OSHA gives an Update on Hazard Communication Standard Enforcement for 2019

Written By: Atanu Das on Sunday, October 13, 2019

Once again, Hazcom non-compliance was #2 on the list for most cited violations in FY 2018. Total initial penalties were nearly $8 million and nearly 65% were for serious violations. The standard most cited was 1910.1200 (e)(1), which requires employers to maintain a written hazard communication program at the workplace.

Under the General Industry category, Automotive Body Repair shops were frequently cited while in the Construction Industry, Masonry Contractors fell under OSHA scrutiny. The lack of a written hazard communication program is usually the "lowest hanging fruit" for an OSHA inspector and can lead to further violations cited.

Let's review what the minimum requirements for a written program are. At a minimum, it should contain:

• A list of hazardous chemicals present in the workplace - The employer may use any identifier for this list, but it is important to use the same name as on the SDS for cross-referencing. 

• Information on the hazards outside of the employee normal work routine - While workers receive initial training on their routine exposures in the workplace, the written program should address chemical and other exposure hazards involved with occasional/non-routine activities

• For Multi_Employer workplaces (e.g. where contractors are present, etc.), employees may be exposed to outside chemicals and will need to be informed

OSHA has a useful guidance document for employers outlining a sample written program which can be modified for your workplace. If you have more questions, we can help