Hazard Communication Program
Hazardous chemicals are present in nearly every organization—from solvents produced at large chemical companies to the desk cleaner used in an office building.
OSHA regulations state that all employees have the right to know and understand about the hazards of the chemicals to which they are exposed at work, what measures they can use to protect themselves from those exposures and how they should react if an exposure incident occurs.
In order to achieve these goals, you should develop a hazard communication program.
Safety Data Sheet Requirements
Safety data sheets (SDS) are the primary tool chemical manufacturers use to describe the hazards of the chemical to the end user. The SDS must be accessible to employees at all times and should not be kept in locked offices or other restricted areas of the facility.
Make sure they can be quickly retrieved in the event of an emergency. Placing the SDS in a bright yellow binder on the wall or on a company's intranet site are ways to enable immediate access.
The SDS contain information employees need to work safely with chemicals. The hazard classification, routes of entry, precautions for safe handling and first aid measures are examples of the types of information provided in each SDS.
It is important that all chemicals used in the building—even those used by custodians and office employees—are included in the SDS list. You should annually review your SDS binders to make sure that new chemicals are added, obsolete chemicals are removed and the SDS reflect current chemical usage.
Hazard Communication Standard Label Requirements
Container labels are an extension of the SDS. They are provided by the chemical manufacturer. Each container of hazardous chemicals in the workplace must be labeled with the identity of the chemical, a signal word, hazard statement for the chemical, corresponding pictograms, any precautionary statements and the name and address of the chemical manufacturer.
This includes chemicals poured from the original container into an unlabeled container, unless they are used immediately by the employee transferring them.
Employee Training on Hazard Communication
The most important part of the hazard communication program is ensuring that all employees are aware of the hazards of chemicals with which they work. OSHA requires that employees receive training at the time of their initial assignment and whenever a new chemical hazard is introduced into their work area.
However, employees are not required to be trained on chemicals that are outside their normal work area. For example, office employees do not need to be trained on the hazards of a production chemical, unless their job duties may place them in an exposure situation.
A written hazard communication program should, at a minimum, contain:
- A list of chemicals to which employees are routinely exposed
- The hazards of nonroutine tasks that may be performed by employees
- SDS section overview
- The location(s) and accessibility of the SDS in the workplace
- How to use the hazard information on the SDS to choose personal protective equipment
- An explanation of container labels entering the workplace
- A description of the labeling system used in the workplace
All employee training must be documented and include the company name, employee's name, date of training and name of trainer. This documentation should be retained indefinitely.
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Disclaimer: This material is designed and intended for general information purposes only, and is not intended, nor shall be construed or relied upon, as specific legal advice.
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