5 Steps to Hazard Communication Compliance
This article is based on an original publication by Brady.
Despite its importance, OSHA's Hazard Communication Standard (HCS or Hazcom) - which ensures associates are aware of the presence of dangerous chemicals in the workplace - is one of the most frequently violated safety standards. As companies struggle to create a viable compliance program, United Nations' Globally Harmonized System (GHS) of Classification and Labeling of Chemicals regulations only add more fuel to the fire.
Ensuring compliance is easy - simply follow these 5 steps:
Step 1: Create a written hazard communication plan.
This plan should summarize use of any hazardous chemicals, state your facility's handling policies and safety precautions, and review training and inspection programs. The information should be regularly maintained and reviewed at each workplace location. To ensure compliance with OSHA's 29 CFR 1910.1200(e) regulation, your written plan must include the following.
- Purpose and scope of the program
- A list of known hazardous chemicals in the workplace, listed in the format of Safety Data Sheets (SDS)
- Labels that coincide with correct and current information in the SDS
- Useful training and information for employees to understand elements of any revision to the Hazard Communication standards, including new GHS labels and SDS's
- Methods for updating, evaluating, and conveying information about chemical hazards
- Methods to accomplish non-routine tasks surrounding hazardous chemicals and the associated risks involved in executing those tasks (i.e. cleaning reactor vessels)
- Storage and transportation methods of hazardous chemicals and materials
- Where and how employees must travel between workplaces and work shift changes when dealing with hazardous chemicals and materials
Step 2: Inventory All Hazardous Chemicals.
Your facility must routinely take inventory of all hazardous chemicals used throughout the organization, which must then be matched with complete SDS's. This inventory management program should include details such as:
- Location tracking
- Container tracking and reconciliation reporting
- Unit of measure conversions and calculations
- Managing restricted and banned chemicals
- Notifications of exceeded thresholds