Hazard Communication: A Keystone in Industrial Hygiene

HazCom pictograms are nine symbols, standardized under the GHS, which represent and communicate specific hazards associated with a chemical. © BORIS – stock.adobe.com

By: Shannon Popa, Contributor

Chemicals are used in nearly every aspect of our lives. They are integrated into so many products and processes that it is easy to overlook the impact they have in our homes, workplaces, healthcare facilities and other places. Some common examples of where chemicals are found include cleaners, personal care products, laundry detergents, bleach, paints and coatings, pesticides, herbicides, fertilizers, adhesives, building materials, disinfectants and sterilants, and water filtering systems.

Most people would be surprised to find that chemicals are even present in food and beverages (preservatives, flavorings, sweeteners, etc.). While some chemicals are harmless, others can contain properties with varying degrees of danger to human health, safety and the environment.

In fact, OSHA estimates that over 30 million workers are regularly exposed to hazardous chemicals in more than 3.5 million workplaces. Hazard communication and the work of industrial hygienists is vital to providing workers with a safe work environment.

Understanding Hazard Communication

OSHA’s Hazard Communication standard, 29 CFR 1910.1200, sometimes abbreviated as HazCom, is also known as the “Right-to Know” standard. This is based on the principle that employees have the right to know about the hazardous chemicals they may be exposed to and how to protect themselves. The standard has requirements for chemical manufacturers and importers, distributors and employers—all of which involve sharing chemical information with downstream users.

In 2012, OSHA aligned the HazCom standard with Revision 3 of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which standardized the way Safety Data Sheets (SDSs) and labels are structured. The GHS is an effort to create a world-wide, universal chemical hazard communication and container labeling system, and it is updated every two years. It’s a voluntary set of “building blocks” which each country can adopt as it sees fit. In 2024, OSHA aligned the HazCom standard with GHS Revision 7.

Key Elements of the Hazard Communication Standard

Written program: In most cases, employers covered by the HazCom standard must develop and implement a written program that describes how they will comply with the standard. The written program must address:

• The chemical inventory,
• Labels and other forms of warning,
• Safety Data Sheets (SDSs),
• Employee information and training,
• Informing employees about the hazards of non-routine tasks,
• Informing employees about the hazards associated with chemicals in unlabeled pipes, and
• How employers will exchange information in a multi-employer workplace.

Laboratories and operations where chemicals are only handled in sealed containers, such as a warehouse, do not need to have a written program. But, if employers have these operations, they might have other responsibilities under the standard at paragraphs (b)(3) and (b)(4).

Chemical inventory: Part of the written program requirement is the chemical inventory. This is a list of all covered hazardous chemicals in the workplace. It must contain a product identifier for each chemical, which can be cross-referenced with an associated label and SDS. Although the product identifier is OSHA’s only requirement for the inventory, some employers also include where the chemicals are located; the physical state of the chemical; the quantities; and the hazard classification for each chemical. The list should be maintained at all times and reviewed for accuracy at least annually.

Hazard classification: Employers who manufacture or import chemicals must evaluate them using the criteria in Appendices A and B to 1910.1200 to determine if they’re hazardous and what hazard class and category apply. There are two main classes for hazardous chemicals:

• Health hazard – These chemicals have properties that can cause adverse health effects, either immediately or over time. Some examples are carcinogenicity, acute toxicity, skin irritation and respiratory sensitization.
• Physical hazard – These chemicals have properties that can cause physical damage to their surroundings. Some examples are flammability, explosivity and corrosivity.

Pictograms are symbols, standardized under the GHS, which represent and communicate specific hazards associated with a chemical. These nine symbols must be framed within a red diamond shape on shipped containers of hazardous chemicals; on in-house labels, a black border may be used. All employers should understand the classification of chemicals and use the information provided by the manufacturer to store and handle chemicals in a safe manner.

SDSs are the primary source of information on a hazardous chemical. Employers must ensure that an SDS is available to employees for each covered hazardous chemical in the workplace. © Pepermpron – stock.adobe.com

Safety Data Sheets (SDSs): SDSs are the primary source of information on a hazardous chemical. Employers must ensure that an SDS is available to employees for each covered hazardous chemical in the workplace.

SDSs contain 16 standardized sections:

1. Identification–Product name, manufacturer information
2. Hazard(s) identification–All hazards regarding the chemical and required label information
3. Composition/ingredients–Chemical ingredients; trade secret claims (if applicable)
4. First aid measures–First aid to be administered when exposed to the chemical
5. Fire-fighting measures–Techniques and equipment recommended when fighting a fire involving the chemical
6. Accidental release measures–Steps to take in the event of a spill or release involving the chemical. Includes emergency equipment and PPE to use during cleanup.
7. Handling and storage–Precautions and safe handling instructions
8. Exposure controls/personal protection–OSHA’s Permissible Exposure Limits (PELs), what PPE to wear during handling
9. Physical and chemical properties–Chemical characteristics
10. Stability and reactivity–Chemical stability and possibility of hazardous reactions
11. Toxicological information–Routes of exposure; related symptoms; acute and chronic effects
12. Ecological information–Environmental impact
13. Disposal considerations–Safe handling of wastes; proper disposal methods
14. Transport information–Information required when shipping hazardous materials
15. Regulatory information–Safety, health and environmental regulations specific for the product
16. Other–Items relevant to working safely with the material; may include the date the SDS was prepared or last revised

Since other agencies regulate the information in Sections 12 through 15, OSHA does not enforce it.

HazCom-compliant labels provide an at-a-glance summary of critical hazard information, making it easy for employees to quickly assess hazards associated with chemicals they are working around. © Sign System – stock.adobe.com

Container labeling: All containers of hazardous chemicals must be labeled. Labels must be affixed to, printed on or attached to the immediate container of the chemical. Labels on shipped containers must contain six key elements:

1. Signal word–A single word that indicates the severity of a hazard (either danger or warning)
   1. Danger–Severe
   2. Warning–Less severe
2. Pictogram(s)–A visual warning that identifies the hazards of a specific chemical
3. Manufacturer information–Company name, address & telephone number
4. Precautionary statement(s)/first aid–Describes the recommended measures to be taken in the event of exposure to or release of the chemical
5. Hazard statement(s)–Describes the chemical’s hazards and their severity
6. Product identifier–Name of chemical (technical and/or production name)

Workplace or in-house labels may contain the same information as on shipped containers of hazardous chemicals, or the product identifier and words, pictures, symbol or a combination of these, which provide at least general information regarding the hazards of the chemical.

HazCom-compliant labels provide an at-a-glance summary of critical hazard information, making it easy for employees to quickly assess hazards associated with chemicals they are working around.

Employee training: Effective employee training is a key part of a good HazCom program. Without it, the program merely exists on paper—not in practice. Providing SDSs to employees and ensuring containers are labeled is not efficacious if employees do not understand what they are looking at.

Training must be conducted in a manner and language comprehensible to all employees and must cover:

• The requirements of the HazCom standard;
• Any operations in the work area where hazardous chemicals are present;
• The location, availability and details of the employer’s written Hazard Communication program, including the chemical inventory;
• An explanation of the labels received on shipped containers and the workplace labeling system used by the employer;
• How to read and understand SDSs and labels, including pictograms, signal words and precautionary statements;
• How to access SDSs;
• The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of chemicals in the work area;
• Methods and observations that can be used to detect the presence or release of a hazardous chemical (e.g., odor, visible leaks);
• How to protect themselves (work practices, PPE, etc.); and
• Emergency procedures, including spill response and first aid.

HazCom’s Impact on Industrial Hygiene

HazCom is deeply entwined with industrial hygiene. Industrial hygienists rely on SDSs and labels to determine the hazards of chemicals employees may be exposed to, so they can protect workers’ health and physical safety. This may involve sampling and testing for air contaminants in the work area. The results can be compared to OSHA’s PELs for specific chemicals or to guidelines, such as the ACGIH’s Threshold Limit Value® (TLV) for chemicals OSHA doesn’t have a PEL for. This helps industrial hygienists understand the true potential for harm, so they can recommend the best control measures to reduce or mitigate the hazard.

Hazard communication is the “Right to Know” standard, because employees have the right to know what chemicals they may be exposed to. The work of industrial hygienists ensures not just the availability of information, but the comprehension and actionable application—giving employees not only the “Right to Know” but the “Right to Understand.”

HazCom is vital to employee safety, ensuring employer commitment to transparency, training and protection. It is a keystone in good industrial hygiene, pointing industrial hygienists in the right direction so they know what testing and sampling should be completed, enabling them to compare the results to OSHA’s PELs and recommend effective control measures.

About the Author

Shannon Popa, CSP, is a Senior Safety Consultant with J. J. Keller & Associates, Inc. She is passionate about assisting employers in providing safe, healthful working conditions for employees. With 19 years of experience in the safety and health field, Popa is skilled in safety programs, policy, training development and delivery, assessments, incident investigations, ergonomics and other safety initiatives, providing support and leadership to help multiple facilities reach and exceed company safety goals.