What is Hazard Communication?

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Learn All About OSHA’s Hazcom Standard

There’s no way around it, employees must be made aware of the dangers associated with any potentially hazardous chemicals in their place of work. Hazard Communication, or HazCom for short, is a set of processes that employees must follow when working with chemicals. Because of the number of health and physical hazards that these workers face, special procedures need to be laid out. Here’s everything you need to know about hazard communication, regulations, and requirements. OSHA requires that any employer who oversees workers that deal with these chemicals must design and write a clearly-framed hazard communication program. As part of a company’s overall OSHA training program, it needs to include training program for all employees who might potentially be exposed to said hazardous chemicals. The Hazard Communication Standard (HCS) as defined by OSHA specifies how to communicate important information about potential hazards to your employees and what measures can be taken to get ahead of any dangerous situations. At its core, the Hazcom exists to ensure that employees are made aware of the chemicals that they may be exposed to in their workplace, and that they understand the risks associated with said materials. Hazard Communication doesn’t just benefit workers, though. It acts as a sort of roadmap for employers – designing and implementing a program from scratch is a lot of work, and the guidelines laid out in Hazcom can serve as a great starting point. The Hazard Communication Standard was last updated in 2012, when a globally-recognized system of classification was implemented, aka: Globally Harmonized System (“GHS”). This update provided consistency when it comes to classifying chemicals on safety labels, including the introduction of “pictograms,” regardless of which state or country the chemicals were originally produced and labeled in. This makes it easier for American businesses who might have storage or processing facilities abroad, and seriously reduces barriers to trade by simplifying and streamlining the way we communicate safety information. The 5 Major Components of a Hazard Communication Program Here are the key pieces of a compliant Hazcom program. Your company needs to build and manage each component on an ongoing basis. Like all OSHA compliance requirements, it’s literally a never ending process. Hazard Communication Written Program The first step in developing your Hazcom program is to develop a customized and updated written program which includes and addresses all aspects of OSHA’s Hazard Communication Standard, and then keep it on file for ongoing use. Chemical Inventory The next step in developing your Hazcom program is to inventory and document all of the chemicals in your workplace. This includes everything from your process chemicals to your cleaning chemicals. They all need to be captured on your inventory so you know the full scope of your chemical safety program. This inventory must be continually updated as you add and subtract chemicals to your workplace over time. You must then ensure that you have a matching safety data sheet for each one of these chemicals. Safety Data Sheets Safety data sheets (formerly known as material safety data sheets (MSDS) are at the core of Hazard Communication. These sheets help clearly communicate a chemical’s specific hazards and helps employers to develop site-specific protection measures that meet their individual needs. The information on these sheets must appear in the following order per GHS:

Identification
Hazard(s) identification
Composition/information on ingredients
First-aid measures
Fire-fighting measures
Accidental release measures
Handling and storage
Exposure controls/personal protection
Physical and chemical properties
Stability and reactivity
Toxicological information
Ecological information
Disposal considerations
Transport information
Regulatory information
Additional information when applicable

Employee Access To Safety Data Sheets It is also important to note that employers must give all employees direct and unblocked access to Safety Data Sheets. In the past the most common way to manage this requirement was to print all SDSs and put them in a binder on the factory floor. This method can be difficult to manage, and as a result, a more common and improved management method is to maintain electronic copies on a shared company computer drive that all employees have DIRECT access to. This means that they don’t have to ask for permission, for example. Container Labeling Aside from safety data sheets, labels are another important big part of hazard communication. The HCS requires that chemical manufacturers and distributors clearly label any hazardous materials that leave the workplace, and that employers properly label chemical containers in the workplace. Specific requirements as to the information on these labels can be found here. Failure to properly label these containers, especially “secondary” containers (containers used to hold or mix chemicals), is a very common violation. Employers must establish a standard labeling process, train employees on that process, and provide labels to ensure that all chemical containers are properly labeled. In the wake of globally standardized classification, the pictures on these labels are now called “pictograms” and communicate the most common hazards such as toxic, flammable, corrosive, etc.. The text on these labels and warnings must be printed in English and be easily legible. It is recommended that employers utilize “pictograms” as part of their labeling system to more easily communicate the hazards. Pictograms are also used in Safety Data Sheets, per the GHS update from 2012. There are nine of these visual representations of hazards outline by the HCS, but OSHA technically only oversees eight – they don’t regulate chemical environmental impact. Employee Training Employees must be made aware of all of these important aspects of the Hazcom before they are allowed to start work – especially if they will be in direct contact with these potentially hazardous chemicals as a part of their day-to-day job function. PPE or Personal Protective Equipment And the last, but definitely not least, component Hazard Communication is the proper selection and use of PPE to protect employees from chemical exposures. This includes gloves, safety glasses, respirators, and more all of which must be designed and able to protect employees from potential chemical exposures. On a final note, it’s important to know that if your company gets inspected by OSHA, one of the first things the enforcement officer will ask for and scrutinize is your company’s Hazard Communication program. They’ll want to see your written program, chemical inventory, training records & verify employee access to SDSs. And they’ll likely interview your employees to determine if they were properly trained and actually understand how to read and understand safety data sheets. Failure to manage any of these components will result in citations and major fines for each area of deficiency. That’s how important Hazard Communication is to OSHA so make sure to review and update your program as needed, and to always be prepared for the possibility of an OSHA inspection.

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By Russell Carr|2022-03-21T12:51:15-05:00April 30th, 2021|Good To Know, OSHA Health & Safety|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

What is Hazard Communication?