The Hazard Communication Standard And OSHA?s Requirement for a Written Program

In last year’s general industry violation list (as well as on previous lists), the HazCom program appeared on the top rank, with 2,220 violations, including 1,254 serious ones, and just two ranks below was training on new chemical hazards.  It’s clear that the hazard communication standard is one of OSHA’s most important, since it protects employees against hazardous substances and requires chemical manufacturers, importers, and users to communicate information about hose hazards to employees who work with them.

This standard (29 CFR 1910.1200) covers some 7 million workplaces, more than 100 million employees, and 945 chemical products.  OSHA says that a written hazard communication program “helps employers design and implement appropriate controls for chemical exposures and gives employees the hazards and identities of the chemicals, as well as allowing them to participate actively in the successful control of exposures.”

The essential elements of the written HazCom program are:

  • Labels (and other forms of warning). Included are the persons responsible for ensuring the labeling of containers — in-plant and shipped, and the labeling system, with alternative labeling and procedures for updating when necessary.
  • Material Safety Data Sheet (MSDS) access system.  Included is the process for locating and using MSDS’s, whether on-site or via an electronic file system or other off-site retrieval.  The description of the process must include the person(s) responsible for obtaining and maintaining the MSDS’s, how they are accessed and maintained in the workplace, procedures to follow when the MSDS has not been received, and a backup system for obtaining information.
  • Employee information and training.  Employers shall provide their employees with effective information and training on hazardous chemicals in their workplaces
  • Non-routine tasks.      Methods to be used will inform the employees of those tasks, such as cleaning reactor vessels.
  • Pipes. There must be a description of how employees will be informed of hazards associated with chemicals contained in unlabeled pipes in work areas.
  • Access to the written plan.  This must be readily available to employees, their designated representatives, the assistant secretary of labor for occupational safety and health (or the applicable state agency), and the director of NIOSH.
  • Multiemployer worksites.  If an outside contractor or vendor is employed, your company is responsible for making sure the contractor complies with HazCom requirements if his workers may be exposed to the chemical hazards.
  • Hazardous chemicals list.  A list of all these chemicals in the workplace must be prepared and checked against the appropriate MSDS’s.