What’s in Your HazCom Plan?

Does your written HazCom plan include all the information required by OSHA? Here’s a quick review of essential content.

A hazard communication plan doesn’t have to be long or spell out your program in detail, but it must be well thought out, clear, and comprehensive. Your written HazCom plan is the first thing a compliance officer will ask to see.

Here are some suggestions about what should be included in a HazCom plan:

• Policy statement. Explain the purpose of the plan (i.e. to reduce employee exposure to hazardous chemicals and the overall incidence of chemical-related injuries and illnesses), and express your organization’s commitment to communicating necessary information to protect employees from chemical hazards in the workplace.
• Plan administration. Describe the duties of the program administrator and others with responsibilities for different aspects of the plan. Additionally, this section should provide contact information (task with designees name and phone number) for administration of the plan.
• Plan review and update. State that the plan will be periodically reviewed and updated, and updated whenever new hazards are introduced into the workplace.

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• Plan availability. Explain how the written plan can be accessed by employees and government agencies.
• Labels. Describe the requirements for container labeling throughout the workplace, including your in-house labeling system.
• Safety data sheets. Describe procedures for ensuring that employees can obtain necessary SDSs, including your primary and backup access systems. Also explain what employees should do when an SDS is not available or cannot be accessed. Include a statement about the procedure for obtaining and filing new or revised SDSs.
• Employee training. Identify information about hazardous chemicals that will be communicated to employees in training sessions, including training content, format, schedule (initial and retraining), and training records.
• Nonroutine tasks. From time to time, employees may be required to perform nonroutine tasks that could potentially result in temporary exposure to hazardous chemicals. Include a statement in your plan that says that if it is determined that a hazardous condition exists with the nonroutine task, employees performing the task will be provided with information that includes specific chemical hazards, safety measures or protective equipment the employee should use, and steps taken to reduce the hazards, such as ventilating, providing respirators, and implementing emergency procedures.

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• Contractors. Explain procedures for communicating chemical hazards to outside contractors who come into your workplace to perform work.
• List of hazardous chemicals. Attach a list of hazardous chemicals in the workplace that includes each chemical’s product identifier (i.e., name or number used to identify the chemical), the manufacturer, and work areas in which the chemical is used.

Tomorrow, 10 tips for ensuring hazard communication compliance.