Hazard communication

Many of us work with chemicals on a daily basis.  These chemicals are used for a variety of purposes including manufacturing products, mixing and cleaning.  Regardless of how the chemical is used it is important to understand the hazards associated with them.  The Occupational Safety and Health Administration’s (OSHA’s) Hazard Communication Standard (HCS) (29 CFR 1910.1200) ensures that employees understand the dangers posed by chemicals they work with and the steps necessary to protect themselves.  In fact, written citations of OSHA’s Hazard Communication Standard is on their top 10 violations list year after year.  To protect your organization, there are steps you can follow to keep a healthy and safe workplace and minimize citations. 

One of the first steps is to obtain a copy of the Hazard Communication Standard from the OSHA website to use as a reference.  Before starting your program review the program and get an understanding of what is necessary.  At times, the regulations may be hard to comprehend, but there are many resources on the internet that will help.  Once you’ve obtained a good understanding of the standard, break it down into 4 categories:

1. Written program
2. Chemical list and safety data sheets (SDS’s)
3. Container labelling
4. Training

Let’s take a closer look at each of these categories.

Written hazard communication program

OSHA says that employers are required to have a written plan detailing how they'll implement an effective hazard communication program in the workplace.  The written program should include such items as, who is responsible for implementing the program, listing of chemicals in the workplace, how Safety Data Sheets (SDS’s) will be managed, the process employees will use to properly label containers, conducting training and handling incidents involving hazardous chemicals.

Chemical list and safety data sheets (SDS)

Employers are required to obtain a list of all hazardous chemicals used within their organization.  Depending upon your company’s operations, this could be a challenge.  Consider breaking down the facility into departments and work with each department, separately.   You may want to work with those employees who have a knowledge of operations like line workers, supervisors, managers or maintenance.  When performing a chemical list evaluation, keep an open mind and inspect every area of the department.  This would include workstations, cabinets and storage rooms.  Once you’ve completed your list of chemicals you will need to collect the SDS’s for each one.  These can be obtained by contacting the manufacturer or looking on the manufacturer’s website.  Once you have obtained all the SDS’s you will need to store them where employees have access to them.  This can be done electronically or at a physical location in the building.

Labels and signs

Chemicals that enter the facility from manufacturers or distributors come labelled per OSHA Guidelines.  However, at times, employees may place those chemicals in a secondary container.  If this is the case, you must develop a way for employees to properly label those containers.  Containers must have clear, visible labels that include information about the product name, hazards, precautionary measures, and handling instructions.  The purpose of labeling allows employees to know the contents of the container and how to protect themselves.  There are several different types of labels you can obtain off the internet.

Training

Like any safety program, the final step is training.  Employers are responsible for providing comprehensive training to employees on the hazards of the chemicals they work with, as well as safe handling, storage, and emergency procedures. This training should be provided during initial job orientation and whenever new hazards are introduced.  Best management practices for the Hazard Communication Program is to train employees on an annual basis so they remain aware of the chemical hazards and the steps to protect themselves.

Creating and implementing a Hazard Communication Program for your organization may appear to be challenging at first.  So, it is important you take the time to understand the requirements and how your facility is affected.  Break down each step mentioned earlier and follow an order that will make it easier for you to implement.  Just like any other safety program, periodically review your Hazard Communication Program to include chemical updates, process changes or employee responsibilities.  By following these guidelines and maintaining a strong hazard communication program, your workplace can minimize the risks associated with chemical hazards and better protect the health and safety of your employees.

If you have questions or need further assistance in your Hazard Communication Program, please reach out to Andy Sawan, Risk Services Specialist, with Sedgwick at andrew.sawan@sedgwick.com or by phone at 330.819.4728.