A Strategic Approach to an Effective Hazard Communication Program

Written By: Atanu Das on Monday, December 4, 2017

As you may be aware, OSHA has recently published a fact sheet and compliance guide on the hazard communication standard (or Hazcom, as it is commonly termed). When OSHA lists its top frequently cited violations, Hazcom is almost always at or near the top for years on end. In the current fiscal year, there are already 4,652 violations of this standard, ranking second on the list. Why does this continually happen and what can you as an employer do to ensure you are compliant?

Start out by understanding that merely having compliant Safety Data Sheets is only one step in having a well prepared hazard communication compliance strategy. If you haven’t already done so, make sure to review the OSHA standard for the requirements applicable to your workplace.

In summary, the Hazcom standard requires all chemical manufacturers, importers, and employers to Evaluate, Communicate and Train. This is achieved in the following steps:

Evaluate the hazards of the chemicals produced or imported, and prepare labels and safety data sheets to communicate the hazard information to downstream customers;  and

Train your exposed workers on how to to handle the chemicals appropriately. This training must ensure employees can demonstrate their understanding of how to properly read container labels and safety data sheets

OSHA says employers can implement an effective hazard communication program by following these six steps:

1. Learn the standard and identify responsible staff for implementing.
2. Prepare and implement a written hazard communication program. Your program must outline hazard communication will be addressed at your site. You’ll need to prepare a list or inventory of all hazardous chemicals. The program must specify your procedures for labeling, maintaining SDSs, and providing employee information.
3. Ensure that containers are labeled. Chemical manufacturers and importers are required to provide labels on shipped containers with a product identifier, signal word, pictograms, hazard statements, precautionary statement, and contact information for the responsible party.
4. Maintain safety data sheets. Sheets are required for each hazardous chemical in the workplace, and they must be accessible to employees. If you do not receive an SDS from your supplier automatically, you are required to request one. If you choose to supply SDSs electronically, OSHA requires an adequate back-up system in the event of a power failure, equipment failure, or emergency.
5. Inform and train employees. Employers must train employees on the hazardous chemicals in their work area before their initial assignment, and when new hazards are introduced. The training must be in a language and vocabulary employees can understand. Workers must be aware of protective measures available at the worksite.
6. Evaluate and reassess your program. Revise your program to address changed conditions, such as new chemicals and new hazards. OSHA requires that your hazcom program remain current and relevant.

Let’s look a little closer to the three main steps mentioned earlier:

Evaluation

The logical way to do this is to first prepare an inventory of all the chemicals you manufacture or import, as well as a list of the ingredients in the mixtures produced. To create the list of ingredients from the mixtures produced, consider information found in the chemical formula, on order receipts, batch sheets, and so on.

If a chemical inventory is not already in place, a good start would be to review purchase orders and receipts to create an initial inventory. Next, take time to inspect the workplace to identify any additional chemicals present.

While determining what materials to include in your inventory, consider if any of your products meet the definition of a hazardous material per OSHA. These include any chemical classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified

After compiling a complete list of the potentially hazardous chemicals in the workplace, the next step is to determine if you have received SDSs for all of them. Check your files against the inventory you have just compiled. Employers are required to have SDSs for all hazardous chemicals that they use. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by keeping a copy of a letter or e-mail, or a note regarding telephone conversations. If you cannot show a good faith effort to receive the SDS, you can be cited for not having the SDS for a hazardous chemical.

Communication

The very essence of this step in the hazcom process depends on how effectively one conveys chemical hazard information both in the workplace and to affected downstream users. This is done with labels and safety data sheets.  As defined in the hazcom standard, a label is an appropriate group of written, printed or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging. Safety data sheets (SDSs) are written or printed material concerning a hazardous chemical that is prepared in accordance with specific standards (such as the Globally Harmonized System).

OSHA has guidance on what an inspector evaluating your program with respect to labeling and SDSs will focus on.

For labels:

1. Designation of person(s) responsible for ensuring compliant labeling of shipped and in-plant
   containers;
2. Description of written alternatives to labeling of stationary process containers (if used);
   
   
3. Appropriate labels on all workplace containers, including those received from a supplier, secondary containers, and stationary process containers;
4. A description and explanation of labels on both shipped and workplace containers included in
   the employee training program; and,
5. Procedures to review and update workplace label information when necessary.

 

For SDSs, they will be looking for the following items in your program:

1. Designation of person(s) responsible for obtaining and maintaining the SDSs;
2. How such sheets are maintained in the workplace (e.g., in notebooks in the work area(s) or electronically), and how workers obtain access to them when they are in their work area during the work shift;
3. Procedures to follow when the SDS is not received at the time of the first shipment;
4. An SDS for each hazardous chemical in the workplace, and training of workers that includes review of SDS format and use.

Training

A critical, and often overlooked aspect in the hazcom program is effective training. OSHA has clearly mandated that employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical specific information must always be available through labels and safety data sheets.

For information and training to be effective, the workers in the training must comprehend the hazards in the workplace and ways to protect themselves. OSHA does not expect that workers will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools. Workers must also be aware of the protective measures available in their workplace, how to use or implement these measures, and who they should contact if an issue arises.

Now What Comes Next?

Ultimately following all these steps demonstrates to OSHA that employers, manufacturers and importers involved with hazardous chemical use are making reasonable efforts to comply. Avoiding the common tendency to think that hazard communication programs are mostly an “exercise in paper creation” by placing a three-ring binder on a shelf to gather dust will invariably steer you away from becoming a statistic on next year’s top 10 list. Keep in mind that this program is ever changing based on your specific chemical usage and is beneficial for you and your chemical users, employees and overall business in general.

Let us know if you need assistance with auditing or implementing your hazcom program.