3 Things EHS Managers Should Include in Their Hazard Communication Program

For the past four years, hazard communication has ranked in the top five for OSHA violations across every industry.

In other words, organizations need to prioritize effective hazard communication programs. But there are many moving parts to a comprehensive program, and implementing one requires a commitment from everyone on your site.

Here are three elements EHS leaders can include in hazard communication programs to protect employees and the organization.

1. Written Communication Plans

A written communication plan should convey necessary safety information, like hazards of non-routine tasks and container-labeling standards for anyone who sets foot on your site.

Here are four ways to make sure your communication plan is effective.

1. Avoid boilerplate language. Cover every element of your program in your written plan, from itemizing the various chemicals to outlining your site’s specific training requirements.
2. Make the plan accessible to everyone. Place your written plan somewhere every person on your site can access. That place might be an unlocked file cabinet in your employee lounge. But don’t discount the benefit of also digitizing your communication plan. By doing this, employees can access the plan in a matter of seconds on their smart devices.
3. Account for contractors. Before bringing a contractor to your workplace, create a plan that informs employees what chemicals they use. Make sure to share this communication plan with contractors on their first day.
4. Regularly update the written plan. Make changes to your plan as soon as they happen on your site (e.g., if you start to use a new chemical or if you add lessons to your training program).

If you find that you aren’t introducing new chemicals or other changes to your site, it’s still wise to assess your communication plan on an annual basis. At a minimum, this internal audit can shed light on new ways to streamline certain processes at your company.

2. Safety Data Sheets for Every Chemical On Site

Safety data sheets (SDS) communicate the hazards or potential hazards of each chemical product on your site.

Maintaining your SDS database requires you to pay careful attention to these chemicals. When managers overlook details, mistakes happen. Here are three ways to avoid them.

1. Update the SDS database. Prevent this by changing your SDS database each time you introduce or remove a chemical from your site. This includes when you hire new contractors who may bring additional chemicals with them.
2. Store SDS documents in an accessible location. Can every employee access every SDS within five minutes? If not, you likely need to put them in a more accessible place. To accomplish this, you might place each SDS in a binder that you keep near your work area. But you can also store them online. The goal here is access. Using a digital SDS database ensures your team can quickly search for chemicals when needed.
3. Adhere to current formatting standards. In 2012, OSHA adjusted its safety sheet standards, moving from material safety data sheet (MSDS) formatting to the current SDS formatting. When obtaining a chemical’s SDS from a manufacturer, make sure it follows OSHA’s 16-section SDS guidelines and that your employees are familiar with this format. This standardization ensures every person who might come into contact with dangerous materials can research proper conduct beforehand.

Your SDS database is the go-to location for anyone who works at your company to quickly understand the hazards and proper procedures for handling chemicals. Updating and making your SDS documents easy to locate are crucial steps for protecting your employees and promoting safety at your company.

3. Comprehensive Hazard Communication Training

OSHA mandates that you provide hazard communication training. But this training isn’t just a box for your employees to tick. Your comprehensive training program is foundational to a culture of safety, and it confirms that each employee recognizes and can handle the chemicals on your site.

To optimize learning outcomes, create or look for training that…

• Integrates repetition.
• Uses real-life examples.
• Offers skill-based assessments and proof of completion.
• Applies to your industry.
• Covers the Globally Harmonized System of Classification and Labeling of Chemicals (GCHS).

In addition to training new employees on their first day, make sure to offer regular company-wide training, both throughout the year and whenever you introduce a new chemical to the site. If you hire a contractor, confirm they’ve completed all necessary training as well.

As you assess your training requirements, evaluate how different training programs stack up and meet your organization’s specific needs.

For instance, digital training technology might be right for you if you want employees to complete their training independently—and this format can even boost engagement.

Workplace Safety Is a Continual Process

Just like your written plan, a hazard communication program is never truly finished. There is always something to rework, from your SDS documents to your training. But once you’ve laid the groundwork of an effective program, updating it becomes easier.

Your hazard communication program is an investment. Maintaining it ensures your team is safe and that you’re able to continue generating revenue.

Hunter Taylor is a Team Supervisor for KPA, an EHS and workforce compliance software and services provider for midsize businesses. KPA solutions help clients identify, remedy, and prevent workplace safety and compliance problems across their entire enterprise.