Highlights and hot topics in hazard communication

In 20141 OSHA issued more than 6,000 citations for hazard communication (HazCom) violations. The right-to-know standard and understand the chemicals with which workers work. The standard is known for its complexity and multiple moving parts, is historically among the most frequently cited.

We’ve rolled must-have information and tips into this Compliance Report, plus a review of the standard and the training and written program requirements. Also, gain insight into the successful HazCom program at a leading corporation where compliance is just the beginning.

OSHA’s hazard communication standard (at 29 CFR 1910.1200) was established to ensure that employers and employees know the identities and hazards of the hundreds of thousands of chemicals present in American workplaces.

HazCom is based on two big ideas. The first is that employees have the right to know about any physical and/or health hazards associated with hazardous materials in their work areas. The second is that they must be aware of and taught to use the protective measures available to them.

One of the most widely applied standards, HazCom covers general industry, shipyards, marine terminals, longshore operations, and construction sites. It also applies to chemical manufacturers, importers, distributors, employers, and employees exposed to chemical hazards.

The standard exempts employees who handle hazardous materials in nonroutine, isolated instances not covered for those chemicals. An example is a worker who occasionally changes the toner in a copy machine. He or she would not need HazCom information or training on the toner. Also exempted are hazardous wastes, which are addressed under the OSHA HAZWOPER standard.

The standard is structured around six core elements:

1. The classification of hazard
2. The written hazard communication program
3. The safety data sheet (SDS)
4. Chemical labeling
5. Employee information and training
6. Protections for chemical trade secrets.

And according to OSHA, an effective program needs to have:

• Management and employee involvement in the program
• Rigorous worksite analysis to identify hazards and potential hazards
• Stringent prevention and control measures
• Thorough training

Under HazCom employers must provide employees with chemical information and training at the time of assignment and when a new hazard is introduced into the work area. OSHA stresses that handing employees a binder of SDSs is not adequate training.

A frequent misconception is that HazCom applies only to large businesses or those in the chemical industry. In fact, nearly all workplaces have some hazardous chemicals on-site. That means nearly all employees must be trained and must meet the other requirements of the standard.

Though the methods can vary (classroom, interactive video, online, etc.), the content of your training must include the following:

• The methods and observations used to detect the presence or release of a hazardous chemical in the work area, such as monitoring conducted by the employer, continuous monitoring devices, visual appearance, or odor of hazardous chemicals when being released;
• The physical, health, simple asphyxiation, combustible dust, pyrophoric gas, and hazards not otherwise classified of the chemicals in the work area;
• The protective measures for workers;
• How workers can detect the presence of a hazardous chemical;
• The specific protective procedures you are providing, such as engineering controls, work practices, and personal protective equipment; and
• An explanation of the labels received on shipped containers and the workplace labeling system used, and an explanation of the SDS, including the standard chronological order of information on the SDS and how workers can use the appropriate hazard information.

OSHA requires that training be provided for categories of hazards (such as carcinogens or toxic agents) rather than for specific chemicals. That means you need to train for hazards, not for every new compound that enters your site. But if a new chemical does not fit into an existing class or category, specific training is required.

UPS delivers chemical safety

Employees of the global package giant UPS encounter hazardous chemicals in two ways. Those who maintain the shipper’s fleet of vehicles and airplanes work regularly with a variety of potentially hazardous fuels, additives, and oils. Those who process and deliver shipments face potential risk from the packages themselves.

Corporate Health and Safety Compliance Manager Dave Keeling explains that UPS is required to comply with both OSHA and U.S. Department of Transportation regulations regarding chemical hazard and training. Operations employees, primarily package handlers, receive annual training that features video and classroom components.

The hour-long session includes hazard recognition and a detailed description of what hazard labels look like and the meaning of the words and warnings on them. “We talk about making sure packages are in good repair and not accepting package that are not,” says Keeling.

The training also covers what to do in the unlikely event of a chemical release. The company reduces the chance of problems by being scrupulous about what it will ship and will not ship, such as pesticides and poisons.

Specialized training is delivered to specific work groups, including aircraft and fleet maintenance, depending on the hazards they face. Keeling says that over time (he has been with UPS for 26 years) the company has improved its training by delivering a more consistent message across its many locations.

UPS: Ready to respond

At larger sites, a dedicated response unit is ready to spring into action in case of a spill or release. The units, typically one or two people, receive specialized training in how to read and recognize hazard assessments, and how to properly dispose of hazardous substances.

A corporate hazardous chemicals support group helps ensure that customers follow federal and company rules when they ship packages via UPS. Keeling says large businesses such as chemical manufacturers and automakers tend to be aware and compliant. However, smaller customers benefit from the seminars on shipping and labeling UPS provides.

Employee access to information assured

Since 2003, UPS has used an electronic safety data sheets (SDS) management system in place at all locations. “For us it’s about access,” Keeling explains. “In the old way, with a hard-copy book on file, you’d always have the chance that the book would be locked up somewhere, missing, or unable to be found in an emergency, but the computer never disappears.”

The system is based on a UPS chemical library that’s vigilantly maintained by an SDS vendor. Within the library are mini-libraries specific to each facility. Some large sites have several mini-libraries that address the chemicals in various operations.

One individual at each site serves as facility controller. He or she is responsible for a monthly audit to keep the chemical list up to date. In order to be sure that UPS is getting the best possible service from its SDS vendor, a request for proposal is circulated every few years.

A global procurement group obtains required chemical information as part of the purchasing process. If an unusual or unknown product has been purchased, a member of the procurement group will discuss it with the facility’s hazardous chemicals coordinator.

Compliance Assistance

The idea behind the HazCom standard is straightforward. It is to ensure that employers and employees can identify and understand hazardous chemical substances in their workplace, the physical and health hazards associated with them, and how to take protective action.

However, creating and maintaining a program that encompasses data sheets, labeling, a written plan, hazard identification, training, and protections for chemical trade secrets is not so simple.