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One of the most tedious aspects of an EHS manager’s job is to keep track of a host of records. Laws have been passed in every jurisdiction requiring facilities to produce and retain records of various kinds. Don’t get caught without the necessary records in the event of a surprise EPA or OSHA inspection! This special report shows EHS managers at a glance the records they must keep on hand and for how long.

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This special report contains a recordkeeping checklist to help you keep track of your records for major environmental laws and OSHA’s Hazard Communication Standard.

Also included are 3 useful tables which provide:
  • A summary listing of federal environmental recordkeeping requirements
  • A list of federal safety recordkeeping requirements.
  • A list of federal recordkeeping requirements for DOT and the Department of Homeland Security as they apply to hazardous material transporters and chemical facilities.
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February 06, 2006
Coal Dust Requires an MSDS

It should not be automatically assumed that common substances that do not generally require a great deal of precaution in handling are not subject to regulation.

For a Limited Time receive a FREE EHS Report "Recordkeeping for EHS Managers." This special report contains a recordkeeping checklist to help you keep track of your records for major environmental laws and OSHA's Hazard Communication Standard. Download Now

For example, take coal and coal dust. Facilities that use coal as a fuel source may be subject to OSHA’s Hazard Communication Standard (HCS) if their employees are exposed to regulated concentrations of coal dust while performing their jobs.

F

or employers, one requirement under the HCS is to make material safety data sheets (MSDS) available to workers exposed or potentially exposed to hazardous chemicals. Substances subject to the HCS are listed at 29 CFR 1919.1000, Table Z-1, which contains two entries for respirable coal dust (respirable is defined based on a formula that measures the amount of coal dust per cubic meter and the amount of silica in that respirable fraction).

In general, a very small amount of coal dust in the air will trip the HCS requirements. According to OSHA, employers can reasonably expect their employees to be exposed to regulated amounts of coal dust during normal operations (e.g., virtually any transfer of coal from its storage location into a boiler). MSDSs must also be maintained if exposure may occur during a foreseeable emergency.

Employers who have their employees engage in such coal handling actions can obtain MSDSs for coal from a number of sources:

  • Generic MSDSs are available for products/complex mixtures with similar hazards and characteristics. In this case, the generic MSDS would cover various types of coal that may be provided by different suppliers to a facility.
  • Private services are available to provide MSDSs to employers.
  • Employers may develop their own MSDS. The requirements for performing a hazard determination and for MSDS content are at 29 CFR 1910.1200(d) and 19101200(g), respectively.
  • The employer may also request an MSDS for the coal from the mine itself. The Mine Safety and Health Administration (MSHA) passed a hazard communication standard (30 CFR Part 47) that addresses the provision of hazard information to customers of the mine. Subpart H of the rule states: “For a hazardous chemical produced at the mine, the operator must provide customers, upon request, with the chemical’s label or a copy of the label information and the chemical’s MSDS.”

Regardless of the method used to obtain the MSDS, the employer is required to maintain MSDSs for coal dust and any other hazardous chemicals used at the facility.

In discussing the HCS requirements for coal dust, OSHA also notes that similar requirements apply to fly ash, which is a by-product generated by coal combustion.

Depending on the type of coal being used, the fly ash may contain between 15 percent and 60 percent silica.

Since silica is regulated by OSHA, fly ash that can expose employees to silica is also considered a hazardous substance for the purposes of the HCS.

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