Read the following scenario, and answer the questions following each section:
The Dosit Corporation is a chemical manufacturer, and its products are sold to other manufacturers and used in household cleaning products. The company has 290 employees with about 220 involved in the production process, 30 working as maintenance personnel, and the remainder in clerical, sales, engineering, and senior management positions.
The company has never had a safety manager before it recently hiring you. The company president instructed you to find out what is wrong regarding safety and health and then to fix it. Several binders and files have been given to you with the explanation that they are the existing safety policies and records. Looking through one folder, you find a chemical inventory list from two years ago that included 780 chemicals. You find no records of hazard communication training, and the existing written program is very minimal and inadequate. You also look at the MSDS/SDS files and find considerably fewer than 780 MSDS/SDSs.
Question 1. What steps should you take to bring the company into compliance with the HCS considering best practices?
You went on a tour of your company's chemical processing area with the production foreman. As with any such operations, there are pipes going everywhere and numerous tanks. You noticed that few of the pipes and none of the tanks have visible labels indicating what is in the tanks or pipes.
Question 2a. Is this a problem from a safety or regulatory point of view? Why?
Question 2b. What would be your recommendation on labeling considering the regulatory requirements?
You have just finished training the entire workforce about chemical hazards. The training was not well received by the workforce, and they generally appeared to be bored; end-of-class quizzes indicated that they did not really grasp the essential information. You do not understand how this could be because you carefully went over the MSDS/SDS for each chemical that a given group of workers were potentially exposed to and explained in detail the precautions they needed to take.
Question 3a. What most likely went wrong in this training?
Question 3b. How could future training be improved, including the explanation of chemical hazards without specifically addressing each chemical?
During the inventory, you find a quart can of a chemical with a label in the maintenance shop. You find out that the shop personnel only use it occasionally and for unfreezing rusted bolts. They do not seem to know anything about the chemical's potential hazards, and the wording on the container is not totally legible, so you are not sure what the hazards are either.
Question 4a. How would find out about the proper use, storage, and disposal of this chemical?
Question 4b. How would you identify the chemical as hazardous, or as not hazardous?
Question 5. What should you do, if anything, about this container?