One of the most common deficiencies the consultants of the USF SafetyFlorida Consultation Program, and indeed OSHA inspectors, find relates to either not having a Hazard Communication Program (HAZCOMM) or having a program that lacks all the required elements. According to the OSHA website, the hazard communication standard (29 CFR 1910.1200) trailed only fall protection in terms of the total number of citations issued to all industries by OSHA in FY 2017 and was the most frequently cited standard in general industry. The likely reasons for this are three-fold: 1. because of its importance in preserving employee health, OSHA puts extra emphasis on the standard; 2. the standard applies to nearly every type of business you can think of from drycleaners to mortuaries to aerospace component manufacturers; and 3. employers can find the standard itself very complicated as it is one of the more voluminous standards OSHA has promulgated. But it is not all doom and gloom for employers and with a little bit of diligence compliance with the standard is pretty straightforward. Let’s look at the three factors individually:
- The purpose of the HAZCOMM standard is to ensure the HAZards of chemicals found in the workplace are effectively COMMunicated to employees so they can properly handle, store, and transport chemicals as well as properly protect themselves during normal use or upon accidental release. Hazards are communicated through training on specific chemicals the employees may use, how to use the safety data sheets (SDSs) that come with every chemical, the purpose of the HAZCOMM standard, and proper labeling of containers. Employees don’t have to be trained to a level so high they become chemistry experts, but they do have to be trained to a level that they can recognize that a specific chemical presents a hazard and what that hazard is, if there is more than one hazard (e.g. corrosive and flammable), how they can protect themselves from the hazard(s), where to find and how to interpret information about a chemical they are unfamiliar with, and whom to contact if they have any questions or concerns.
- Applicability of the HAZCOMM standard is pretty simple: if you are an employer or an employee and there are hazardous chemicals in your workplace, then the HAZCOMM standard applies to you (with exceptions for research labs, pharmaceuticals, and food/alcohol/tobacco, to name a few). So what is a hazardous chemical, you ask? There are several criteria that classify the hazardousness of a chemical: acute, long-term, and reproductive toxicity; corrosiveness; sensitization; carcinogenicity; explosiveness; flammability; pressure; and reactiveness. All the individual criteria are divided into four sub-categories to indicate severity. If there are any chemicals in your workplace that fall into one or more of these categories, then the HAZCOMM program applies to you. The good news for employers is that you are not responsible for classifying the chemicals you work with, the manufacturers take care of that for you!
- The standard is comprised of 10 paragraphs (a-j) but once the purpose, scope and application, definitions, hazard classification, trade secrets and effective dates paragraphs are put aside along with a good portion of the labeling paragraph and all but four sub-paragraphs of the SDS paragraph; the employer is left to comply with a more manageable two paragraphs (written HAZCOMM program and employee information and training) plus the applicable parts of the labeling and SDS paragraphs. That being said, those two-plus paragraphs are the heart of the standard and of the utmost import in protecting employees. Let’s quickly review what is required of the employer:
- Develop and implement a hazard communication program that includes a description of how you will ensure that containers are properly labeled;
- Keep a list of hazardous chemicals known to be present at the worksite; maintain a current safety data sheet for each listed chemical;
- Provide employees training on the requirements of the OSHA standard, where hazardous chemicals may be present, location of the written program and SDSs, methods used to detect chemical releases, hazard classifications of chemicals in their work areas, measures used for protection from hazards, and details of the written HAZCOMM program;
- And methods for informing other contractors of your program.
Employees also have implied responsibilities in the HAZCOMM standard to follow the requirements of the standard, adhere to policies and procedures implemented by the employer, and absorb and apply the training they are given.
Hopefully this will help illustrate the importance of the HAZCOMM standard as well as simplify what is required of employers and employees. The consultants with the USF SafetyFlorida Consultation Program are available to help employers navigate the ins and outs of not only the HAZCOMM standard but all OSHA standards and to also help employers provide a safe and healthy working environment for the workers of Florida. To request a free consultation please visit www.usfsafetyflorida.com and click the “Request a Free Consultation” link at the top of the page. We also have a vast library of training DVDs available for employers to borrow and our Safety Writer tool can help you develop your written program.