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Pulse Point Newsletter for August 28, 2001
Published by Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
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REVIEWING MEXICO'S HAZARD IDENTIFCATION AND COMMUNICATION STANDARD NOM-018-STPS-2000

By Enrique Medina, MS, CIH

Mexico's Secretariat of Labor and Social Security (STPS for its Spanish acronym) issued Official Mexican Standard NOM-018-STPS-2000, System For the Identification and Communication of Hazards and Risks from Hazardous Chemical Substances in the Workplace" in October 2000. This NOM modified the previous standard NOM-114-STPS-1994 of the same name.

The new standard provides a process for developing and implementing a Hazard and Risk Identification and Communication System (HRICS). The system's three main element consist of: (1) developing and implementing a Hazard and Risk Identification System for all hazardous chemicals; (2) maintaining current Material Safety Data Sheets (MSDS) for all hazardous chemicals used in the workplace, and (3) training employees in the elements of the standard and keeping a record of such training.

The new standard applies to all work places where hazardous chemicals are handled. Finished products ready for commercialization or off-site transportation of hazardous chemicals, which are regulated by other agencies' rules are not covered. In addition, products with health, fire, and reactivity hazard rankings of zero are excluded.

Although this standard shares elements found in the United States' OSHA Hazard Communication standard (HazCom), and the Canadian Workplace Hazardous Materials Information System (WHIMS), it has important differences as well.

Employer's obligations under NOM-018-STPS-2000 include the following:

Identifying with required labels and signage all vessels, containers and areas where hazardous chemicals or waste are kept
Communicating to employees and contractors the hazards and risks from exposure to hazardous chemicals using the established system
Keeping a registry of employees who have been informed
Knowing the hazard ranking and the risks of the hazardous chemicals used in the workplace
Having available Material Safety Data Sheets (MSDS) for all hazardous chemicals, according to the requirements of the standard
Issuing MSDS to clients for the chemicals they acquire, with proof of delivery
Training employees in the HRICS at least annually, and whenever a new material is introduced, or a process is modified
Keeping a log of the most recent training for each employee
Providing training certificates to all employees who request them.

In turn, employees are required to participate in the communication and training activities provided by the employer, following the HRICS's instructions, and informing the employer of any detected hazardous condition, which cannot be corrected following the established procedures.

The Hazard and Risk Identification System is intended to provide employees with immediate visual information to prevent health hazards or damage to the workplace. It is based on the use of one of two hazard labeling formats, the National Fire Protection Association's (NFPA) diamond, or the Hazardous Material Information System's (HMIS) rectangle. Employers may also choose an alternative labeling system with prior approval from STPS. Specific requirements for each of these models are described, such as color, content, dimensions, customization, and placement.

The labels or signs must be indelible and made of a resistant material appropriate to the conditions to which they will be exposed. Container labels may be replaced with area signs when only one hazardous material is stored in a specific area or shelf. Signs must be visible and placed in unobstructed locations. All containers in process areas or used to transport hazardous materials must be permanently labeled. Label and sign dimensions are based on container capacity, with four size ranges starting from 3.8-18, 18-50, 50-200, and more than 200 liters or kilograms. As a point of reference, 200 liters is equivalent to a 55-gallon drum. There is also a size requirement based on distance. Signs for distances under 5 meters must cover 125 cm2 (19.3 in2), while those for distances greater than 50 meters need to be no less than 12,500 cm2 . A formula is provided for sizing signs at the intermediate distances.

Selection of Personal Protection Equipment (PPE) specifications for the hazard labels should be based on the physical and chemical characteristics of the material, route of exposure, and handling of the hazardous material.

The Training and Communication component requires hazard communication in the system used at the work place to be clear, accurate, and simple. It must be provided to all employees. Training for emergency response personnel must follow the requirements of NOM-005-STPS-1998, which regulates health and safety conditions where hazardous chemicals are used. Basic training shall include:

Risk classification and types of hazards from each hazardous material
Interpretation of the colors, numbers, letters and symbols of the HRICS
Interpretation of the letters or symbols for specific PPE requirements
Information and content of the MSDS
Information regarding the individual to consult for questions.

NOM-018-STPS-2000 provides detailed instructions for the preparation and management of MSDS. All workplaces must have an MSDS for each hazardous chemical used or stored, which must be available permanently to all employees who use these materials. MSDS forms must be written in Spanish. While the format is open, it must contain the specific information listed in the standard. No blank spaces are allowed. When a specific data element is not available or applicable, it must be noted as "NA" or "ND", respectively. The reference sources consulted shall be listed at the bottom of the MSDS form. MSDS must be updated whenever new data exists on the hazardous material.

The content of the MSDS is compatible with the U.S. and Canadian models. It consists of the following major sections:

General information, including preparation date and updates.
Information on the hazardous chemical
Hazardous material identification, including permissible exposure limits according to NOM-010-STPS-1999, hazard ranking for health, fire, reactivity, and special hazards, and name and percentage of hazardous ingredients (over 1% of content).
Physical and chemical properties
Fire and explosion risks, including extinguishing media, PPE, fire fighting procedures, and products of combustion.
Reactivity data
Health hazards and first aid, including route of entry, toxicological information, emergency and first aid measures, and other medical information.
Spill response procedures
Emergency PPE
Transportation information according to the Regulations for the Land Transport of Hazardous Materials issued by the Communications and Transportation Secretariat, the UN, and the North American Emergency Response Guide.
Environmental information related to water, air, soil, and hazardous waste, according to requirements from the Secretariat of Environment and Natural Resources.
Special precautions for handling, transportation and storage.

The standard contains a detailed description of the hazard ranking systems for assigning health, fire, reactivity, PPE and special risk rankings for each of the two optional formats.

NOM-018-STPS-2000 includes a Reference Guide for Classification of the Type and Degree of Risk of Some Chemical Substances. This is a non-mandatory complement to the standard, containing the NFPA and HMIS hazard rankings for 931 chemicals listed alphabetically with corresponding CAS numbers.

The best option for complying with this standard is to obtain complete MSDS forms in Spanish from the chemical manufacturer with appropriate hazard label information. A less desirable option is to translate the English language MSDS from the manufacturer into Spanish. Facilities should use only qualified technical translators to ensure accuracy and to limit potential liability. Those who opt to use the standard's guidance document to develop hazard labels at their facilities should note that the health hazard ranking criteria used by NFPA and HMIS are different from each other. Also, these rankings apply to pure chemicals and may not be appropriate for mixtures or dilutions. A qualified industrial hygienist or toxicologist should review all hazard rankings developed by facilities in order to ensure their accuracy and that proper protection and information are provided to employees as required by the standard.

If you have questions about how this or other health, safety or environmental regulations may affect your operations, please contact us at (619) 297-1469 or send us an email at emedina@pulse-point.com.
PP

Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
3361 28th St.
San Diego, California 92104
(619)297-1469
(fax (619)297-1023
emedina@pulse-point.com
www.pulse-point.com/alliance

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Pulse Point is written for the benefit of our readers with the sole intent to provide general information. The articles are not intended as specific opinions or as a substitute for professional advice in individual cases.