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October 15, 2013
OSHA's hazard communication standard: Common mistakes and tips for compliance

For fiscal year 2013 (which ended on September 30), hazard communication was once again OSHA’s top-cited general industry violation. So what does the hazard communication (HazCom) law require, and where do many employers fall short? Keep reading to find out.

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OSHA’s hazard communication standard (HazCom), also known as the worker’s right-to-know law, requires that employers train workers who may be exposed to hazardous chemicals in the workplace on the dangers these chemicals may pose and how to protect themselves.

So what pieces of the HazCom law tend to trip employers up the most? The most common HazCom mistake is not having a written plan. Other common errors include inadequate employee training, improper labels on chemical containers, and lack of, or lack of access to, safety data sheets (SDSs), formerly known as material safety data sheets (MSDSs).

Below, we’ll discuss each of these common HazCom mistakes, share some tips for staying in compliance, and direct you to relevant resources to help make your job easier.

Not having a written HazCom plan. During an inspection, the written plan is often the first piece of your HazCom system an inspector will ask to see. Key elements of a written HazCom plan include the following:

  • Identification of key personnel;
  • Description of the methods an 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;
  • Designation of the person(s) responsible for ensuring proper labeling and description of the labeling system;
  • Designation of the person(s) responsible for obtaining and maintaining SDSs, procedures for employee access to SDSs, and description of the SDS management system;
  • Designation of person(s) responsible for employee training, description of the training program, and procedures for training new employees and employees who become exposed to a new hazard; and
  • A list of all hazardous chemicals present in the workplace.

Need help writing a written HazCom plan? Download BLR’s prewritten Hazard Communication 2012 Plan and Hazardous Chemical List and customize them for your facility.

Inadequate employee training. Employees must be trained on hazard communication when they are initially assigned to a work area or duty in which they could be exposed to a hazardous chemical and whenever a new chemical hazard is introduced into the work area. Training must include information about the specific chemical hazards the employee could encounter and the appropriate personal protective equipment (PPE), control measures, and procedures for working safely with these chemicals.

In addition, OSHA adopted amendments to its hazard communication standard in 2012 that incorporate the United Nations’ Globally Harmonized System for the Classification and Labelling of Chemicals, or GHS. By December 1, 2013, employees must be trained to read and interpret the new GHS-compliant chemical labels and 16-section SDSs.

Get started with GHS-compliant training today. Download BLR’s Hazard Communication and GHS PowerPoint presentation, handout, quiz, and more, and use them to train your employees.

Inadequate or improper labels on chemical containers. Each container of hazardous chemicals must be labeled, tagged, or marked. The only exceptions are pipes and piping systems and portable containers for immediate use. The labels must be in English, legible, and prominently displayed on the container or readily available throughout the work area. Other languages may be present on the label in addition to (not instead of) English if necessary.

Hazardous chemical containers must include either the label shipped with the chemical container or a product identifier and combination of words, pictures, and/or symbols that provides information about the physical and health hazards of a chemical. There are several alternatives to these labeling procedures, but it’s important to remember that an SDS is not an acceptable substitute for a label.

Download BLR’s Understanding Chemical Labels Under GHS PowerPoint presentation and share the information with your employees.

Lack of, or lack of access to, SDSs. Employees must be able to immediately access an SDS for every hazardous chemical present in the workplace at all times, without a supervisor’s permission or other barrier. Employees must be trained on how and where to access SDSs, as well as how to interpret the information contained there.

If you use an electronic SDS management system, make sure it is reliable, and have a backup system in place for emergencies and other occasions where the electronic system does not function properly.

For mobile operations and multiemployer worksites, the SDS collection can be kept at the primary workplace facility (instead of having a separate copy at each individual jobsite), as long as the SDSs can be accessed immediately in case of emergency.

Need help managing your SDSs? Download BLR’s SDS File System Management Policy and SDS plan and customize them for your facility.

For more information on hazard communication, refer to BLR’s GHS and Hazard Communication resource center.

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