The fifth step on the path to safety leads us to the very important Hazard Communication (HazCom), or the Right to Know regulations. The purpose of the HazCom regulation is to ensure that chemicals produced or imported are evaluated by the manufacturer for potential physical or health hazards, and that information is transmitted to employers and employees who work with these chemicals. Employees have the right to know what chemicals they are working with or around, what hazards those chemicals pose and how they can protect themselves from those hazards.
The Hazard Communication
Standard is composed of five key elements. These five key elements are:
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.
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.
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
Training: All employees must be trained to identify
and work safely with hazardous materials.
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
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.
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.
Path to Safety - Step Five
November 1, 2009