Kevin Ian Schmidt

Hazard Communication Plan

More than 30 million workers in the United States are potentially exposed to one or more chemical hazards. There are an estimated 650,000 existing hazardous chemical products, and hundreds of new ones are being introduced annually. This poses a serious problem for exposed workers and their employers.

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. This update will also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.

OSHA.gov

How does the OSHA Hazard Communication Standard effect your business? Well first let’s take a look at what OSHA sets as some standards.

The OSHA Hazard Communication Standard (HCS) – 29 CFR 1910.1200 provides workers exposed to hazardous chemicals with the identities and hazards of those materials,

From OSHA.gov

Hazard Communication Standard

spray-bottleIn order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. OSHA’s Hazard Communication Standard (HCS) requires the development and dissemination of such information:

  • All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.

So you read this and say to yourself, “I don’t deal in hazardous chemicals”. But if you have things like cleaning chemicals, that employees or the public can handle, then you need to comply with OSHA’s Hazard Communication Standard. Employees need to be familiar with OSHA’s hazard communication standards to help save lives and avoid OSHA citations.

Purpose of the HAZCOM standard

The purpose of the HCS 2012 is to make sure that:

  1. the hazards of all chemicals produced or imported are classified, and
  2. information about the classified hazards is transmitted to employers and employees.

Classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, may include:

  • hazard communication plandeveloping and maintaining a written hazard communication program
  • listing hazardous chemicals present
  • labeling containers of chemicals in the workplace
  • labeling containers of chemicals being shipped to other workplaces
  • preparing and distributing SDSs to employees and downstream employers
  • developing and implementing employee training programs

The HCS 2012 applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

Foreseeable emergency” means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.

The phrase “known to be present” is important. If a hazardous chemical is known to be present by the chemical manufacturer or the employer, it is covered by the standard.

This includes not using generic, unlabeled cleaners, or buying cleaners in bulk and putting them in unlabeled bottles. Using a marker on the bottle isn’t enough either.

“Hazardous chemical” means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

This includes chemicals to which employees may be exposed during normal operations or in a foreseeable emergency. This means that even though an employer was not responsible for the manufacture of the hazardous chemical, the employer has the responsibility for transmitting information about the hazardous chemical to his or her employees.

Employees, such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. For example, an office worker who occasionally changes the toner in a copying machine would not be covered by the standard. However, an employee who operates a copying machine as part of her/his work duties would be covered by the HAZCOM Standard.

Do you have all SDS sheets and a chemical listing of chemicals onsite, that is available to all employees, not locked in a drawer in a back office. Online access is acceptable, as long as all employees know how to get it and have access to a computer.

Have you conducted employee awareness training on how to read an SDS sheet?

 

Click Here to download a Sample Hazcom Policy that can be adapted for your needs, but remember a small business owner might find a full and proper Hazard Communication Plan to be overwhelming to fully and properly design.

 

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