Safety Vault Information Service

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HAZARD COMMUNICATION PROGRAM

In order to ensure chemical safety in the workplace, State and Federal regulations require that information be available about the identities and hazards of the chemicals. OSHA's Hazard Communication Standard (HCS) requires the development and dissemination of such information:

While the following synopsis is provided by the Ohio Bureau of Workers’ Compensation’s Division of Safety & Hygiene, it is applicable to employers in all states. Since employers often get cited for record keeping safety violations, we thought this timely reminder should be reprinted.

HAZARD COMMUNICATION PROGRAM

Introduction

OSHA first published its Hazard Communication Standard (HCS) on November 25, 1983. The HCS is intended to ensure that workers and their employers are informed of the identities of these hazardous chemicals, associated health and safety hazards, and appropriate protective measures. The HCS now covers some 650,000 hazardous chemical products found in over three million establishments.

Chemical information is the foundation of workplace chemical safety programs -- without it, sound management of chemicals cannot occur. While the rule has been amended since 1983 to broaden the coverage to include all workers exposed to chemicals, as well as evolved to reflect new technology in information dissemination and other developments, the basic approach is still sound.

SCOPE - To ensure that the hazards of all chemicals produced or used in the workplace are evaluated and that information concerning their hazards are communicated to the employees. This is provided to employees so they will have the information they need to protect themselves from hazards.

AUTHORITY/REFERENCE - OSHA 29 CFR 1910.1200

ACCOUNTABILITY

Employers shall provide employees with information and training on hazardous chemicals in their work areas at the time of their initial assignment and whenever a new hazard is introduced into their work area. That information shall include the requirements of the Hazard Communication Standard, any operations in their work area where hazardous chemicals are present and the location of the written hazard communication program.

PROGRAM ELEMENTS

The required hazard communication program contains the following elements:

Written Program - this will describe how the criteria for labels and other forms of warning, material safety data sheets (MSDS) and employee information and training will be met.

An inventory of all hazardous chemicals - this is to assure that an MSDS exists for all hazardous chemicals in the workplace.

Product (Container) Labeling - each label shall identify the hazardous chemical, appropriate hazard warnings and the name and address of the chemical manufacturer, importer or other responsible party.

Material Safety Data Sheets - these must be maintained by the employer. They are to identify hazards and the need for employee training. The MSDSs must be readily accessible to all employees at all times on all shifts.

TRAINING

Employees shall be trained at the time of their initial exposure (assignment to the workplace) and whenever a new hazardous chemical is introduced. The training may be either chemical or hazard specific. The employees must know the location and content of the written hazard communication program, the MSDSs and the hazardous chemicals list. Training should include an annual refresher for all involved employees. Specific training for any non-routine tasks as they apply to hazardous chemical exposure should also be conducted.

DEFINITIONS

Hazardous Chemical - any chemical which is a physical hazard (combustible, explosive, flammable, unstable, water reactive, etc.) or a health hazard (carcinogens, toxic agents, irritants, corrosives, sensitizers, etc.).

Labels - for all in-plant containers - written, printed, or graphic material displayed on, or affixed to containers of hazardous chemicals.

Labels must contain appropriate hazard warnings and state the identity of the chemical as it appears on the MSDS. Shipped containers must also have the manufacturer's name and address.

Material Safety Data Sheets - MSDS - written or printed material containing information known about the chemical. MSDSs must include both the chemical and common names if they are different. MSDSs must list the physical and chemical characteristics and hazards, health hazards including signs and symptoms of exposure, any applicable exposure limits, the date of preparation of the MSDS, appropriate emergency and first aid procedures, known control measures, applicable precautions for safe use and handling, including appropriate personal protective equipment, and the name of the chemical manufacturer, importer, distributor or other party responsible for preparing or distributing the MSDS.

CROSS-REFERENCING

Other programs which may be involved in the development of this program might include Respiratory Protection, First Aid, Spill Response and Laboratory Chemical Safety.

RESPONSIBILITY

Who is going to see that the program is developed and implemented including creating and conducting the training.

This information is designed to provide the basic information necessary to develop written programs and appropriate training as required by the Occupational Safety and Health Administration. They are not intended to be or become a written program. They are a guideline for the creation of a program specific to a company.

For more information: Contact the Association office for recommended programs, the Occupational Safety & Health Administration, or your state Workers’ Comp department.

-- from the Ohio BWC Division Of Safety & Hygiene