Hazard Communication: What Your Company Needs to Know
The OSHA hazard communication standard (HCS) was created to ensure that employers make their employees aware of the hazards to which employees may be exposed on the job. The HCS is one of the most important—and frequently violated—OSHA standards. Here is what your company needs to know about hazard communication so that it can stay in compliance with the standard and keep employees safe.
Overview of the Hazard Communication Standard
The HCS, 29 CFR 1910.1200(b), applies to almost every organization and employer covered by OSHA regulations. The hazard communication standard applies to general industry, shipyards, marine terminals, longshore operations, and construction employment. The HCS covers chemical manufacturers, importers, employers, and employees exposed to chemical hazards.
The hazard communication standard applies to any chemical in the workplace to which employees would be exposed under normal working conditions or in a foreseeable emergency. Foreseeable emergencies include control equipment failures and container ruptures, but do not include chemical releases from accidental fires.
Hazards that must be communicated include physical hazards (such as flammability) and health hazards (such as irritation, lung damage, and cancer). Most chemicals used in the workplace have some hazard potential, and are therefore covered by the hazard communication rule.
The hazard communication standard requires all employers that manufacture, import, distribute, or otherwise use hazardous substances to communicate the information about hazards to employees who work with those substances through a written hazard communication program, labels, material safety data sheets (MSDSs), and an employee information and training program.
HCS requires chemical manufacturers and importers to assess the substances they produce or import in terms of their potential health hazards, as well as establish hazard communication programs for their workers. Employers that store and use chemicals but do not produce or import them do not have to comply with the requirement to evaluate and determine the hazards of those chemicals; they will receive that information from the manufacturer or importer. Distributors of chemical products must transmit the required information about hazards to employers.
Exemptions from Hazard Communication
Hazardous wastes are exempted from the communication standard because there are special OSHA requirements for hazardous waste workers. Other exempted products include those subject to labeling by the Federal Food, Drug, and Cosmetic Act and the Consumer Product Safety Act. Specific items that are exempt from hazard communication requirements include chemicals in physical objects such as plastics, drugs in a form available for retail sale or intended for consumption by workers, and cosmetics for the personal use of employees, packaged for retail sale.
Employees who handle hazardous substances in non-routine, isolated instances are not covered for those chemicals under the hazard communication standard. For instance, an office employee who periodically changes the toner in a copying machine would not need information or training for the toner under the HCS.