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.