Hazard Communication, General Industry • Regulation 29 CFR 1910.1200

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Workers can potentially be exposed to chemical hazards in many industries, including:

• Chemical manufacturing, metal fabrication, and electronics, where workers may handle solvents, heavy metals, and other hazardous substances.
• Warehousing and transportation: workers handling hazardous materials during shipping, receiving, and storage may be exposed to chemicals such as fuels, lubricants and other substances.
• Construction: building and renovation activities may involve asbestos, lead, paints, adhesives and solvents
• Agriculture: pesticides, herbicides, fertilizers, and other chemicals that can pose health risks if not managed properly.
• Healthcare: in healthcare settings, workers may encounter hazardous chemicals in pharmaceuticals, cleaning agents, and sterilization processes.
• Cleaning Services: employees in janitorial and cleaning services are frequently exposed to various cleaning agents, disinfectants and solvents.
• Mining and Oil Extraction: hazardous chemicals including heavy metals and petroleum-based products are often used during drilling, extraction and processing.

OSHA’s Hazard Communication Standard (HCS), 1910.1200, plays a crucial role in ensuring the safety and health of workers who may be exposed to hazardous chemicals in the workplace. The standard mandates that employers inform and educate their employees about the dangers associated with chemicals they may encounter on the job.

ABOUT THE STANDARD

The Hazard Communication Standard was first promulgated in 1983 and has undergone revisions to align with global standards, particularly the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The transition to GHS has streamlined communication about hazards and improved the consistency of hazard information across different countries. The HCS aims to ensure that both employees and employers understand the risks associated with hazardous chemicals, thereby reducing workplace incidents and ensuring safer working conditions.

Employers must implement several key components according to the Hazard Communication Standard (HCS) to ensure compliance and protect their employees from hazardous chemicals. These components include:

1. Chemical Inventory: Employers must maintain a comprehensive list of all hazardous chemicals present in the workplace.
2. Labeling: Each container of hazardous chemicals must have proper labels that include:
   • Product identifier
   • Signal words (e.g., “Danger” or “Warning”)
   • Hazard statements
   • Precautionary statements
   • Pictograms that visually represent the hazards
3. Safety Data Sheets (SDS): Employers must ensure that Safety Data Sheets are available for each hazardous chemical. These sheets provide detailed information about the chemical, including hazards, handling instructions and emergency measures.
4. Employee Training and Information: Employers are required to train employees on:
   • The hazards of the chemicals they may encounter
   • How to read and understand labels and SDS
   • Safe handling, storage and disposal practices
   • Emergency procedures for chemical exposure or spills
5. Written Hazard Communication Program: Employers must develop and implement a written program that outlines how they will comply with the HCS requirements. This program should cover the chemical inventory, labeling procedures, access to SDS and employee training protocols.

COMPLIANCE CHALLENGES

While the Hazard Communication Standard has greatly improved workplace safety, compliance can present challenges for employers. Some common issues include:

Keeping Updated Inventory: Maintaining an accurate and up-to-date chemical inventory can be cumbersome, especially in industries with fluctuating chemical usage. Employers must regularly review and update their inventories to reflect current conditions.

Training and Resources: Effective training programs require time, resources, and expertise. Employers may struggle to provide comprehensive training that meets the diverse needs of their workforce, particularly in larger organizations.

Understanding GHS: The transition to the Globally Harmonized System can be complex, requiring employers to understand new labeling and SDS formats. Companies may need to invest in training and resources to ensure compliance with both OSHA regulations and international standards.

OSHA’s Hazard Communication Standard 1910.1200 is a vital component of workplace safety, providing a framework for the effective communication of chemical hazards. By mandating proper labeling, the provision of Safety Data Sheets, and comprehensive employee training, the standard empowers workers to understand and manage the risks associated with hazardous chemicals. While challenges in compliance exist, the benefits of improved safety, increased awareness, and a culture of prevention far outweigh the difficulties. As industries continue to evolve and new chemicals are introduced, the importance of adhering to the HCS will remain critical in safeguarding the health and well-being of workers across the nation. WMHS

RESOURCES

OSHA Fact Sheet: Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals: https://tinyurl.com/2z68ppph

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals: https://tinyurl.com/52mpm559