What are the 3 components of the hazardous communication program?

Workplace chemicals have many hazardous properties: flammability, reactivity and carcinogenicity, to name a few. This is why OSHA’s Hazard Communication Standards (HCS, also known as HazCom) exist. They require companies producing and/or using hazardous chemicals to provide employees with information and training relevant to the hazardous chemicals, their handling, protective measures, and any other significant safety concerns.

According to OSHA’s Right-to-Know Standard, employees have a need (and a right) to know what chemicals they encounter in the workplace and to understand how these chemicals may affect their health and safety. All containers with hazardous chemicals in the workplace must be clearly labeled and employees must have access to safety data sheets (SDSs, formerly material safety data sheets or MSDS). Armed with the relevant information and proper training, employees can safely handle chemicals in the workplace and will know how to behave in the event of an emergency.

The OSHA standards help employers understand regulations and take the right steps to ensure workers’ safety. When approaching HazCom, remember its five key elements:

• materials inventory;
• safety data sheets;
• labeling;
• written program; and
• training.

Materials inventory/hazard determination

Prepare a thorough and complete list of the hazardous materials present in your workplace and particular work areas. A comprehensive list will make it easier to address each and every potential chemical hazard in the workplace and help you avoid forgetting anything vital.

Safety data sheets

The United Nations has developed a set of guidelines called the Globally Harmonized System for Classification and Labeling of Chemicals (GHS). The aim of GHS is to standardize how workplaces define hazards related to a chemical, classify them and then communicate the hazards and relevant protective measures on labels and safety data sheets. In 2012, OSHA published a revision of the HazCom Standard to align with GHS.

SDSs should contain a detailed description of each hazardous material listed in the workplace materials inventory. The data sheets are required to contain 16 sections (4 of which are non-mandatory) and OSHA mandates that they should include information such as:

• the properties of each chemical;
• the physical and health hazards posed by the chemical;
• environmental health hazards;
• protective measures; and
• safety precautions for handling, storing and transporting the chemical.

Safety data sheets must be available for all of the hazardous materials present in a work area and the information provided in them should be helpful to anyone who needs to get it quickly. It must also be easily accessible.

Labeling

All containers of hazardous materials must have labels that identify the material and warn of its potential hazards. The HazCom Standard requires all hazardous materials to be labeled on the container itself, the batch ticket, placard or the process sheets. The only exception is the use of portable containers for the immediate use of the employee who performs the transfer of the chemicals.

Hazardous chemical containers are required to have a label that includes:

• product name;
• signal word (“Danger” or “Warning”);
• hazard statement for each hazard class and category;
• pictograms;
• precautionary statement describing safe handling procedures; and
• name and telephone number of the responsible party.

There are different formats of labeling and the National Fire Protection Association (NFPA) Diamond System and Hazardous Materials Information System (HMIS) are both acceptable.

Written program

If your company makes use of or produces hazardous chemicals then a written hazard communication program is required. The plan should include steps to ensure that all workers are familiar with the risks involved in chemical handling and understand the labeling and symbols associated with each type of chemical hazard.

The written program must tie together labeling, materials inventory, safety data sheets and training. The plan should be implemented, maintained and readily available to employees. In addition, reviews and revisions are required on a regular basis to address changing conditions such as new chemicals or new PPE.

Companies are responsible for protecting workers from chemical hazards and preparing a thorough hazard communication program is an essential component of keeping people safe in the workplace.

Training

All employees must be trained to identify and work safely with hazardous materials. The training should cover the HazCom Standard requirements, the location of chemicals in the workplace and a written program that includes SDSs and lists of hazardous chemicals present in the work environment.

Workers need to learn how to read safety data sheets and should develop the habit of reading the SDS before working with any hazardous materials. They should also know how to act in unsafe and unplanned situations where they might be exposed to dangerous chemicals. Regular refreshers and drills could help with the goal of keeping information fresh in people’s minds. 

In addition, including human factors training in the company safety program can improve safety communication and prevent chemical-related incidents. Human factors such as rushing and fatigue cause a significant number of errors that can lead to injuries, spills, mislabelling of chemicals and other serious incidents. Human factors training teaches employees how to recognize and address states of mind that negatively affect their safety and performance, and helps them become more mindful around workplace hazards.

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When working with hazardous chemicals, employees must have the proper information and training regarding handling the chemicals, protecting themselves against risk, and understanding any outstanding safety concerns.

It’s no wonder that OSHA’s Hazard Communications Standards (HCS, otherwise known as HazCom) is the second-most cited federal workplace safety and health standard, exceeded only by the construction field’s fall protection standard. Between October 2018 and September 19 alone, OSHA cited the HCS upwards of 4,000 times across just 2,276 inspections.

HazCom requires companies handling these hazardous chemicals to disclose any pertinent information and offer any necessary training about the chemicals themselves. As an enforcement standard, HazCom helps employers protect their workers and understand the regulations surrounding their line of work.

To remain in compliance with HCS standards, you will need to uphold these three key elements:

1. Labeling Compliance

OSHA compliance officers, also known as CHSOs, will check carefully for label compliance with HCS while inspecting the facilities of importers, manufacturers, or distributors of hazardous chemicals.

They’ll be looking to see that the hazard classifications on labels and in SDSs meet OSHA’s standard while also checking for updated labels that include any significant new information about the chemicals and the risks they pose.

It’s critical to ensure your chemical labels include all of the following:

• Necessary hazard descriptions
• Chemical identity
• Contact information for the responsible party, including name and address

The goal of these labels is to inform employees of the hazardous effects of chemicals they may expose themselves to, so CSHOs may also conduct employee interviews to confirm their understanding of these labels.

2. SDS Compliance

During workplace inspections, OSHA CSHOs will check that employers have indexed an SDS for every hazardous chemical in their workplace. They’ll be hoping to find that all safety data sheets for all hazardous materials are present and that the information is both helpful and easy to access.

This information should be available in a comprehensive list of the hazardous materials on the premises. When creating your SDS inventory, take the time to do these four things:

• Physically take inventory of all chemicals on-site and build the list
• Check for SDSs currently on file
• For missing SDSs, contact the supplier or manufacturer and request a copy
• Keep documentation of this request on file until the SDS is finally received

The system that maintains your SDSs is also an essential part of the Hazard Communication Standards. This system should define the chemical hazards, classify them, and provide updated information for labels and safety data sheets. OSHA mandates that these SDSs must include the following:

• Chemical properties
• Health and physical hazards of the chemical
• Environmental health hazards
• Safety precautions for handling, transporting, and storing
• Protective measures

3. Training Compliance

Finally, CSHOs will also look for compliance with HCS regarding employee training requirements. They execute this by interviewing employees on the hazards of the chemicals they work with on-site and how to handle them safely.

Stay on the ball with a robust training program in addition to a written HazCom program that can be referenced as needed.

Your training program should feature:

• Discussion on SDSs, PPE, safety measures, and general chemical hazards, exposure response, and clean up protocol
• A variety of media such as interactive videos, audiovisuals, and classroom instruction
• A language and literacy level appropriate for the employees
• Training via chemical categories
• Training based on chemicals employees have the highest potential of interacting with

Trained employees should also feel confident about where they can find SDSs in the workplace and where to access their written HazCom program.

The written hazard communication program for your company must equip employees with the knowledge they need to understand the risks involved with the chemicals they typically handle and make sense of often complicated labeling and hazard symbols.

Within the written program, employees should be able to find:

• Labeling information
• Materials inventory
• The most updated revisions to new chemicals, new PPE, or new risks

This documentation should be readily available to all employees to reduce the chance of injury or illness caused by chemical exposure.

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