Your Hazard Communication Program Must Be in Writing

Ray Chishti, Editor, J. J. Keller & Associates

Employers that have hazardous chemicals in their workplaces are required by OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a hazard communication program. This program must be written. Unfortunately, failure to have a written plan continues to be the number-one violation in general industry. This article provides insights on understanding and addressing the requirements.

Why must it be written?

Paragraph (e) of the standard requires employers to prepare and implement a written hazard communication program. The reason for this is to:

• Address how hazard communication will be addressed in your facility,
• Help ensure that compliance with the standard is done in a systematic way, and
• Coordinate all elements of the program as necessary.

A written HazCom program helps employers to inform and train their employees properly and to design and put in place protection measures. Hazardous chemicals can be deadly; therefore, OSHA wants to ensure that a company and its employees are managing them safely at all times. Having a program in writing helps ensure that this objective is met by organizing and defining all of the required elements.

What are the required elements?

OSHA requires that the written program must indicate how the following will be addressed:

• Labels and other forms of warning,
• Safety data sheets (SDSs),
• Employee information and training, and
• Chemical inventory.

Labels and Warnings

Labels serve to warn employees about the hazardous nature of the chemical. Each container must be labeled, tagged, or marked with the following:

• Product identifier,
• Pictogram,
• Signal words,
• Hazard statement,
• Precautionary statement, and
• Supplier information.

The written program needs to address how and when hazardous chemicals will be labeled in your workplace.

SDSs

Your written HazCom program must include information on how you obtain, update and make SDSs available to employees. You must have a Global Harmonization System (GHS) style, 16-section SDS for each chemical, which is considered to be a health or physical hazard, except for those product specifically exempted under 1910.1200(b)(6).

Training

The training requirements of the standard are not satisfied solely by giving employees SDSs to read. Therefore, the written program needs to specifically address how these requirements will be met. This includes:

• Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area,
• The physical and health hazards of the chemicals in the work area,
• The measures employees can take to protect themselves from these hazards, and
• The details of your HazCom program.

Chemical Inventory

The written program also requires employers to maintain a list of the hazardous chemicals known to be present in the workplace. Using the product identifier (e.g., product name, common name or chemical name) to prepare the list will make it easier to track the status of SDSs and labels of a particular hazardous chemical. Remember, the product identifier must be the same name that appears on the label and SDS of the hazardous chemical.

The list can be compiled in whatever way you find most useful and applicable to your workplace. A list of all hazardous chemicals in an entire workplace may be most suitable for very small facilities, where there are few work areas and all workers are potentially exposed to essentially the same products. For larger workplaces, it may be more convenient to compile lists of hazardous chemicals by work area and have them assembled together as the overall list for the workplace.

You should already have a written HazCom program for your workplace. Review your written program to ensure that it is consistent with the standard’s requirements. It may need to be updated; for example, you may have to add or delete chemicals from the list in the program, etc.

Remember, if OSHA inspects your workplace, the inspector will ask to see your written plan if you are required to comply with the HCS.

About the Author:

Ray Chishti is an editor at J. J. Keller & Associates, a nationally recognized compliance resource company that offers products and services to address the range of responsibilities held by business professionals. Chishti specializes in workplace safety topics such as employee training, fall protection, personal protective equipment, and fire protection. He is the writer and editor of J. J. Keller’s Safety Training Talks and OSHA Compliance for Transportation manuals, and is a speaker at webcasts and other educational events. For more information, visit www.jjkeller.com/osha and www.jjkellerlibrary.com.