Hazard Communication

What is "hazard communication" and why is it so important?

The employer, as part of the written hazard communication program required by OSHA 29 CFR 1910.1200, must train employees about the hazards of materials to which they are exposed.

The training must include specific information from Material Safety Data Sheets of the metal removal fluids and other materials used in metal removal processes in the workplace, as well as any specific information regarding labels or other forms of warning and employee information and training the employer adopts. (Please see More on HazCom for details regarding formaldehyde.) This training is required for employees new to metal removal operations or employees transferred into metal removal operations.

What is the procedure for complaint investigation?

A complaint can be one of many kinds of concern, from employee questions to complaints about odor to employee symptoms of irritation or respiratory problems. In general, a complaint investigation includes the following steps:

1. Physical inspection or review of the area for apparent problems;

2. Identification of items or conditions that may cause or contribute to the complaint, such as lack of splash guarding, review of control systems, or condition of coolant. The list of key features presented elsewhere in this guide should be used for further reference;

3. Corrective actions to items or conditions that were found to be deficient;

4. Follow-up to determine whether corrective actions have been successful in resolving the issue.

How can hazards be reduced or eliminated in the workplace?

There are several primary methods to reduce or eliminate hazards in the MRF environment:

Elimination: Not all metal removal operations require the use of MRF. If the hazard is thought to be due to the MRF itself, and it is unnecessary, don't use it.

Substitution: In some cases, substitution of less irritating coolant additives may help to resolve instances of irritation, if the cause is MRF-related. Ensure that an appropriate fluid is being used for the metal removal operation.

Engineering controls, such as enclosure, local exhaust ventilation and general plant ventilation.

Administrative controls, such as employee instruction or transfer of an employee who appears to be unusually responsive to materials in the MRF environment.

Personal Protective Equipment (PPE), such as gloves or aprons.

How can employees' attention to personal hygiene reduce health hazards?

Minimizing personal contact with MRF, metal debris, and other chemicals in the workplace can reduce the chance of harmful effects.

Employees should change work clothing that becomes soaked with metal removal fluids and contaminants during the work shift. Work clothing must be thoroughly washed to remove metal removal fluid residues before reuse.

Wash hands with mild soap before breaks and meals. Avoid using rags contaminated with metallic debris, such as swarf and chips.