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Organization of 30 CFR
The Mine Health and Safety Act
A Look at General Provisions
HAZCOM (Part 47)
©Feb 2003 Dr. Bradley C Paul
CFR Structure
Coal Mines
Subchapter
H
Education
And
Training
Subchapter
M
Uniform
Mine Health
Regs
Metal-Non Metal
Quarry/Gravel
Part 48 Miner Training
Part 49 Mine Rescue Teams
Part 48 Hazard Communications (HAZCOM) (June 2002)
Part 46
Miner
Training
Part 62 Occupation Noise Exposure
Part 47 Hazcom Regulation
• Principle is two pronged
– Your employees have the right to know about the risks
and characteristics of chemicals they work with
• Part of rationale is that many chemical effects may not showup for years after exposure
– The mine operator should know about the risks at
his/her own operation
• Regs went in Aug. 2002 for mines with 6 or more
– March 21, 2003 for those 5 and under
Why MSHA Intervened
•
•
•
•
Over 2500 chemical burns a year
Over 1200 Lost Time Accidents
Over 400 Cases of Poisoning
Cases were over all types of mines and job
classifications
Goal of Your Hazcom Training
• Recognize the chemical hazards that exist
• Know how to understand a Material Safety
Data Sheet
• Know where to get the information
• Know what protective gear and procedures
will keep them safe
Setting Up a Hazcom Compliant System
• Start by Inventorying your chemicals
– Chemicals you bring into your site
– Chemicals you produce at your site
• You will be trying to find those that are
– Exempt
– Non-Hazardous
– Are Hazardous and demand a response
What is Exempt
• Consumer Items
– Common store products when used as common
consumers would use them
• Cleaners would be example
• Key is also when used as common consumer
– Regular workers probably have no Hazcom chemical
issues
– Janitors may
• Packaged break cleaner from Auto Zone
– Gasoline is not a packaged consumer item
More Exemptions
• Articles
– Manufactured item that releases no more than
incidental hazardous chemical + posed no
special health risk to miners
• Examples Conveyor Belting, Pipes, Truck tires
– Articles can become a raw material for
producing something else
• Example galvanized pipe being welded releases zinc
fume
Personal Items
• Things like food, make-up, tooth paste,
soap, tobacco products
• Also Excluded are things pose no hazard
– Most materials have Material Safety Data
Sheets that discuss risks
– Example – some greases are not considered
hazardous in normal use
What Makes a Hazard
• Physical Hazard
–
–
–
–
Flammable
Explosive
Chemically active (corrosive for example)
Water reactive
• Chemical Hazard
– Creates illness
• Acute (ie it zaps you down now)
• Chronic (ie. Long term of persistent long term duration)
Mines Must Have Written Hazcom Plans
• Now that you have the list of materials
• Develop a plan that includes
– Your list of Hazardous Materials
– How you will tell miners about unlabeled hazards
• Things in pipes
• Things where risk appears only under special circumstance
– The labeling system you will use on your containers
– Where you will keep Materials Safety Data Sheets for different
substances
– What Training Program you will give to your miners
• Can and should be integrated with part 46 or 48 training
– How you will inform contractors and others on the property of
hazards and protective measures
Things Must Be Labeled
• A Label will disclose
– Name of Chemical so it can be cross referenced to your
chemicals list and MSDSs
– Flammability or Reactivity issues (if any)
– Other Chemical and Physical Hazards or Risks
• Ie. Carcinogen, skin irritant etc.
• List risks in approximate order of severity being as specific as
possible about target organs effected
– Personal Protective Gear that should be used in
handling
– Special precautions when working around the chemical
Labels
• Labels can be in any system as long as it is
–
–
–
–
Obvious
Legible
Accurate in its information
In English
• This does not prohibit posting in another language
also
Things Exempt from Labeling
• Items that are Exempt from part 47 as discussed before and
kept in original containers
• Wood and wood products
• The raw material mined or processed at your facility
– Unless put in a mixture in a container and the mixture is hazardous
• A RCRA Hazardous Waste labeled in accordance with EPA
• A Hazardous Chemical regulated under the Toxic
Substances Control Act and labeled as required
• Any Hazardous material involved in a superfund clean-up
being processed as part of the clean-up
Must Have a Bank of MSDS
• Each Hazardous Chemical Must Have One
– Many Chemicals brought in have them from the
manufacture
• Must update when you receive an update from manufacture
• You are not responsible for defects in MSDS received from
outside
• You must keep the sheet as long as the chemical is at the mine
– Must inform the miners 3 months before you can dispose
– Must have MSDS on any hazardous chemical you
produce at the mine
• Must update the sheet within 3 months on any new information
you maintain
What Kind of MSDS Bank is Allowed
• Can be any format – not just paper
– Can even be a fax on demand service off the
property
• Can it be a computer
– Yes but it must be accessible to miners
• Often a condition that you don’t want to meet
Whats on an MSDS ?
• Identity of Chemical or ingredients if a mixture
– Needs to Cross-Reference for the Chemical Inventory List, the Labels, and
the MSDS
• Properties
–
–
–
–
–
–
–
Boiling, Melting
Vapor Pressure and Evaporation Rate
Solubility in Water
pH
Appearance and Odor
Flash Point
Flammability Limits
• Some of these Properties may not apply
– Flammability Limits on Aggregate
– Solubility of Gasoline that floats on water
Good Grief – Where Do I Get That Stuff
• A lot of the MSDSs come from your
chemical suppliers
• Your trade association probably already has
this stuff because they need to supply it to
buyers
• MSHA’s web site has information for many
commonly mined materials
More MSDS Stuff
• Physical Hazards
– Fire
– Explosion
– Reactivity
• Health Hazards
–
–
–
–
Acute and Chronic Effects
Signs and Symptoms of Exposure
Medical Conditions Aggravated by Chemical
Method of entering the body
More MSDS Stuff
• Carcinogenic Status
– Not, Possible, Probable, Known Carcinogen
• Exposure Limits set by organizations such as
MSHA or OSHA
• Safe Use
– Instruction on good hygiene practice
– Protection during repair or maintenance around
contaminated equipment
– Procedure for clean-up of spills and leaks
More MSDS Stuff
• Control Measures
–
–
–
–
–
–
What is needed for Ventilation
Process Controls
Restricted Access
Protective Clothing
Respirators
Goggles
• Emergency Information
– First Aide
– Special Instruction to Firefighters
• Date Prepared
Hazcom Training Requirements
• Hazcom Training must cover
– Physical and Health Hazards of Chemicals in their area
– Protective Measures that Can be Taken
– An explanation of your Mine’s Hazcom Program
• Special Hazcom Training had to be given before
effective dates
• Now Hazcom is included specifically in
– All new miner training
– All new task training or when a new chemical is
introduced into an existing work environment