Go Behind the Hazards to Prevent HazCom Citations

Every year HazCom features somewhere on OSHA’s top 10 list. Violations can have a significant impact on employee safety, and citations can be costly.

Many of the 7,000 HazCom violations cited this year were serious, which implies a substantial probability that death or serious physical harm could result. Even small oversights when hazardous materials are concerned can lead to grave danger for employees.

Issues involving labels and MSDSs are often at the core of HazCom citations. It’s not surprising, since OSHA views them as two of HazCom’s most powerful safety tools.

For example, during inspections, OSHA wants confirmation that MSDSs are readily available to employees, says Ken Schmerber, principal EHS consultant with Hellman & Associates, a Denver area safety and industrial hygiene consulting firm.

In some workplaces, says Schmerber, availability is ensured by establishing MSDS stations or kiosks where employees who do not have their own computers can access the sheets via communal terminals. Other alternatives are a phone and fax method or storing an inventory of sheets on a readily accessible Internet site or in binders.

“Regardless of whether you keep MSDSs on paper or electronically, OSHA wants them available to workers, not locked in a filing cabinet or in an electronic system people can’t get into,” says Schmerber.

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Secondary Labels

Transferring chemicals from large containers into smaller, easer-to-use secondary containers is another key HazCom issue. This relatively simple process results in many costly citations for employers in diverse industries.

“I think it’s one of the reasons you continue to see HazCom in the top 10 list,” says Schmerber.

A technique used successfully by Hellman & Associates clients gives employees access to a comprehensive binder with all relevant compounds listed in alphabetically order. An employee who needs to transfer a chemical into a smaller container looks up the chemical in question and finds a completed label. The content of the label is copied onto a new label template and then affixed to the secondary container.

Some employers provide completed labels in the binder, making it even easier to select the needed label, peel of the backing, and apply it to the secondary container.

The system is monitored by a supervisor or manager who walks the plant floor to ensure that no unlabeled secondary containers are in use.

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Making sure that MSDSs and labels are available is only half the battle, of course. The other half is making sure that employees know how to read labels and MSDSs to find the safety and health information they need to work safely with hazardous materials and prevent injuries and illness.

Tomorrow, we’ll highlight 5 keys to preventing employee exposures to hazardous materials, courtesy of 7-Minute Safety Trainer, the ready-to-use program that provides short, comprehensive training for all your employees for around $1 a day.

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