What's in a Written Hazard Communication Program?
In the past ten years, OSHA has issued more citations for Hazard Communication violations than for violations of any other general industry Standard. For fiscal year 2022, the Hazard Communication Standard or HCS (29 CFR 1910.1200) ranked second on the list of the ten most frequently cited health and safety Standards, behind only fall protection in construction.
The HCS requires employers to inform employees about the hazards associated with chemicals in their workplace with a written program, mandatory training, hazard labels, and Safety Data Sheets (SDS).
Failure to develop or maintain the written program is one of the most-cited HazCom violations every year. To comply with the HCS, employers must develop and implement a hazard communication program that includes all the information OSHA describes in 29 CFR 1910.1200(e).
Who is Required to Comply with the HCS?
The HCS defines employer to mean:
“a person engaged in a business where chemicals are either used, distributed, or are produced for use or distribution, including a contractor of subcontractor.”
[29 CFR 1910.1200(c)]
The definition of employer explicitly excludes “workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances.”
In addition to the requirements for workplaces in which employees may be exposed to hazardous chemicals, the HCS requires chemical manufacturers, importers, and distributors to properly classify chemicals, label shipped containers. These facilities must also provide detailed information about the chemicals’ hazards to downstream users.
What’s In a Written HazCom Program?
A written Hazard Communication program is a detailed plan that describes how your workplace will comply with OSHA’s requirements for:
- Container labeling [1910.1200(f)];
- Safety Data Sheets [1910.1200(g)]; and
- Employee training [1910.1200(h)].
Other mandatory elements of the written program are:
- A list of hazardous chemicals present in the workplace (identified using a product identifier referenced on the appropriate safety data sheet).
- A description of how you will inform employees about the hazards of non-routine tasks and the hazards associated with chemicals in unlabeled pipes in their work area(s).
[29 CFR 1910.1200(e)(1)(i) and (ii)]If your workplace manufactures, imports, or distributes chemicals, your written plan must include details about how you will comply with the HCS requirements specific to those workplaces in addition to the details covered here.
Creating a Written HazCom Program
Before you create a plan, health & safety leaders should get to know the HCS inside-and-out. To plan how your workplace will comply with the Standard, you need to know all of the relevant rules.
Below are some key considerations to keep in mind when developing each section of the written program.
Chemical Labeling (Paragraph f)
How will you ensure that chemical containers are properly labeled?
Will all hazardous chemical containers arrive from the supplier with original manufacturer or importer labels that contain all the information the HCS requires? If yes, write that in the plan.
Who will verify that every received container is labeled with all required information? These employees should be identified in the plan, by name or by position title. If a chemical arrives without the required label, or the label is somehow damaged in transportation, how will you ensure that it is labeled so that all required information appears?
If you will be required to label workplace containers that employees use, your written program should specify the type of labels you plan to use—whether that is “GHS” style hazard labels or approved alternatives like Hazardous Materials Identification System (HMIS) or National Fire Protection Association (NFPA) labels.
Safety Data Sheets (Paragraph g)
How will you comply with the rules for Safety Data Sheets (SDS)?
Who will be responsible for reviewing Safety Data Sheets (SDS) received with chemical shipments? When a new SDS arrives with a shipment, it should be reviewed for any new hazard information that it may include. Any new information must be communicated to employees who may be exposed to the substance. The written program can describe how you plan to do this, if necessary.
Where will Safety Data Sheets be kept, and how will you ensure employee access? If you store physical copies of the sheets, where will they be stored and who will put them there? If you maintain each SDS in an electronic format, how will employees be informed about how to use that computer system to access the hazard information?
Employee HazCom Training (Paragraph h)
How will you ensure that all covered employees receive required HazCom training?Your plan should include the details of who will be trained, when they will be trained, what that training will cover, and who will provide it.
In 29 CFR 1910.1200(h), OSHA requires employee training to include at least:
- The requirements of OSHA’s Hazard Communication Standard (HCS),
- Any operations in their work area where hazardous chemicals are present,
- The location and availability of the written program, including the list of hazardous chemicals
- Awareness of the hazards of chemicals present in the workplace,
- Specific workplace duties that involve use of hazardous chemicals,
- How to read and understand information on hazard labels used in the workplace,
- How to read and understand a Safety Data Sheet,
- Where or how Safety Data Sheets can be accessed in the workplace,
- How to detect the presence or release of a hazardous chemical in the work area,
- Where to find and review the written hazardous communication program
If your organization uses Lion’s Hazard Communication online training to help satisfy this OSHA requirement, you can find a short description of the course and a list of topics covered here.
Online Training to Manage Hazard Communication Compliance
The Managing Hazard Communication Online Course prepares EH&S professionals to identify regulated chemicals in their workplace and create/implement a required written program for compliance with the HCS regulations in 29 CFR 1910.1200.
The Hazard Communication Online Course covers what employees need to know to recognize hazardous chemicals, read hazard labels and pictograms, use Safety Data Sheets, and protect themselves from chemical hazards on the job. The course is designed to help satisfy OSHA's training requirement for employees under the HCS.
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