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OSHA's Hazard Communication Standard and Emergency Training

Posted on Thu, Apr 14, 2011

NOTE: The Hazard Communication Standard, including Safety Data Sheets (SDS) format, has been updated. See TRP's "Phased Compliance of the Hazard Communication Standard..." blog. 

 

The Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Occupational Safety and Health Administration (OSHA) both have regulations focused on safety for transportation of hazardous materials. 

In 1986, OSHA initiated the Hazard Communication Standard - 29 CFR1910.1200. The purpose of this regulation is to communicate information to employees who may be exposed to hazardous chemicals in the workplace. As a result of this standard, each container of hazardous chemicals must:

  • Be labeled, tagged or marked with the identity of the hazardous chemical
  • Contain an appropriate hazard warning
  • Identify the name and address of the chemical manufacturer, importer, or other responsible party.

Based on the information on the label, the chemical manufacturer or other responsible party should be able to be contacted to determine emergency control measures and to estimate worst-case exposures.

According to OSHA, a MSDS must accompany each initial shipment of hazardous chemical and be readily accessible to employees handling the chemical. Since DOT requires truck drivers to carry MSDS information with the bill of lading for all shipments of hazardous cargo, which satisfies both agency requirements. Additionally, DOT requires transported hazardous materials to contain proper labeling in compliance with 49 CFR 172.302.

If the potential exists for an emergency situation to develop, training must be provided as described in 29 CFR 1910.1200. Training includes, but is not limited to:

  • Applicable leak and spill cleanup procedures
  • Appropriate PPE usage
  • Decontamination procedures and safety precautions

If an emergency response may be required for transported hazardous materials, emergency response plans must be developed and implemented and the provisions of OSHA’s Hazardous Waste Operations and Emergency Response Standard - 29 CFR 1910.120 apply.

When organizations opt to respond to emergencies with company personnel, a sufficient number of trained personnel must be available. In most cases, this is not the truck driver. However, the training required under 29 CFR 1910.120(q)(6) depends on the duties and functions to be performed by the truck driver. If truck drivers are expected to stop leaks involving hazardous materials and clean up potential spills, then a minimum of technician or specialist level training is required.

On March 10, 2011, the Department of Transportation announced a proposed rule to improve the safety of transferring hazardous materials to and from cargo tank motor vehicles. The notice proposes to add the following requirements:

  • Practice drills and classroom training of truck drivers and other workers who unload or load hazardous material
  • Training on automatic valve shut systems
  • Developing inspection and maintenance programs to ensure the safety of hoses, valves and other equipment used in loading and unloading.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

TRP Corp Emergency Response Planning Exercises

 

Tags: PHMSA, OSHA HAZWOPER, DOT, Emergency Preparedness, Regulatory Compliance