Managing Hazard Communication for Process-Generated Chemicals

Employers must manage hazard communication for chemicals generated during work activities such as welding fumes, combustion byproducts and reaction products. The Globally Harmonized System of Classification and Labeling of Chemicals has improved chemical hazard communication by standardizing labels and Safety Data Sheets. Many workplace chemical hazards do not arrive in a container with a label attached, according to Safety+Health Magazine.

Identifying Generated Hazards

Welding fumes, combustion byproducts, diesel exhaust, silica dust and chemical reaction products generated during manufacturing, maintenance or laboratory operations create challenges for employers in identifying, evaluating and communicating these hazards to employees. Unlike purchased chemical products, process-generated hazards may not have a supplier label or SDS. These substances can lead to acute toxic exposures and pose serious health risks including respiratory illness, cancer and neurological effects.

The first step is conducting a thorough process-based hazard assessment. Employers must identify the airborne contaminants, fumes, vapors, mists, dusts and reaction products generated during work activities in addition to reviewing the materials and chemicals being processed and used. Welding operations can generate fumes containing manganese, chromium, nickel or other hazardous constituents. Cutting, grinding, combustion processes and chemical mixing activities may create hazardous byproducts that require evaluation. The materials involved, operating temperatures and expected reaction pathways can provide important clues about what substances may be generated.

Developing Communication Strategies

Employers should develop a communication strategy that provides employees with accessible and understandable information about the hazards to which they may be exposed. Although a traditional SDS may not exist for a generated substance, employers can use industrial hygiene exposure assessments, technical guidance documents, process-specific hazard summaries, written procedures, training and signage to communicate risks. This information should be incorporated into the organization’s strategy for communicating workplace hazards and made readily available to affected employees. The goal is to ensure workers understand the hazards they may encounter, the symptoms of exposure and the protective measures required, according to Safety+Health Magazine.

Integrating Training and Controls

Employees should understand not only the hazards associated with the materials they handle but also the substances that may be produced during the work process itself. Organizations must provide and document effective training that explains how exposure can occur, potential health effects, warning signs of exposure, and required exposure controls and protective measures.

An effective program to reduce workplace hazards should be multitiered. Employers should integrate communication efforts with exposure control measures including engineering controls, ventilation systems, safe work practices, air monitoring and appropriate personal protective equipment. Hazard assessments and communications should be updated whenever materials, equipment or operating conditions change, according to Safety+Health Magazine.