The Written HazCom Program Under OSHA's Standard
OSHA's hazard communication standard, 29 CFR 1910.1200(b), or HazCom, is designed to prevent injury and illness resulting from employee exposure to hazardous chemicals in the workplace. Under HazCom, employers are required to alert their employees to the hazards to which employees may be exposed. Employers must have in place a written HazCom program that addresses how they will communicate hazards to their employees. Employers must use labels and material safety data sheets (MSDSs), and implement a HazCom training program.
What Goes into the HazCom Program?
The written hazard communication program is the blueprint for the HazCom standards, and it is the first thing an OSHA compliance officer or inspector will ask to see. The written HazCom program does not have to be long or go into excruciating detail, but it must be well thought out, clear, and comprehensive—and should at least outline all the parts of the HazCom program the company is implementing. It must include the following information:
- Identity of all participating personnel.
- Description of the methods the employer will use to inform employees of the hazards of non-routine tasks, and hazards associated with chemicals contained in unlabeled pipes in work areas.
- Criteria for labels and other forms of warning. This section includes a description of the labeling system the company is using, written alternatives to labeling of on-site containers, and procedures for reviewing and updating label information. It also includes designations of the persons responsible for ensuring the labeling of in-plant containers and for ensuring labeling on shipped containers.
- Criteria for MSDSs. This includes designation of the persons responsible for obtaining and maintaining the MSDSs, how the data sheets are to be maintained, procedures for retrieving MSDSs electronically, and the ways employees will obtain access to the MSDSs. This section must also include procedures to follow when MSDSs are not received at the time of the first shipment. Chemical manufacturers or importers must also document procedures for updating MSDSs when new and significant health information is found.
- Criteria for employee training. This section includes designation of persons responsible for conducting HazCom training, format of the program to be used, and elements of the program that meet the duties outlined in the HazCom regulation. It must also include procedures for training new employees when they are initially assigned to the job; training employees when a new hazard is introduced into the workplace; and training employees regarding new hazards to which they may be exposed when working on or near another employer's worksite.
HazCom Program Must Be Accessible
A company's written HazCom program must be made readily available to all employees. Further, it should be easily accessible to employees' designated representatives, the Assistant Secretary of Labor for Occupational Safety and Health, and the Director of the National Institute for Occupational Safety and Health (NIOSH).