Hazard Communication Program Guide and Best Practices

By Kathleen Clair, CSP, MS, SMS

Chemicals in the workplace can present numerous hazards including health hazards such as irritation, sensitization, and carcinogenicity as well as physical hazards like flammability, corrosion, and explosibility.

That’s why OSHA’s Hazard Communication Standard (HCS), often called HazCom for short, is a necessity in order to keep workers safe. The standard is also sometimes referred to as “Right to Know” because workers have the right to know when they have the potential of being exposed to a hazardous chemical.

The HazCom Standard

The Occupational Safety and Health (OSHA) HCS was first adopted in the US in 1983. In 1987, the scope of the standard was expanded to cover all industries where employees are potentially exposed to hazardous chemicals. OSHA revised the HCS in 2012 to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The United Nations (UN) adopted the GHS in 2003. The GHS includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals. The GHS also standardized the format of safety data sheets. The US was an active participant in the development of the GHS and is a member of the UN bodies established to maintain and coordinate the implementation of the system.

It is estimated that the updated standard covers over 43 million workers who produce or handle hazardous chemicals in more than five million workplaces in the US. The HCS requires that companies provide employees with information and training about hazardous chemicals, their safe handling, safe storage, protective measures, and any other significant safety concerns in accordance with OSHA’s regulation.

The HCS is expected to prevent more than 500 workplace injuries and illnesses and more than 40 fatalities annually.

OSHA Enforcement

Year after year the HCS can be found on OSHA’s Top 10 Most Frequently Cited Standards. In the fiscal year 2020, it was list as number 2 behind fall protection which consistently stays at number one. OSHA issued over 3,000 HCS citations in FY 2020.

The areas where companies are most likely to be cited include:

• Failure to properly label all chemical containers
• Incomplete inventory list
• Not having a hazard communication plan
• Lack of training

This post provides clarification on what is required so that employers can better understand what they need to be doing. Always verify the information by reviewing the applicable OSHA regulations prior to making any change in your safety program.

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Hazard Communication Regulatory Requirements

There are some key elements required under the HCS that must be addressed in every workplace that uses chemicals. They include a chemical inventory, a written program, container labeling, safety data sheets, and employee training.

Let’s review each element in more detail in order to understand what companies need to do to comply with the HazCom Standard.

Chemical Inventory

The HCS states that the employer is responsible for conducting a hazardous chemical inventory and developing a list of all hazardous chemicals in the workplace by using the identity that is referenced on the SDS and the container label. The identity is often a common name, like a product or trade name. The HCS also requires that this list be specific to the workplace as a whole or for individual areas in the workplace.

OSHA recommends preparing this list using the common name to more easily track the status of SDSs and labels for a particular chemical. It’s important that the product identifier or common name be the same name that appears on the label and SDS for each chemical.

The employer should walk around the office, yard, warehouse, and project sites, and record the product names of all chemicals, along with the manufacturers’ names, addresses, and telephone numbers. Each chemical’s location should also be stated. The completed chemical inventory list should be kept with the written program since it may need to be amended as new chemicals are purchased.

Labels

Labels on containers of hazardous chemicals help to identify and provide immediate warning of the hazards associated with the chemical, they also remind users that more detailed safety and health information is available elsewhere, like in an SDS.

For these reasons, manufacturers, distributors, and importers are required to provide labels that include both the chemical name and all appropriate hazard warnings.

Labels, signs, placards, and other forms of warnings provide visual reminders of specific hazards to the chemical user. Users of hazardous chemicals must ensure that labels on purchased or supplied chemicals are not removed or defaced, unless the container is relabeled with the required information.

Companies must ensure that all containers have EITHER the original manufacturer’s label or supplemental label, which contains the following information:

• Product identifier
• Signal word
• Hazard statement(s)
• Pictogram(s)
• Precautionary statement(s)
• Supplier information

Labels shall be:

• Legible
• In English
• Prominently displayed on the container

Safety Data Sheets (SDS)

The HCS requires that the chemical manufacturer, distributor, or importer develop and provide SDSs for each hazardous chemical to users to communicate hazard information. The information contained in the SDS is presented in an easy-to-read, 16-section format. This document provides guidance to help workers who handle hazardous chemicals to understand the hazards and how to keep themselves safe.

The SDS includes information such as the properties of each chemical; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical. The information contained in the SDS must be in English, but it may be in other languages too.

The information that can be found on the SDSs includes:

• Section 1, Identification (product identifier; manufacturer or distributor name, address, phone number; emergency phone number); recommended use; restrictions on use.

  

• Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.
• Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
• Section 4, First-aid measures include important symptoms/effects, acute, delayed; required treatment.
• Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment, chemical hazards from fire.
• Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
• Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.
• Section 8, Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); ACGIH Threshold Limit Values (TLVs); and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS where available as well as appropriate engineering controls; personal protective equipment (PPE).
• Section 9, Physical and chemical properties list the chemical’s characteristics.
• Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.
• Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
• Section 12, Ecological information*
• Section 13, Disposal considerations*
• Section 14, Transport information*
• Section 15, Regulatory information*
• Section 16, Other information, includes the date of preparation or last revision.

Note: Since other Agencies regulate this information, OSHA does not be enforcing Sections 12 through 15.

Below are some common terms that may be found on an SDS.

• Action level – An airborne level, typically one-half of the PEL designated in OSHA’s substance-specific standards, 29 CFR 1910, Subpart Z, calculated as an eight (8)-hour time-weighted average, which initiates certain required activities such as exposure monitoring and medical surveillance.
• Ceiling Limit – The exposure limit that a worker’s exposure may never exceed.
• Short-Term Exposure Limit (STEL) – The average exposure to a contaminant to which a worker may be exposed during a short period (typically 15 – 30 minutes).
• Time-Weighted Average (TWA) – The average exposure to a contaminant over a given period of time, typically 8-hours.

Employers must make sure that SDSs are readily accessible to employees for all hazardous chemicals in their workplace. There are several ways to do this. For example, employers may keep the SDSs in a binder or on computers. The employees must have immediate access to the information in their work area when needed and a backup is available for rapid access in the case of a power outage or other emergency.

Hazard Communication Training for Employees

All employees who may be exposed to hazardous chemicals in the workplace must be trained to identify and work safely before their initial assignment and whenever the hazard changes.

• Ensure compliance with the standard by:
• Training employees on the hazardous chemicals in the workplace
• Instructing workers on how to recognize exposure to hazardous chemicals
• Training on container label elements
• Offering instruction on Safety Data Sheet (SDS) format and content
• Explaining to employees how to access SDSs
• Explain to employees how to obtain a copy of the written HazCom program
• Training employees on any in-house labeling system used
• Discussing safety measures
• Explaining the use of PPE
• Explaining what to do if there is an exposure
• Training by grouping the like chemicals together rather than training for each individual chemical.
• Training based on what chemicals each employee will be potentially encountering during the course of his or her normal duties.

Additionally, employees must have information about where to find SDSs and the company’s written HazCom program in the workplace, and who in the company is responsible for oversight of the HazCom program.

HazCom Written Program

All workplaces where employees are exposed to hazardous chemicals must have a written HCS plan describing how that facility will comply with the standard. The plan does not have to be lengthy or complicated, but it should ensure all requirements have been addressed in a systematic and coordinated way.

A written HCS plan must include an inventory of all hazardous chemicals present in the workplace. The plan should also reflect what you are doing in the workplace, and outline specific procedures for container labeling; maintaining, managing, and deploying SDSs; and training employees.

It is important that this document always be complete and up to date. Reviews and revisions are required on a regular basis (at least annually) to address changing conditions such as new chemicals or new PPE.

Eliminating and Mitigating Chemical Hazards

Elimination or substitution is the most desirable way to control chemical hazards, followed by engineering controls. OSHA’s long-standing policy states that whenever feasible, engineering controls be used to reduce employee exposure to toxic chemicals.

Administrative or work practice controls may be appropriate in some circumstances when engineering controls cannot be implemented or when different procedures are needed after the implementation of the new engineering controls.

Personal protection equipment (PPE) is the least desirable but may still be effective. PPE is always considered the “last line of defense” when dealing with chemical hazards.

Respiratory protection is required to be used if engineering or work practice controls are not feasible or while engineering controls are being implemented. Employers must provide appropriate respiratory protection at no cost to workers, provide appropriate training and education regarding its use, and ensure that workers use it properly.

The table below gives some examples of each type of control.

Finding Information About Specific Chemicals

There are several resources that can be used to find out about a specific chemical. The OSHA Occupational Chemical Database compiles information from several government agencies and organizations. The information available on the pages includes chemical identification and physical properties, exposure limits, sampling information, and additional resources.

The NIOSH Pocket Guide to Chemical Hazards contains information on several hundred chemicals commonly found in the workplace and The Environmental Protection Agency’s (EPA’s) Toxic Substance Control Act (TSCA) Chemical Substances Inventory lists information on more than 62,000 chemicals or chemical substances.

Summary

Employees need to know about the chemicals they are working with or exposed to, hazards associated with each chemical, and how to protect themselves. Many employees work with potentially hazardous materials on a regular basis.

Employees can maintain a safe working environment when they use chemicals as they were intended and follow necessary safety precautions as outlined in the HCS.

An effective HazCom program is designed to teach all workers how to safely handle and work with the chemicals they use every day.

Sources: OSHA, NIH