How to Get "Right to Know" Right

OSHA estimates that more than 32 million workers are exposed to 650,000 hazardous chemical products in more than 3 million American workplaces. If yours is one of those workplaces, then your employees are among those at risk of exposure, and the requirements of OSHA’s hazard communication standard (29 CFR 1910.1200) apply.

The hazard communication standard requires you to tell employees about chemical hazards and protections. Specifically, you must:

• Identify hazardous chemicals in the workplace.
• Explain how these substances are hazardous.
• Provide procedures and equipment to prevent chemical exposure.
• Train employees to reduce the risks of working with hazardous chemicals.

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Right to Know

The federal right-to-know law applies to all hazardous chemicals used or stored in the workplace and to all employees who may be exposed to any of these chemicals while performing their jobs. “All,” “all,” and “any” are the key words here.

To facilitate the communication of safety and health information about hazardous chemicals, you are required to have a written hazard communication program that explains, in detail, what your facility will do to teach employees about chemicals, hazards, and precautions to prevent injury and illness.

Your OSHA-required hazard communication program must cover:

• General requirements of the hazard communication standard
• Chemicals present in the facility and the hazards they present
• How employee training and information will be provided to recognize hazards and minimize risks
• Use of labels and material safety data sheets (MSDSs)
• Procedures and precautions that will be implemented to prevent overexposure to hazardous chemicals

You are also required to provide unrestricted access to MSDSs on all shifts and to make sure all hazardous chemical containers are properly labeled.

Many states have their own right-to-know laws, which generally cover the same requirements. But some may go beyond what OSHA mandates. OSHA requires state laws to be at least as stringent as the federal right-to-know law. If a state law is stricter, however, it preempts federal law. So, be certain to check your state’s hazard communication requirements and make sure your hazard communication policy and program reflect those requirements as well.

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HazCom Violations

In 2009, the hazard communication standard received the highest number of general industry citations from OSHA and was in third place overall for all regulated businesses. OSHA issued more than 7,000 violations and imposed almost $2 million in penalties.

Most frequently cited violations of the standard included:

• §1910.1200(e)(1), Written Hazard Communication Program
• §1910.1200(h)(1), Information on Hazardous Chemicals
• §1910.1200(g)(1), Material Safety Data Sheets
• §1910.1200(g)(8), Availability of MSDSs
• §1910.1200(h), Employee information and training
• §1910.1200(f)(5)(i), Hazardous chemical labels
• §1910.1200(f)(5)(ii), Appropriate hazard warnings required
• §1910.1200(e)(1)(i), Written hazard communication program

Tomorrow, we’ll review key points to include in your hazard communication training program to ensure employee safety and to help assure compliance with OSHA HazCom requirements.

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