OSHA’s Hazard Communication Standard (HCS) is based on a simple concept that employees have a right to know and understand the hazards of the chemicals they might be exposed to in the workplace. Unfortunately, many employers fall short when it comes to compliance with the HCS as evidenced by the fact that hazard communication is always toward the top of OSHA’s most cited violations every year.
The HCS requires information to be prepared and transmitted regarding all hazardous chemicals. The standard covers both physical hazards (such as flammability) and health hazards (such as irritation, lung damage, and cancer.) All stages of the chemical supply chain are covered by the standard. Chemical manufacturers, distributors, and importers must evaluate the hazards of the chemicals and provide Safety Data Sheets (SDS) and labels for each hazardous chemical to the downstream users. Employers that use hazardous chemicals in the workplace must create a written hazard communication program, train employees, and maintain SDSs for all chemicals in the facility. Employers should be aware that the word “use” means to package, handle, react, or transfer chemicals. This is an intentionally broad meaning so that almost any situation is covered under the HCS where a chemical is present in the workplace in such a way that employees may be exposed.
The HCS was revised in 2012 and is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The Safety Data Sheets are required to present important information in a consistent, user-friendly, 16-section format. Chemical manufacturers and importers must prepare labels that include a harmonized signal word, pictogram, and hazard statement for each hazard class and category.
Employers can implement an effective hazard communication program by following these simple steps:
- Identify responsible staff who will be responsible for particular activities such as training on the program and updating the Safety Data Sheets.
- Prepare and implement a written hazard communication program. The written program should explain how hazard communication will be addressed at the workplace. The responsible employee(s) should perform an inventory and then prepare a list of all hazardous chemicals in the workplace. The written program should also describe the company’s procedures for maintaining the Safety Data Sheets, providing information to employees, and the procedures for labeling of the chemicals.
- Ensure that all containers are labeled.
- Maintain Safety Data Sheets. Employers are required to have an SDS for each hazardous chemical in the workplace, and the SDSs must be accessible to all employees.
- Inform and train all employees. Employees must be trained on the hazardous chemicals in their work area before starting their initial assignment, and thereafter whenever new chemical hazards are introduced. Further, employees must be trained in a language and vocabulary they can understand.
- Evaluate and revise to address changed conditions. OSHA requires that the hazard communications program remain current and relevant to chemical hazards in the workplace.
Please contact a safety professional or a member of our Labor & Employment section with questions regarding OSHA’s Hazard Communication Standard.