When OSHA revised its Hazard Communication Standard in 2012 to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, the final transition deadline of June 2016 was years away. In that time period, employers covered under HazCom were expected to train employees on the revised standard (by December 2013), and manufacturers were expected to update all labels and safety data sheets to comply with the requirements (by December 2015). And now, all employers covered under HazCom are expected to be in full compliance.
Has everyone in your shop been trained on the hazardous chemicals they’re exposed to on a daily basis? In this column, we’re going to talk about how you can create a safer, more informed workplace, as well as stay compliant with OSHA regulations.
Six Steps to Success
According to OSHA, a successful and effective hazard communication program can be accomplished in six steps:
1. Learn about the standard, including and especially how it applies to your workplace. The standard, as well as guidance, interpretations and other educational materials, can be found at www.osha.gov/dsg/hazcom. If you haven’t done so already, identify staff members who will be responsible for ensuring your shop is in compliance with the standard and facilitating training for all employees. Remember, these are ongoing responsibilities, not one-time tasks. In some cases, assigning backup employees is a good idea in case of turnover or shifting of duties.
2. Prepare a written plan for your shop to indicate how you will address hazard communication at your facility. This plan should include a list of all the hazardous chemicals in your shop. When you start using a new chemical, it should be added to that list. Your shop’s HazCom plan does not have to be extensive or complicated. Chemicals can be listed by any sort of product identifier, such as product name or chemical name, but the same identifier should be used both on the label and the safety data sheet (SDS). Remember, chemicals come in all forms: liquids, solids, gases, vapors, fumes and mists.
3. Make sure your chemical container labels are up to date. Keep labels on containers that have been shipped. When you transfer chemicals from bulk containers to smaller containers, make sure those containers are also labeled appropriately. The addition of pictograms on labels was intended to draw attention to the hazards of a particular product, as well as let employees (no matter what language they speak) identify those hazards quickly.
4. Maintain safety data sheets (SDS) for each chemical in the workplace. Safety data sheets give detailed information for workers and are a requirement for every hazardous chemical. If you have old MSDS materials, make sure they’re replaced with new ones. Each new shipment of a chemical should have a current version of the sheet. Also, make sure that all employees know where the SDS are located and that employees can access them when necessary. If you’re using an electronic SDS database, there should be a backup paper copy in case of an emergency such as a power outage.
5. Inform and train employees. New hires should be trained upon entering the workplace. All employees should be trained when a new chemical or other hazard is introduced. Employees should know the general requirements of the standard, the location of hazardous chemicals in work areas and what the workplace hazard communication program includes (including where and how to access it). Shops need to make sure they aren’t just passing out information, but rather creating an environment where employees understand the information and are comfortable asking questions.
Training must address:
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.)
- The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.
- The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures and personal protective equipment.
- The details of the hazard communication program developed by the employer, including: an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the SDS, including the format of the SDS (where each type of information is located); and how employees can obtain and use the appropriate hazard information.
6. Review and adjust your program accordingly. Periodically, you should review your hazard communication program and measure its successes or shortcomings. No two programs are alike, so be flexible and open to suggestions from employees. In addition, remember to revise your program as new chemicals enter the workplace. Most importantly, your plan should always be accurate. Proactive monitoring of the workplace and the hazards within is critical to having a successful and compliant hazard communication program.