Hazard communication

No matter the industry you work in, there is a good chance your organization and employees will come across hazardous chemicals at some point in their career. OSHA provides specific guidelines on how to protect you and your employees from chemical hazards.

Hazard communication applies to more than just chemical manufacturer and distributor. Hazard communications applies to most business. Be sure to communicate appropriately about chemical hazards to your employees to prevent health issues for your employees and possibility citations from OSHA. The Hazard Communication Standard (HCS) requires employers that have hazardous chemicals in their workplaces to implement a hazard communication program (29 CFR 1910.1200). The HCS covers all employers and employees within OSHA’s jurisdiction exposed to hazardous chemicals.

Important standard changes occured eight years ago to give us the Hazard Communication Standard we have today. Back in 2012, OHSA’s main goal was to create chemical safety in the workplace and allow workers to easily understand information and hazards associated with the chemicals they worked with. This process is commonly referred to as Globally Harmonized System of Classification and Labeling of Chemicals or GHS.

Written Hazard Communication Plan
According to the number one cited OSHA standard related to HAZCOM, 1910.1200(e)(1), employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at a minimum describes labels and other forms of warning, safety data sheets, and employee information and training.

As you can imagine, this written plan needs to be comprehensive enough to cover all the details mentioned within the standard, and should be communicated to and easily understood by all employees. Luckily, OSHA has included a sample program for us to view online           - https://www.osha.gov/dsg/hazcom/docs/State_of_Wisconsin_revised_Hazcom_Plan_2012.pdf

An often-overlooked requirement of the written program is maintaining a list of the hazardous chemicals known to be present in the workplace. Not maintain a list of chemicals is a mistake for two reasons: (1) you are not fully following the requirement and (2) once this list is created, the tracking of SDS sheets and creating labels will become significantly easier.

Labels
The Globally Harmonized System also included updating the requirements on labeling hazardous chemicals.  The OSHA standard states that all labels are required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification and shown in the sample from OSHA’s Quick Card on labeling and posted below.

(Sample from OSHA Quick Card -https://www.osha.gov/Publications/OSHA3492QuickCardLabel.pdf )

A common theme or answer I often receive when inspecting locations with improper labeling is “my employees work with these chemicals every day, they know what is in the bottles.” Although this may be true even 99 out of 100 times, one mistake could be deadly. Without knowing the proper chemical information, it is nearly impossible to know what PPE you should be wearing, proper firefighting measures, or what steps to take in case of accidental ingestion. Proper container labeling is vital to keeping yourself and employees safe.

Safety Data Sheets  
SDS or Safety Data Sheets (formerly called MSDS or Material Safety Data Sheets) go hand in hand with container labeling. Once you know what the chemical is (labeling), you can then search your database for the correct SDS sheet to learn how to safely work with the chemical or in severe cases, how to next handle an immediate emergency. Environmental Health and Safety Online defines an SDS as “a detailed informational document prepared by the manufacturer or importer of a hazardous chemical. It describes the physical and chemical properties of the product. SDS's contain useful information such as flash point, toxicity, procedures for spills and leaks, and storage guidelines.”

On an OHSA Brief following the new standards, they state SDS’s are required to be presented in a consistent user-friendly, 16-section format. They go on to explain that the SDS includes information such as the properties of each chemical; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical.

• Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., fire fighting). This information should be helpful to those that need to get the information quickly.
• Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision.
• The entire OSHA Brief can be referenced at the following link: https://www.osha.gov/Publications/OSHA3514.pdf  

Training
As in anything we do in life or the workplace, we cannot simply put something in writing and hope for the best. After our Hazard Communication Plan is in place, we must ensure proper communication and training throughout our company. Training should include understanding the chemicals they work with, importance of proper labels, how to find and read safety data sheets, location of the Hazard Communication Plan, and of course, any other required information found in the Hazard Communication Standard.

As found in the standard, employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. The purpose of this requirement is to have all the information before you start working with the chemicals. Waiting even a day could have serious consequences.

Your program will only be successful if all employees fully understand the information you provide and you are enforcing the program.

Citations
As you will find on OSHA’s webpage, hazard communication is consistently on OSHA’s top 10 violations list. Below were the most common violations in 2019 for Hazard Communication per the National Safety Council:

• 1910.1200(e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program. – 1,521 Violations
• 1910.1200(h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. – 1,087 Violations
• 1910.1200(g)(8) The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). – 468 Violations
• 1910.1200(f)(6) Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked – 352 Violations

For specific questions or assistance with hazard communication requirements, please contact your local Marsh & McLennan Agency representative.

Resources for OSHA hazard communication can be found at the links below:

• Steps to and Effective Hazard Communication Program - https://www.osha.gov/Publications/OSHA3696.pdf
• OSHA Hazard Communication Etool - https://www.osha.gov/dsg/hazcom/index.html
• Several OSHA Quickcards that can be used as handouts or trainings - https://www.osha.gov/pls/publications/publication.athruz?pType=Types&pID=6
• Several Fact Sheets on Hazard Communication can be found here - https://www.osha.gov/pls/publications/publication.AthruZ?pType=Types&pID=2