Tag Archives: OSHA

Safety Goggles

Props people are often said to “have a good eye” when it comes to building furniture or dressing a set. Well, if you don’t wear safety goggles when working in the props shop, you may end up with NO EYES AT ALL.

Safety goggles are often thought of in two different ways; there are impact resistant goggles and chemical splash goggles.

When you are woodworking, grinding metal, even hammering, you are creating the risk that a piece of material will fly into your eyes. Impact resistant goggles will protect your eyes from all but the most severe projectiles; if you are working on something that can break through a pair of impact resistant goggles, it can probably also break through your skin and or bones, in which case, you need more than just eye protection. Specifically, OSHA sets the minimum standard which impact resistant goggles must meet to ANSI Z87.1. You can read a summary of ANSI Z87.1 to see what kind of tests they perform on goggles.

For chemical splash goggles, most labs also recommend goggles which conform to ANSI Z87.1 as a minimum. Additional recommendations include goggles which wrap around the sides to fit snugly against the face. Elastic bands keep the goggles tight against the face and resist being knocked off from side impacts. Vents on the side help the eyes breathe and keep the goggles from fogging, but they should be designed in a way so that chemicals splashing from the front can’t get inside.

You can, of course, find goggles which claim to be chemical splash goggles but offer no impact resistance whatsoever. These will keep your eyes dry but little other protection. Since you should have ANSI-rated goggles for both impact and chemical protection, these kinds of goggles are completely worthless and should be avoided at all costs.

Working in props can demand both types of goggles. Carpentry, metal-working and other “hard materials” projects require impact resistant goggles. Working with epoxies, resins, powders, paints and other chemicals, as well as with heat and glassware, require chemical splash goggles. You can, of course, find a single pair of goggles which fills both needs, or you can have two pairs of goggles. Either way, you do not want to use goggles which fit neither needs. Often, you can find yourself working in a prop shop where a couple pairs of goggles are found thrown in a bin, with no indication of whether they conform to safety standards, not to mention how unhygienic this is. If you can’t identify the brand and model of a pair of goggles, then you can’t know whether it conforms to safe standards, and you have to assume it does not.

I recommend having your own personal set of goggles. Besides working in shops with a poor selection of safety equipment, you may also find yourself working in places which aren’t actually shops. Technically, your employer is supposed to provide you with the safety equipment you need, but like most props artisans, you may do a fair amount of work on your own, either as a hobby or to make extra cash. A personal pair of goggles also means you can find a pair that fits well and that feels well; you should not forgo eye protection just because most goggles feel uncomfortable on your face. You have a multitude of choices in eyewear out there, most under $20. Even the most expensive pairs are only $80-90, which is still far less than the cost of a visit to the eye doctor, not to mention the lifetime cost of losing an eye. Mind you, the price of goggles is not necessarily an indication of their quality or effectiveness.

A Label of Love

Here is a funny item I found a few years back while cleaning out a theatrical props shop:

Badly labeled bottle

Once you stop laughing, you should realize it’s not actually funny. It’s serious: deadly serious. A container without a proper label can potentially contain any number or combination of hazardous chemicals, and should be treated as such. If you are just a hobbyist or sole proprietor of a shop, you should follow the proper labeling of chemicals for the reasons I give in the last two paragraphs of this article. If you work in a company with more than ten employees in the United States of America, then you are legally obligated to follow the OSHA regulations on Hazard Communication, which have strict and well-defined rules for labeling of products. You should know these whether you are the employer or employee (technically, as an employee, your employer is required to make sure you know these rules and train you if you don’t). The ten employee–rule does not apply just to the prop shop; the whole company is counted. If you count up the employees in finance, literary, scenery, marketing, lighting, box office, casting, etc., you will probably find that most theatres employ way more than ten people.

Part of the OSHA regulation on Hazard Communication (1910.1200) states what is needed for labeling:

“Labels and other forms of warning.”

The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: Identity of the hazardous chemical(s); appropriate hazard warnings; and name and address of the chemical manufacturer, importer, or other responsible party.

You can read the entire Hazard Communication (1910.1200) regulation if you like. It further defines what is meant by all of its terms, such as what constitutes a “hazardous chemical”, where to find the appropriate hazard warnings and other information of this type. Like many government regulations, the language can seem heavy, the wording verbose, and the overall tone threatening. Here’s the thing; in order for a manufacturer or importer to sell these products, they are the ones who need to abide by these rules. If you buy properly-labeled products from legitimate manufacturers in the United States,  then you are already following the labeling requirements. If you remove or deface the label, or transfer the product to an unlabeled container, then your employees can no longer see what hazardous chemicals are present and you are in violation of the Hazardous Communication regulation.

During Hazard Communication training with Monona Rossol this past July (part of the 2010 S*P*A*M Conference), I learned an interesting caveat. If you purchase a product from another country, you become the “importer.” You are now responsible for making sure the labeling requirements are properly followed, and because US requirements differ in subtle ways from other countries, a foreign product will not necessarily have the right label. It also means you are the one responsible for creating the MSDS. What this all boils down to is that if one of your employees becomes adversely affected by the chemicals in that product while employed by you, you can be legally liable if the label and MSDS do not follow OSHA’s regulations for properly warning the employee of the health risks. If you find a product from a foreign company that you like and want to use, you need to find a US distributor of that product and only purchase it from them.

The regulation does have some allowances. You do not need to label the container if, according to the regulation, “the container into which the chemical is transferred is intended for the immediate use of the employee who performed the transfer.” Suppose you are mixing a two-part RTV silicone to make a mold. You pour each part into a cup to measure it, then you pour these into a third cup to mix it. These cups you are using do not need to have a label for RTV silicone on them because you are the one who poured the stuff in, and you are using the stuff immediately.

If you do not use it immediately, you may forget about it, and years later, someone else digs up a bottle marked “Kerosene?” I hope by now, you realize this is in gross violation of the labeling requirements. Because it is mislabeled, we do not know what hazardous chemicals are present, and thus, we do not know what we need to protect ourselves. Do we need to wear gloves? If so, what kind? Do we need a respirator? If so, what kind? Is this flammable? Acidic? Also, without a manufacturer’s name and address, we have no one to contact to get an updated MSDS.

We have a secondary problem; how do we dispose of this? Depending on local regulations, dumping many kinds of hazardous chemicals down a drain is illegal. Even without regulations, there are certain chemicals that should not be dumped down a drain regardless. Without a label, we can’t be sure. The same is true for disposing of chemicals in the dumpster or garbage dump. Not knowing what chemicals are in this jug essentially make it “toxic waste”, with no easy way to get rid of it. It is quite a headache just because somebody did not feel like properly labeling or emptying that container when they were through using that product.

So Many Chemicals in the World

54,973,018. That’s how many registered organic and inorganic substances there were in the world when I wrote this sentence, according to the Chemical Abstracts Service (CAS). The Toxic Substances Control Act (TSCA) gives the EPA in the United States the authority to maintain an inventory of all chemicals used in commerce (excluding chemicals used in foods and food additives, pesticides, drugs, cosmetics, tobacco, nuclear material, or munitions). To date, their inventory contains 84,000 such chemicals. Over 1670 of these are considered hazardous substances which your employer is required to inform you when you are working with them. You’ve probably seen products which state “This product contains a chemical known to the state of California…” There are somewhere in the neighborhood of  750 chemicals listed under California’s Proposition 65 which are known to cause cancer or reproductive toxicity.

Of course, over 78% of the high volume chemicals produced have not had even basic toxicological testing (see Toxic Ignorance, published by the Environmental Defense Fund), let alone testing for carcinogenic properties. “High Volume” of course does not include all 84,000 chemicals used in commerce; in 1990, that list included a mere 2971 chemicals. In other words, around 653 chemicals have been tested for their toxicity by 1990. What a far cry that is  from the 54,980,438 registered chemicals in existence (when I wrote this sentence). Some estimates put the total amount of chemicals tested worldwide for carcinogenic properties at around 900. Nine hundred out of nearly 55 million.

What’s a props person to do? When you look at all the products you use – spray paints, adhesives, epoxies, mold-making and casting, coatings, sealants, resins, foams, cleaners, and so on and so on – and count up all the various chemicals contained within, you could have hundreds of hazardous and carcinogenic substances which you are exposed to on a daily basis. If you wish to make a career of making props, that could mean several decades of exposure. It adds up quickly.

One shouldn’t generalize about safety, because proper safety procedures involve specific actions for specific chemicals. But if one were to distill down the essence of safety it is this: don’t breathe anything but air, and don’t get stuff on you. Always use the least-toxic product in every situation. Often, the only benefit of a more-toxic option is speed, or ease of use. Formula 409 may cut grease faster and with less effort then soap and a scrubber, but soap will not be absorbed through your skin and cause reproductive harm.

In the brief time it took you to read this article, around 24 chemicals have been added to the CAS database. As I write this sentence, the number stands at 54,980,470.