Path to Safety - Step Five
The Hazard Communication Standard is composed of five key elements. These five key elements are:
(1) Chemical Inventory: The employer must conduct and document an inventory of hazardous chemicals found in each work area. This inventory list must be made available to employees who work in or around the area so they are aware of what chemicals they may have exposure to. A system should be put into place to maintain the accuracy of the inventory over time.
(2) Material Safety Data Sheets (MSDS): The employer must obtain MSDS from the chemical manufacturer. Only chemical manufacturers and importers who manufacture, process, formulate, or repackage hazardous chemicals are required to perform hazard determinations. An MSDS does not have a specific form but must contain certain key information, which identifies the product and manufacturer, specifies all hazardous chemicals in the product and their exposure limits, describes the dangers of the chemical(s) and details the personal protective equipment required to prevent exposure. Workers must have ready access to these sheets either in electronic or paper format. If an internet-based electronic form is used, there must be a “back-up” system such as a CD. The information on the sheets may change from time to time so care must be taken to ensure that the MSDS are current.
(3) Labels: All containers of hazardous materials must have legible labels written in English which identify the material and warn of its potential hazard. These labels must remain in place at all times. Damaged labels must be replaced before the product is used or shipped. If chemicals are transferred to smaller containers for in-plant use, the smaller container must be properly labeled.
(4) Training: All employees must be trained to identify and work safely with hazardous materials.
(5) Written Program: A written program must be developed which ties all of these components together.
There are special considerations found in 1910.1200(b)(4) through 1910-1200(b)(4)(iii) for work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use. This would cover most warehousing operations. The largest exception is that a written program is not required. Training is required to the extent necessary to protect employees in the event of a spill or leak of a hazardous chemical from a sealed container. Employers must ensure labels are not removed or defaced. MSDS must be readily accessible.
The full text of OSHA 1910.1200 can be found at www.osha.gov. Chemicals are a fact of life in the workplace. Developing and implementing a compliant chemical program will lead your company on the path to an effective safety program and positively impact your productivity, the health and well-being of your employees, and a better bottom line.
This article was written in conjunction with participants in the OSHA and ASA Alliance. It does not necessarily reflect the official views of OSHA or the U.S. Department of Labor.
For more information on this and additional safety topics, visit www.asa.net and click on the Safety Resources tab. A series of Tool Box Talks can be found there, as well as links to additional resources to assist in developing an effective safety program at your company.