What's Inside an Effective Hazard Communication PlanBack to The PIG® Library
Did you know that each year, breaches of OSHA's hazard communication (hazcom) standard are among OSHA's top 10 violations? These violations include improperly labeled containers, training deficits and failure to have a written plan.
The purpose of the hazcom standard is simple: Workplace chemical hazards must be evaluated, and information about those hazards must be communicated to workers so that they are better able to protect themselves.
According to OSHA, over three million US workers have the potential to be exposed to over 650,000 hazardous chemicals annually. However, because hazards and situations vary from site to site, the standards have some flexibility. This allows employers to develop a plan suitable for their facility's needs while still meeting certain requirements.
Keep in mind that just collecting Material Safety Data Sheets (MSDS) is not enough. To be in full compliance with the hazcom standard, facilities that use hazardous chemicals must have a written plan that lists all hazards present. The plan must also outline how the program will be implemented at the facility – including gathering information on hazards, employee training, labeling containers and providing other hazard warnings. [29 CFR 1910.1200(e)]
What You Will Find on a Good Material Safety Data Sheet
Having the proper information on chemicals used and stored in the workplace is an essential first step in any safety program. Chemical manufacturers and distributors are required to provide MSDSs for hazardous chemicals they sell. They must also update MSDSs when changes are made to a product, or if they become aware of new information about a product. If changes occur, they are required to immediately notify their customers. [29 CFR 1910.1200(f)(11)]
Properly prepared MSDSs should also provide the information necessary to make informed decisions about the control and safe use of products. Essentially, they are "all-in-one" reference documents that can be used by workers, employers and health professionals.
OSHA requires that MSDSs be maintained for all hazardous chemicals used at a facility, and that they are written in English. Paper copies may be stored in Right to Know Centers throughout the facility, or electronic copies may be kept. With either storage method, employees must have immediate access to them at all times.
Using Container Labeling and other Reminders
While MSDSs are mainly reference documents, container labels provide summaries and more immediate reminders of the hazardous chemicals being used in a workplace. After all, it's quicker to read a label on a container than to have to refer to MSDS papers.
While OSHA does not dictate a format for information on container labels, it specifies that the chemical's identity, as well as appropriate hazard warnings, appear on the container [29 CFR 1910.1200(f)(5)]. Two common methods for container labeling are the NFPA or the HMIS systems, which use colors and numbers to help convey hazards.
Signs may also be used throughout the facility as another form of hazard communication to remind employees of hazards and the need for engineering controls or proper protective equipment.
Areas to Cover in Employee Training
Effective training is a requirement of the hazcom standard [29 CFR 1910.1200(h)], and it must include the following elements:
- State the requirements of the hazard communication standard
- List of operations at the facility where hazardous chemicals are present
- Ensure that employees know the location of the written plan and list of hazardous chemicals as well as the location of MSDS
- Share method that can be used to detect the presence of a hazardous chemical release
- Go over physical and health concerns of hazardous chemicals, as well as the specific procedures, practices, and personal protective equipment to prevent exposure
- Explain the details of the hazard communication plan
- Review the labeling system and the information contained in MSDS
Properly educated employees will understand the hazards present in their work areas and will know how to protect themselves from those hazards. Employees should receive training when they are initially assigned to an area and whenever a new hazard is introduced to their work area.
For anyone just starting a program or for those who want additional information on chemicals in their workplace, the OSHA Occupational Chemical Database contains information from NIOSH, EPA and DOT on a wide variety of chemicals. Reports can be generated on the physical properties chemicals, exposure guidelines, emergency response information or in an all-in-one report.