Hazard Communication in the Warehouse Industry

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Bill Martin

MD, MBA, MPH
Medical Director

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Doug Patron

MD, MSPH
Medical Director

In today’s fast-paced industrial environment, warehousing establishments play a critical role in the storage, distribution, and management of chemicals. As such, these facilities must adhere to strict safety regulations to minimize hazards and protect workers from potential chemical exposures. In this blog post, we will discuss the importance of hazard communication, process safety management, and chemical warehousing and distribution, and offer guidance on implementing effective safety programs in these areas.

Hazard Communication

The Occupational Safety and Health Administration (OSHA) has established the Hazard Communication Standard (HCS) (29 CFR 1910.1200) to ensure that workers are aware of the chemicals present in their work environment and understand how to handle them safely. An effective HCS program involves several key steps:

  1. Assigning primary responsibility for coordinating the implementation of the HCS to a designated individual.
  2. Developing a written hazard communication program that outlines procedures for identifying and managing hazardous chemicals at the facility.
  3. Maintaining an up-to-date inventory of hazardous chemicals and ensuring that safety data sheets (SDSs) are readily accessible to workers.
  4. Properly labeling containers of hazardous chemicals and ensuring that labels on shipped containers are not removed or defaced.
  5. Providing comprehensive training to workers on the hazardous chemicals in their work area, including protective measures and additional information resources.
  6. Periodically reviewing and updating the hazard communication program as workplace conditions change.

When workers handle chemicals in sealed containers, employers must ensure that proper labeling is maintained, SDSs are accessible, and workers receive the necessary training to respond to spills or leaks effectively.

Process Safety Management

OSHA’s Process Safety Management (PSM) standard (29 CFR 1910.119) applies to facilities that store or handle highly hazardous chemicals in quantities above specific thresholds. This standard emphasizes the comprehensive management of chemical hazards through the integration of technologies, procedures, and management practices.

Implementing a PSM program can help prevent fires, explosions, chemical spills, toxic gas releases, and other major incidents, ensuring the safety of employees, contractors, visitors, and emergency responders. Additionally, compliance with the PSM standard can minimize damage to facility equipment and neighboring structures in the event of a highly hazardous chemical release.

Resources on process safety management include OSHA’s Safety and Health Topics page, which addresses the management of highly hazardous chemicals, and publications focusing on storage facilities (OSHA Publication 3909) and small businesses (OSHA Publication 3695).

Chemical Warehousing and Distribution

Facilities involved in the processing, formulation, blending, re-packaging, storage, transport, and marketing of chemical products must manage chemicals safely and securely. This involves:

  1. Storing chemicals in a secure manner and accounting for all on-site containers.
  2. Conducting periodic inspections of tank systems to ensure their integrity.
  3. Providing adequate secondary containment for chemicals to contain spills or leaks.
  4. Ensuring that hazardous and flammable chemicals are stored in structurally appropriate buildings with proper fire protection.
  5. Storing chemicals away from forklift traffic areas to prevent accidents

Compliance with OSHA standards, such as the Hazard Communication Standard (HCS) (29 CFR 1910.1200), Process Safety Management (PSM) standard (29 CFR 1910.119), and Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120), is essential for chemical warehouse and distribution facilities. Additionally, these facilities may be subject to regulations enforced by the Environmental Protection Agency (EPA), the Cybersecurity and Infrastructure Security Agency (CISA), and the United States Coast Guard (USCG).

In conclusion, maintaining a safe and compliant chemical warehousing environment requires a thorough understanding of hazard communication, process safety management, and chemical storage and distribution practices.

References: www.OSHA.gov