skin disorder called chloracne and leading to long-term health problems. This lead to the European Economic Community's Seveso Directive. Then on the night of December 2, 1984, a Union Carbide pesticide plant in Bhopal, India released a plume of methyl isocyanate, killing over 2000 people. World-wide concern led to world-wide initiatives.

In the United States the Congress passed the Superfund Amendment and Reauthorization Act (SARA) and Emergency Planning and Community Right-Know Act (EPCRA). As part of SARA and EPCRA manufacturers had to publish MSDS, employers had to train workers, and businesses with toxic substances had to notify their local fire departments and Local Emergency Planning Committees of their emergency / contingency plans and of any exteremely hazardous substances on their sites.

In the meantime, industry was taking action to identify chemical hazards in the workplace. In Canada, the WHMIS regulations on Material Safety Data Sheets (MSDS) were implemented by the provinces based upon a federal program. This was the first program to lead to uniform nation-wide workplace regulations in that country. Similar initiatives in the US and other countries led to standardized Material Safety Data Sheets (MSDS).

**Table 1: Canadian WHMIS Labels**

Compressed Gas	Flammable / Combustible Material

Oxidizing Material	Poisonous Infectious Materials: Immediate & Serious Toxic Effects

Poisonous Infectious Materials: Other Toxic Effects	Poisonous Infectious Materials: Biohazardous Infectious Material

Corrosive Material	Dangerously Reactive Material

Workplace Hazard Communication:

Hazard Communication / Workplace Hazardous Materials Information System (Right-to-Know / WHMIS / Material Safety Data Sheets)

Wherever you are in the U.S., Canada or Mexico some type of Safety Data Sheet is used for workplace controlled products / hazardous chemicals. In Canada, this program is regulated through the Workplace Hazardous Materials Information System (WHMIS); in the US, through OSHA's Hazard Communication/"Right to Know" regulations. In Mexico a similar program is administered by the Secretariat of Labour and Social Security (STPS). Of course MSD sheets are not available for everything--for example, hazardous wastes do not require MSDS in Canada or the US, nor do consumer products. A good Right-to-Know / WHMIS program will include:

Worker training on the program;
Appropriate labels for workplace hazardous chemicals;
A list or inventory of all hazardous chemicals in the workplace;
Material Safety Data Sheets that describe the hazards of those chemicals.

Note that unlike Canada, the US does not use a cross-hatched border on the item's container to indicate which products require MSDS. The US also does not use the Canadian labels or the three-year limit on MSDS age.

**Table 2: Material Safety Data Sheets**

Environmental Safety

Materials Without MSDS: Dangerous / Hazardous Wastes

In the US and Canada some materials do not require Material Safety Data Sheets. Also many substances pose a threat to public health and the environment as well as to workers. Even though these substances may not have MSDS, there is normally other information available. For example, there may be pesticide markings or PCB markings.

Of particular interest are dangerous or hazardous wastes. When an MSDS is not available a worker or responder can look for other information, such as information from a remediation/clean-up site characterization, or a waste "profile" for disposal. Wastes from US Superfund sites must be characterized, and are regulated under the Comprehensive Environmental Response, Compensation and Liabiliy Act (CERCLA) and the Superfund Amendment and Reauthoriztion Act (SARA). Shipping papers may also provide needed information on the hazards in a waste.

Other information may be available for toxic and hazardous wastes in the US. Asbestos and Polychlorinated biphenyl (PCB) wastes are regulated by the Toxic Substance Control Act (TSCA), which gives specific waste definitions. Hazardous wastes are regulated under the Resource Conservation and Recovery Act (RCRA), which also uses strict definitions. RCRA hazardous wastes use "waste codes." These codes are based on EPA lists and descriptions of characteristics. Several waste codes may apply to the same waste if it is covered by more than one category. See the RCRA Waste Code table for more information.

**Table 3: US RCRA Waste Codes**
Waste Code	Description
D001	Ignitable Waste. Waste has a flash point below 140 F (60C), or is an oxidizer that will ignite flammable materials.
D002	Corrosive Waste. Waste either corrode metal or has a pH below 2 (acid wastes) or above 12.5 (caustic, alkaline, or basic wastes). Unlike WHMIS, OSHA, Canadian TDG and US DOT HMR definitions for corrosives, wastes must be liquids to have the corrosivity characteristic.
D003	Reactive Waste. Waste may undergo violent changes, react with water or other wastes, generate toxic gases, vapors, or fumes. Cyanide or sulfide wastes that may generate toxic gases at pHs between 2 and 12.5 fall into this category.
D004 - D043	Specific wastes listed for their toxicity (e.g., D008, lead).
F-listed wastes	Wastes from generic sources, such as spent chlorinated or halogenated solvents.
K-listed wastes	Wastes from specific sources (e.g., K051, API separator sludge from the petroleum refining industry).
P-listed wastes	Commercial chemical products, containers, or spill residue with unspent waste with acute (short term) toxicity (e.g., P098, Potassium cyanide.
U-listed wastes	Commercial chemical products, containers, or spill residue with unspent waste with chronic (long term) toxicity (e.g., U151, Mercury).

Transportation Hazard Communication:

Shipping Papers

People who work with shipping dangerous goods / hazardous materials may need to quickly identify the hazard with which they work. Emergency responders may also need to identify dangerous cargo as quickly as possible. Some industries use industry- wide ways of describing cargos, such as the American Association of Railroads' Standard Transport Commodity Codes (STCC).

Unfortunately, these common practices don't help responders from outside that industry. To ensure that workers and responders can easily identify dangerous goods or hazardous materials, shipments of these materials use standard names and other nomenclature as well as easily identifiable placards and labels. These names and information are put on shipping papers, such as Bills of Lading and US Uniformed Hazardous Waste Manifests.
Table 4: Shipping Papers
MODE SHIPPING PAPERS Responsible Party

Highway Bill of Lading (non-wastes/non-reg wastes) / Dangerous Goods Waste Manifest / US Uniform Hazardous Waste Manifest (dangerous / hazardous wastes) Vehicle driver

Rail Rail Bill of Lading / Waybill Crew

Water Dangerous Cargo Manifest Captain

Air Air Bill with Shipper's Certification for Restricted Articles Pilot

Nomenclature

There are many, many potentially hazardous chemicals in transport - too many to easily describe without grouping similar chemicals together. To make life easier for emergency responders, each of the three North America countries has identified dangerous good / hazardous material shipping names, hazard classes, and product identification numbers. These shipping names, hazard classes, and identification numbers are based on international agreements. They are written as Shipping Name, Hazard Class, Product Identification Number (PIN), and Packing Group. For example: "Waste Acetone solution, Class 3, UN 1090, Packing Group II." As a mnemonic (memory tool), Just think "SHIP."

In Canada these names and numbers are regulated by the Transport of Dangerous Goods Act and Regulations (TDGA / TDGR) and administered by Transport Canada. They are found in Schedule II, List I and II of the TDGR. As a rule, almost all of the names parallel the US names, because they come from the same international agreements. As an exception to this rule the "Waste Type" names parallel US EPA hazardous waste codes (e.g., both Canadian "Waste Type 77, Class 3, NA 9377, PG II" and the US EPA waste code K051 are "API separator sludge from the petroleum refining industry").

In the US these names and numbers are mandated by the Hazardous Materials Regulations and administered by the Office of Hazardous Materials of the US Department of Transportation's (US DOT) Research and Special Projects Administration (RSPA). They are found in Part 172.101 of Title 49 of the US Code of Federal Regulations (49 CFR 172.101).

Dangerous Goods / Hazardous Materials Placards and Labels

Along with the designated SHIP information, Mexico, Canada and the US all use container labels and vehicle or bulk-container placards to note the presence of hazardous materials. These are the diamond-shaped markings on small containers like drums (labels) and on vehicles (placards). The shape and color are also based on international standards. Take one example: Flammable Liquid, n.o.s. (a technical name), Class 3, UN1993, Packing Group (I, II, or III) is a standard name tied into the Emergency Response Guides / Guidebooks used in North America; the red-shaped Flammable Liquid label or placard is likewise a standard. Labels go on non-bulk containers like drums. Placards go on bulk containers such as vehicles.

**Table 5: Sample Labels & Placards**

North American Emergency Response Guidebook

In 1996 Canada, the US, and Mexico published a joint North American Emergency Response Guidebook that replaced the Canadian CANUTEC Dangerous Goods Initial Emergency Response Guide and the US Department of Transportation Emergency Response Guidebook. While this guide did not include basic container recognition (the graphics on the accompanying HazMat Transport page are partly based on the old Canadian CANUTEC guidebook and my experience), it did combine the best of the Canadian guidebook's response pages with the Initial Isolation and Protective Distances charts for Poison by Inhalation Hazards (PIHs).

**Table 6: NAERG**

Other Resources:

PRIVATE SECTOR
- CHEMTREC, at (800) 424-9300, or (703) 527-3887 (collect).
  The Chemical Manufacturers' of America (CMA) sponsors CHEMTREC, an information center. Note that CMA and the Canadian Chemical Producers' Association (CCPA) also sponsor a Transportation Community Awareness and Emergency Response (TransCAER) program as part of their Responsible Care� programs well; Responsible Care� was a voluntary industry program started in Canada and which spread world-wide.
PUBLIC SECTOR
- CANADA
  CANUTEC, at (613) 992-4624 (collect).
  Remember that you must report spills to both CANUTEC and your Provincial authority. Call CANUTEC immediately for railcar spills, spills of Class 6.2 infectious substances, or if the shipper is using CANUTEC as the 24-hour notification number; otherwise, you must notify CANUTEC within 30 days using form 2 in Schedule IX* of the Transport of Dangerous Goods Regulations. See page 4 of the North American Emergency Response Guidebook (NAERG).
- UNITED STATES
  National Response Center (NRC) at (800) 424-8802 (267-2675 in Washington, D.C.). The US Coast Guard-run NRC advises on hazardous materials spills and contacts other agencies for you. If you have a spill exceeding DOT or EPA Reportable Quantities (RQs) or which otherwise require immediate reporting, you can find the number on page 6 of the NAERG.
  Site Releases
  40 CFR 302.6 EPA requires persons in charge of facilities (including transport vehicles, vessels and aircraft) to notify the NRC report any release of a an RQ of hazardous substance as soon as that person has knowledge of the release.
  Transportation Releases
  Certain releases during transportation - and that includes shipping and receiving - must be reported immediately. Other releases must be reported later. This is what 49 CFR 171.15 requires for immediate reporting:
  49 CFR 171.15(a) At the earliest practicable moment, each carrier who transports hazardous materials (including hazardous wastes) shall give notice in accordance with paragraph (b) of this section after each incident that occurs during the course of transportation (including loading, unloading and temporary storage) in which:
  1. As a direct result of hazardous materials-
  (i) A person is killed; or
  (ii) A person receives injuries requiring his or her hospitalization; or
  (iii) Estimated carrier or other property damage exceeds $50,000; or
  (iv) An evacuation of the general public occurs lasting one or more hours; or
  (v) One or more major transportation arteries or facilities are closed or shut down for one hour or more; or
  (vi) The operational flight pattern or routine of an aircraft is altered; or
  2. Fire, breakage, spillage, or suspected radioactive contamination occurs involving shipment of radioactive material (see also 174.45, 175.45, 176.48, and 177.807 of this subchapter); or
  3. Fire, breakage, spillage, or suspected contamination occurs involving shipment of infectious substances (etiologic agents); or
  4. There has been a release of a marine pollutant in a quantity exceeding 450 L (119 gallons) for liquids or 400 kg (882 pounds) for solids; or
  5. A situation exists of such a nature (e.g., a continuing danger to life exists at the scene of the incident) that, in the judgment of the carrier, it should be reported to the Department even though it does not meet the criteria of paragraph (a) (1), (2) or (3) of this section.
  (b) Each notice required by paragraph (a) of this section shall be given to the Department by telephone (toll-free) on 800-424-8802. Notice involving infectious substances (etiologic agents) may be given the Director, Center for Disease Control, U.S. Public Health Service, Atlanta, Ga., 1-800-232-0124, in place of the notice to the Department or (toll call) on 202-267-2675. Each notice must include the following information:
  1. Name of reporter.
  2. Name and address of carrier represented by reporter.
  3. Phone number where reporter can be contacted.
  4. Date, time, and location of incident.
  5. The extent of injuries, if any.
  6. Classification, name, and quantity of hazardous materials involved, if such information is available.
  7. Type of incident and nature of hazardous material involvement and whether a continuing danger to life exists at the scene.
  (c) Each carrier making a report under this section shall also make the report required by 171.16.
The report required in (c) above is the US DOT's Form 5800.1. You may find more information on this form at the US DOT's Office of Hazardous Material's website.

If you need more information, I recommend that you try the following sources:

**HazMat Resources**

Hazard Communication	Joint N. America Effort	Canadian Agencies	USA Agencies	Mexican Agencies	Private Sector Organizations	HazMat Page

The above is copyright 10 May 1997, by Earle B. 'Glas' Durboraw.

This page, of course, does not represent my employer's views--just my own! I work with Safety-Kleen (ex-Laidlaw Environmental Services), and I've been dealing with aspects of chemical response since 1982, when I graduated from Hardin-Simmons University and was commissioned in the U.S. Army's Chemical Corps. I spent a very enjoyable decade on active duty before volunteering for President Bush's Drawdown bonus. I am also a Certified Environmental Trainer through the National Environmental Training Association, was a member of the National Fire Protection Association, and a professional member of the American Society of Safety Engineers.
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