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The most common OSHA
violation for employers is the failure to follow
the rules set by the Hazard Communication
Standard (HCS). Also referred to as “Right to
Know,” this program is intended to inform
employers and employees of the dangers
associated with the different chemical products
used or stored on site. The Hazard Communication
Standard specifies that employers are required
to provide training to their employees on these
dangers, and make available the appropriate
reference materials. In short, employees should
be able to learn anything they would like to
know about any chemical product that is used or
stored at their facility.
For most employers
this is no easy task. Depending on the number of
chemical products, work areas, and employees,
meeting the requirements of the HCS could prove
to be extremely complex and time consuming. This
article is intended to provide a brief
explanation of the Hazard Communication Standard
and what it takes to stay in compliance.
To better
understand the Hazard Communication Standard it
is easiest to divide it into five essential
categories:
- The Written
Plan
- Chemical
inventory
- Material
Safety Data Sheets (MSDS)
- Proper
Labeling and Hazard Warnings
- Employee
Training
In any business
environment it is commonly stated that “If it is
not documented, it didn’t happen.” This is
especially true when it comes to a Hazard
Communication Plan. The written plan is designed
to be a guide for how a business is going to
meet the regulatory requirements of the HCS and
a reference for the management of the program’s
specific components, listed above. The written
program must be made available for review by any
employee at any time. As mentioned in the
beginning of this review, the complete lack of
this written program is a commonly cited OSHA
violation and without it, the employees don’t
know that they NEED to know.
One thing
employees need to know is what chemicals they
are using or may become exposed to. Each
facility must have a listing of the all of the
hazardous chemicals that are used and stored
on-site. This list must be maintained and
updated when new products are acquired. This
master list is important to not only keep track
of what is there, but also to ensure that the
appropriate Material Safety Data Sheets are also
on-site and available for employee review at any
time.
Material Safety
Data Sheets (MSDS) are one of the most valuable
tools in the HCS. These may be obtained from the
manufacturer or distributor and are required to
contain almost everything about a chemical
product; manufacturer’s information, chemical
composition, physical hazards and properties,
health effects, first aid and emergency response
procedures, and personal protection equipment
requirements. MSDS’s must be made available to
any employee who desires to review them. Many
businesses are now finding it useful to create a
supplemental electronic MSDS database. In the
event of an emergency, it is easier to use a
desktop computer to find a document than to dig
through a book with possibly hundreds of pages.
Just as it is
important to have an MSDS for each hazardous
chemical, it is also crucial that all chemical
containers are properly marked and labeled. This
is required to identify each product for use and
convey the hazards of the material.
Manufacturers and distributors of chemicals are
required to properly label or mark containers
with their company name and business address,
contents of the container, and applicable hazard
warnings. It is the responsibility to the
employer to ensure that all chemicals retain
their labeling or are marked accordingly.
Employees must know how to read the labels and
also apply them when necessary.
Employee training
is an annual requirement that brings the Hazard
Communication Standard’s requirements together.
Training must be organized to explain details of
the “Right to Know” program and how their jobs
are affected by the use of these hazardous
chemicals. It is important to inform the
employees on the location, availability, and
usefulness of Material Safety Data Sheets. Other
topics that must be covered include: methods to
detect hazardous releases or exposures, health
hazards and physical properties of chemicals in
use, personal protection equipment and
environmental controls used to limit exposure,
and an explanation and proper use of hazard
labels. An effective and comprehensive training
program will meet the requirements of the HCS
and provide valuable information to your
employees that may prevent a disaster or save
lives.
The Hazard
Communication Standard is intended to inform all
employers and employees of the hazards
associated with the chemical products that may
affect them. Uninformed businesses and employees
are more likely to be the cause and victim of
accidents. They will also be unprepared to
respond to such an incident. Failure to meet any
or all of the Hazard Communication requirements
is OSHA’s number one violation, and it will
continue to be the primary topic of enforcement
because of the millions of workers affected and
the numerous associated injuries and fatalities.
More information
regarding the Hazard Communication Standard may
be found on the
OSHA website. |