In the village of Addison, Ill., the United Parcel Service, with some 2,300 workers, is the largest employer. The Cary Co., with its 42 full- and part-time employees, doesn't even come close in size. But in Addison, Cary Co. is a big deal.
Cary, which stores and distributes chemicals and other products to facilities that use or make paint and coatings, printing ink, plastics and rubber, is the only company of its kind in Addison. The chemicals found at Cary include four or five different Department of Transportation (DOT) classes of hazardous chemicals and company management is very aware that maintaining a reputation as a good neighbor is crucial.
The way to be a good neighbor, believes Bill Cary, company president, is to operate a safe facility and to communicate openly with employees and the community.
"We want to maintain a safe environment for our people, our neighbors in Addison and the fire department," he notes. Cary is the fourth generation of his family to manage the company. A family-owned business for 107 years, Cary Co. has been located in Addison for the past 37 years.
Over the years, the company developed the type of OSHA-mandated hazardous communication (HAZCOM) program that is usually found at much larger companies with greater resources: extensive new employee training in OSHA Right-to-Know and Department of Transportation (DOT) regulations and occupational safety; an extremely well-maintained library of some 2,500 material safety data sheets (MSDS); a partnership with the Addison Fire Department; and ongoing education for both employees and management.
New Employee Training
All new employees, or current employees whose jobs have changed, take HAZMAT training as dictated by the DOT and HAZCOM training as required by OSHA. They learn about OSHA's HAZCOM standard and their right to know about the chemicals stored on site, the chemicals with which they work and their potential exposures to the chemicals. All employees, including truck drivers, take HAZCOM training in addition to any training they receive related to job tasks or occupational health and safety. Every two to three years, all employees receive updated training unless changes in regulations dictate otherwise even if their job tasks have not changed since the last round of training.
Dave Meehan, who is the logistics and regulatory coordinator at the company, says he attends a special "train-the-trainer" course every year to ensure he stays up to date with HAZCOM and HAZMAT regulations in the industry. "The course examines DOT, OSHA and EPA regulations and how they interact with each other. New regulations come out all the time. It's an ongoing thing, and I have to say up on it," he says. "When new hazards or chemicals are introduced into our workplace, that's when our HAZCOM program kicks in for employees: training, right-to-know, etc."
Employees need clear, accurate information about the safe use and storage of chemicals in the workplace, Meehan notes. At Cary Co., chemical drums and containers are received from the manufacturer labeled with the name of the chemical; notification about whether the chemical is flammable, an irritant, a corrosive, etc.; and any harmful health effects to target organs or symptoms from exposure. Employees learn how to read both the MSDSs and the various warning labels and signs for chemicals stored and distributed by the company, and they are told what to do if they spot a leak or if a drum spills.
"They are taught how to identify the product, and they know if they should clear the area or call for an evacuation of the entire facility," says Meehan. "Cleanup is handled by an outside vendor. For a small company, it's not really practical to do the cleanup ourselves. The cost of the equipment and the specialized training to do that kind of work is just not cost effective."
MSDSs are separated by manufacturer and stored in binders on site. Employees currently have access to the MSDSs upon request, but the company is in the process of creating a computer database that will allow employees to print up an MSDS on demand. Whenever Meehan, who manages the MSDS binders, receives a new MSDS from a manufacturer, he compares it to the MSDS on file. If the MSDS has changed, he notifies employees, and customers who purchased that product from Cary Co. are sent updated MSDS. If significant changes have occurred such as with handling, first aid or health hazards then the HAZCOM program kicks in and the employees who handle that chemical receive additional training about it.
Partnering with the Fire Department
Employees are not the only people educated about the hazards and chemicals found at Cary Co. The local fire department has gotten into the act, says Bill Cary.
Since Cary Co. is the only chemical distributor in Addison, the village's fire department began visiting the facility about 20 years ago to hold emergency response training exercises. It's good training for employees, they learn what to do in case of emergency, and good training for the fire department.
"The Addison Fire Department comes out about every two years and looks for the emergency shut off valves for the gas and electric; examines where the chemicals are kept; where the emergency response equipment is kept; where the MSDSs are kept" says Meehan. "When they get new firefighters, they bring them out to take a look at the facility and learn about the chemicals stored, so they will know what to expect if they need to come out for an emergency."
Cary says the company tries to be extremely proactive where the fire department is concerned. "We notify them if the regulations we comply with have changed," he says. "We've gained credibility with the fire department because of our policy about being open about sharing information about the facility and the chemicals here. We've never tried to get around regulations."
That honesty saved the company money, Cary adds. When management decided to construct a new, 140,000-square-foot warehouse building, they wanted to include a HAZMAT room. The National Fire Protection Association (NFPA) Code 30 has stringent regulations regarding the storage of hazardous materials. There are restrictions concerning the location of the storage room within the facility, and numerous building code and safety requirements for such rooms.
Company management wanted a room that could store 300,000 gallons of chemicals in 55-gallon drums. According to NFPA 30, the room needed explosion-proof lighting, explosion-proof outlets, and an explosion-proof heating and cooling system; all of which would have added $100,000 to the construction cost.
"We would have paid it, because we needed that room," Meehan admits. But before committing to those additional costs, management decided to talk to the local fire department.
"We told them what we needed and what was going to be stored in the room, and they helped us design it so that it met NFPA standards, but did not have to be explosion-proof," says Cary. "Our years of open communication with the fire department paid off."
With the input of the Addison Fire Department, the HAZMAT room contains an in-rack foam suppression system, and an early suppression system was installed for the general storage area that is designed to spray twice as much water as a normal fire protection sprinkler sprays. The HAZMAT room also has a dike to contain any spills. The warehouse itself is equipped with heat sensors, 11 hose stations, 54 fire extinguishers and a fire protection room that has a dedicated phone line, alarm and electrical circuits.
In addition, the fire department keeps a key to the fire protection room so emergency responders have 24-hour access to MSDSs, maps showing electrical power switches and emergency contact phone numbers.
Fortunately, say Meehan and Cary, the company has not experienced a serious incident. Prevention is the best solution, believes Cary. Although he has no concrete proof, he says by educating employees and the local fire department about hazards and the impact of potential chemical leaks and exposures, the likelihood of accidents and injuries has been reduced.
"Until you have an incident, you don't know if [your HAZMAT and HAZCOM] programs work or not or if the programs have reduced injuries or illnesses," Cary admits, but adds, "This is the way we run our company."
The Cary Co. is a member of the National Association of Chemical Distributors (NACD), which has 300 member companies in the United States and Canada. NACD's Responsible Distribution Process helps the company stay in compliance with HAZCOM and HAZMAT regulations, since member companies are audited on their practices and procedures by a third-party auditor every three years. The certification process is similar to some ISO programs.
"We are always revising and improving our processes and programs," says Meehan. "We try to stay ahead of regulatory changes."
And by doing so, says Cary, "It helps differentiate us from many of our competitors. We believe they reduce accidents and injuries, saving us money, and our customers trust us to provide them with the most current, accurate information available for the chemicals they purchase from us."
Sidebar: The HAZCOM Standard
In 1910.1200 (the Hazard Communication standard, also known as HAZCOM), OSHA says employees must be trained when they are assigned to work with a hazardous chemical so they have information about the chemical prior to exposure to prevent the occurrence of adverse health effects.
The training provisions of the HAZCOM standard are not satisfied solely by giving employees the material safety data sheets to read. An employer's training program must educate employees not only about the hazards of the chemicals in their work area, but also how to use the information generated in the HAZCOM program. OSHA allows this training to be conducted in a variety of ways, but whatever type of training is used, it should include an opportunity for employees to ask questions to ensure that they understand the information presented to them.
Training does not need to be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents) that are or may be encountered by an employee during the course of employment.
OSHA also dictates that employees must understand the training, ie., if the employees receive job instructions in a language other than English, then the training and information to be conveyed under HAZCOM also must be conducted in a foreign language.
Additional training must be conducted whenever "a new physical or health hazard is introduced into the work area," not a new chemical. For example, if a new solvent is brought into the workplace, and it has hazards similar to chemicals for which training has already been conducted, then no new training is required. As with initial training, and in keeping with the intent of the standard, the employer must make employees specifically aware in which hazard category (i.e., corrosive, irritant, etc.) the solvent falls. The substance-specific data sheet must still be available, and the product must be properly labeled. If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where they will be exposed.
Although OSHA says it is not necessary that employers retrain new hires if they received prior training, employers such as Cary Co. ensure that their employees are adequately trained and are equipped with the knowledge and information necessary to conduct their jobs safely. That makes it likely that additional training will be needed when new employees arrive, since employees must know the specifics of their new employers' programs, such as where the MSDSs are located, details of the employer's in-plant labeling system and the hazards of new chemicals to which they will be exposed.