OSHA estimates that more than 32 million workers are exposed to 650,000 hazardous chemical products in more than 3 million American workplaces. If your workplace is one of those 3 million, hazard communication is a critical issue for you and your workers.
OSHA’s Hazard Communication Standard (HCS) was developed to ensure that workers and employers are informed about hazardous chemicals in the workplace, that they understand associated health and safety hazards, and that they take appropriate protective measures.
Three-Pronged Approach
HCS incorporates a 3-pronged approach:
Labels on containers- Material safety data sheets (MSDSs) developed by chemical manufacturers and importers, and made available to employees on all shifts
- Employee training in chemical hazards and precautions
OSHA stresses that these three essential elements of hazard communication are interdependent. None can stand alone as a foolproof mechanism to communicate chemical hazard information. You must have the interplay of all three.
The label, of course, is the most immediate source of information. Although the hazard statement on the label is brief, you have to take into account that it’s only intended to be a snapshot to remind workers that the materials are hazardous and that more detailed information is available in the MSDS and through the training they receive.
HazCom training is essential to ensure that workers understand:
The information provided- Where they can get more information
- How they can use the information to protect themselves
In fact, under HCS, workers have not just a need but a right to know about chemical hazards in the workplace. Failure to provide adequate training is therefore a serious violation of the standard.
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Training Requirements
At a minimum, the following information must be covered in hazard communication training:
- HCS and its requirements
- Specifics of your hazard communication program
- Workplace operations and processes that include hazardous chemicals
- Location of your written HazCom program, the list of hazardous chemicals on site, and MSDSs
- How to understand and use labels and MSDSs
- Methods for detecting the presence or release of hazardous chemicals in the work area
- Physical and health hazards of chemicals
- Safe work practices, PPE, and emergency procedures
HazCom training must take place when employees are first assigned to jobs that expose them to chemical hazards, and retraining is required any time a new chemical hazard is introduced.
Other Key Aspects of HCS
- Is generic and performance-oriented—all hazardous chemicals are covered.
- Is criteria-based, not limiting coverage to a list that can become outdated.
- Incorporates a downstream flow of information from producers to users.
- Generally protects trade secrets but requires disclosure when necessary to protect employee health and safety.
- Has an impact on interstate commerce and international trade.
- Interfaces with other federal and global requirements for classification and labeling. In 2003, the United Nations adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS includes criteria for the classification of health, physical, and environmental hazards, as well as specifying what information should be included worldwide on labels of hazardous chemicals as well as in MSDSs.
- Is designed in part on communication theory in addition to technical data, and incorporates the concept of modifying behavior through training and awareness.
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HCS Boosts Safety
Since the HCS was adopted, the availability of chemical information in workplaces has increased dramatically, and the provision of labels and MSDSs with products has become a standard business practice.
OSHA surveys have shown that employers rely on MSDSs to select less hazardous substitutes as well as to help them identify appropriate protective measures.
Nevertheless, year after year, HCS remains one of the most frequently violated OSHA standards and continues to be a focus of OSHA enforcement efforts, with millions of dollars in penalties assessed annually.
Tomorrow, we’ll focus on hazard communication programs so that you can assess yours in light of compliance requirements.
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