SAFETY 101: HAZARD COMMUNICATION: STEPS TO AN EFFECTIVE HAZARD COMMUNICATION PROGRAM FOR EMPLOYERS THAT USE HAZARDOUS CHEMICALS
Employers that have hazardous chemicals in their workplaces are required by OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a hazard communication program. The program must include labels on containers of hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and training for workers. Each employer must also describe in a written program how it will meet the requirements of the HCS in each of these areas.
Employers can implement an effective hazard communication program by following these six steps:
Step 1. Learn the Standard/Identify Responsible Staff
- Obtain a copy of OSHA's Hazard Communication Standard.
- Become familiar with its provisions.
- Make sure that someone has primary responsibility for coordinating implementation.
- Identify staff for particular activities (e.g., training).
In order to ensure that you have an effective hazard communication program, and address all of the necessary components, responsibility for implementation of hazard communication should be assigned to someone to coordinate. The person designated for overall program coordination should then identify staff to be responsible for particular activities, such as training.
Step 2. Prepare and Implement a Written Hazard Communication Program
- Prepare a written plan to indicate how hazard communication will be addressed in your facility.
- Prepare a list or inventory of all hazardous chemicals in the workplace.
The written program also requires employers to maintain a list of the hazardous chemicals known to be present in the workplace. Using the product identifier (e.g., product name, common name, or chemical name) to prepare the list will make it easier for you to track the status of SDSs and labels of a particular hazardous chemical. Remember, the product identifier must be the same name that appears on the label and SDS of the hazardous chemical.
Step 3. Ensure Containers are Labeled
- Keep labels on shipped containers.
- Label workplace containers where required.
As the employer, you are required to ensure that containers in the workplace are labeled. You may use the same label from the supplier or you may label workplace containers with alternatives, such as third party systems (e.g., National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS)) in addition to the other required information. Any container of hazardous chemicals in the workplace must at a minimum include the product identifier and general information concerning the hazards of the chemical. Whatever method you choose, your workers need to have access to the complete hazard information.
Step 4. Maintain Safety Data Sheets (SDSs)
- Maintain safety data sheets for each hazardous chemical in the workplace.
- Ensure that safety data sheets are readily accessible to employees.
Step 5. Inform and Train Employees
- Train employees on the hazardous chemicals in their work area before initial assignment, and when new hazards are introduced.
- Include the requirements of the standard, hazards of chemicals, appropriate protective measures, and where and how to obtain additional information.
Step 6. Evaluate and Reassess Your Program
- Review your hazard communication program periodically to make sure that it is still working and meeting its objectives.
- Revise your program as appropriate to address changed conditions in the workplace (e.g., new chemicals, new hazards, etc.).
See Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals for more detailed information on how to implement an effective hazard communication program. Additional information on the Hazard Communication Standard can be found on OSHA's Hazard Communication webpage at www.osha.gov/dsg/hazcom.
|U.S. Department of Labor, OSHA, 2014|