OSHA’s Hazard Communication Standard, 29 CFR 1910.1200, (HCS), spells out
the information needed for employers and employees to work safely with chemicals. First published in 1983, The HCS targeted manufacturing companies but was soon expanded to cover all industries with potential exposures to hazardous chemicals.
HCS was modified in 2012 to align with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) to ensure consistent information. The onus is on chemical manufacturers to develop and distribute Safety Data Sheets (SDSs) based on GHS requirements to their industrial clients. Companies that purchase hazardous chemicals are required to obtain and maintain SDSs and labels.
There are several requirements for compliance:
- Written Plan: A Hazard Communication Plan (HCP) is required by the Standard and must outline information informing employees of the requirements and specific site information.
- Labels: All chemical containers must be correctly labeled.
- Safety Data Sheets: SDSs must be current, maintained, and accessible for all hazardous chemicals at the site.
- Training: All employees handling or working near chemicals must be trained in your HCP and be fully informed of the hazards and methods of protection.
- Evaluation: It is essential to assess the effectiveness of your program. This is the often neglected element.
On the surface HCS and your plan seem basic and once established the assumption is that it runs smoothly; however, violations are frequently found. It is almost certain that some SDSs are missing or out of date, and that employees often forget key information. When we conduct audits, we include system assessments to identify potential gaps by asking employees questions regarding the HCP such as identifying GHS pictograms, SDS locations, and even just, ‘tell me about the chemical you are using.’
Years ago when asked, an employee respond that she/he was using a ‘cleaner’ and when asked what the cleaner was, the response was, ‘a good cleaner.’ Later the employee learned the chemical/cleaner name, the hazards, and why protection was necessary.
Were they once informed of the hazards? Probably. But information is transmitted in the classroom and often not transferred when the actual work task is performed or is quickly forgotten.
Is it complacency? Perhaps, since we all perform routine tasks without thinking through the hazards – or what we are doing – every time! Sometimes employees just comply with the manager’s instructions to use a cleaner to mop surfaces. Information is not provided, and the employees do not question.
How to ensure continued HCP effectiveness and safety? As part of your Safety Program for leaders and employees,
- Inform and educate managers, the safety team, and lead employees.
- Observe the work tasks and frequently talk to employees in their work areas.
- Provide brief, but regular and consistent reminders.
- Spot check labeling and SDSs maintained.
- Coach employees, managers, and Safety Committee members on chemical safety when walking around the facility.
- Schedule daily or at least weekly department/team safety huddles that are conducted by managers, lead employees, Safety Committee Members and/or EHS. Reviewing chemical hazards and safe handling should be regular topics.
- Review your HCP regularly, but at least annually and when new chemicals or equipment are introduced.
Of course, hazard communication is not limited to chemicals. A broader approach is essential. A key element of an effective safety and health program is informing employees of all potential hazards and protection. In addition, ensure all stakeholders know how to identify and report hazards, and are also involved in effective control and prevention solutions.
The bottom line is that we should not be complacent in thinking that HCP is ‘basic’ information, and that all should know this! A safe and sound workplace requires vigilance and regular assessments to ensure an effective safety and health program.
Image by Michal Jarmoluk from Pixabay