OSHA’s new Hazard Communication Standard took effect Dec. 1, 2013, but before that, the workplace safety agency had mandated that all employers were required to train their employees about any hazardous chemicals in the workplace.
But that training alone won’t be enough to avoid being cited by OSHA. The Hazard Communication Standard is one of the most-often cited of OSHA’s safety standards. It’s also of extreme importance to the health of your workers, as it makes them aware of potentially hazardous chemicals they may be exposed to in the course of their work.
Already many employers struggle to create a hazard communications program that complies with OSHA’s rules. And there is more confusion now that the Hazard Communication Standard has been harmonized with the United Nations’ Globally Harmonized System (GHS) for classifying and labeling chemicals.
Brady Corp., a Milwaukee-based manufacturer and marketer of complete identification solutions, has published a booklet on complying with the new Hazard Communication Standard and it recommends the following:
Develop a written Hazard Communication plan – Your plan should include a summary of the hazardous chemicals you have on your premises, as well as your firm’s policy for dealing with hazardous chemicals.
The plan should include the scope of your policy, how you communicate chemical hazards, a review of the new hazcom standards, your employee training, and a regular inspection schedule. Your policy needs to be implemented and maintained in all of your worksites.
According to OSHA’s 29 CFR 1910.1200(e) regulation, a written hazard communication program must include (at minimum):
- Purpose and scope of the program
- A list of known hazardous chemicals in the workplace to be drawn up in the format of safety data sheets (SDSs)
- Labels that coincide with correct and current information in the SDSs
- Training and information for employees to convey any changes to the Hazard Communication Standard, as well as the new GHS labels and SDSs
- Methods for updating, evaluating and conveying information about chemical hazards
- Work processes for non-routine tasks surrounding hazardous chemicals, and the associated risks involved in those tasks
- Appropriate storage and transportation of hazardous chemicals and materials
- Where and how employees must travel between workplaces and work shift changes when dealing with hazardous chemicals and materials
Inventory all hazardous chemicals – Make an inventory list of the hazardous chemicals found in your worksites and match them with properly formatted SDSs.
Your chemical inventory management system should also include:
- Location tracking
- Container tracking and reconciliation reporting
- Unit of measure conversions and calculations
- Material approval routings
- Methods of managing restricted and banned chemicals
- Notifications of exceeded thresholds
Maintain a complete library of SDSs – Employees should have easy access to your SDSs at all times.
Your program should outline how employees can access individual SDSs, be they paper or in electronic format.
Clearly post which employees are responsible for obtaining and maintaining the SDS library.
After you receive SDSs from chemical manufacturers, make sure the labels comply with all of the elements. The following elements are included in a typical hazardous chemical SDS:
1. Identification of the substance or mixture, and of the supplier
2. Hazards identification
3. Composition/information on ingredients
4. First-aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information, including information on preparation and revision of the SDS
Label all storage containers, pipes and tanks – Use highly visible permanent labels to clearly communicate chemical hazards to your employees.
All containers and tanks that store chemicals in your organization’s facility must be properly labeled in accordance with the Hazardous Communications Standard.
If you remove chemicals from their primary containers and place them into secondary containers for use in the workplace, then you must properly label the secondary containers too.
Also, pipes that carry hazardous chemicals should ideally have pipe markers at fixed distances.
Train your employees in your HazCom policy – You must fully train affected employees in all elements of OSHA’s Hazard Communication Standard.
Train them in reading and interpreting hazardous chemical labels and SDSs. They should also know where you store the SDSs, and how to access them.
Regularly communicate and provide reminders (posters, updates, memos) to employees to keep them actively aware of the HazCom program.