Preparing a Written Hazard Communication Program

All workplaces where employees are exposed to hazardous chemicals are required to have a written plan describing how hazard communication will be carried out in that facility. Plan preparation is not just a paper exercise — all of the elements must be implemented in order to be in compliance with the rule. This is one of the most important aspects of your compliance program. It is also one of the first items that an OSHA compliance officer will examine to determine if your hazard communication program is adequate.
Add a Note HereThe irony is that the area that OSHA checks first is the one that the employer most frequently leaves for last. If your written program is not done, at least you are not alone. In a survey of New York State manufacturers, 75 percent did not have a written hazard communication program. A large percentage of the OSHA citations have been issued due to the lack of, or an inadequate, written program. In fact, deficiencies to the written hazard communication program requirement has topped the list of federal OSHA violations as the most cited standard for many years.
Add a Note HereThe plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your program — an assurance that all aspects of the requirements have been addressed. It serves to communicate to your employees and to OSHA exactly what you have done to comply with the HCS. In general, the written program must describe how the requirements for labels and other forms of warning, material safety data sheets, employee information, and training are going to be met in your facility.
Add a Note HereRemember that the written program needs to reflect what you are doing in your workplace. If you use a generic program, it must be adapted to address the facility it covers. For example, the written plan must list the chemicals present at the site, indicate who is to be responsible for the various aspects of the program in your facility, and indicate where written materials will be made available to employees. Your written program must cover the following topics.

Add a Note HereHazard evaluation procedures
Add a Note HereIf you are a manufacturer responsible for developing MSDSs, you need to document how you made your hazard determination.
1.  Add a Note HereDid you use the OSHA-designated lists?
2.  Add a Note HereDid you examine the studies involving your chemical?
3.  Add a Note HereDid you do any testing?
4.  Add a Note HereAre you relying on the data on the MSDSs?
Add a Note HereYou will probably have used a combination of these four categories. Clearly indicate which chemicals you used which method on. Cite what studies were used for each chemical. The documentation here could be as simple as one sentence stating that you relied on the upstream information from chemical manufacturers that you purchased from. Indicate who is responsible for evaluating the chemicals and who developed the MSDSs.

Add a Note HereHazardous chemical inventory list
Add a Note HereThis is the inventory of chemicals for which you must have MSDSs. The list may be compiled for the workplace as a whole or for individual work areas. Remember to include any consumer products that you have determined are covered by the standard as well as any substances you may inadvertently produce, such as carbon monoxide. This list must be made available to employees, upon request.
Add a Note HereYou need only list the chemical name, but OSHA suggests that for your own use, you include all information that will assist in clearly identifying the substance in question, such as chemical name, common or trade name, manufacturer’s product name, and CAS number.

Add a Note HereLabels and other forms of warning
Add a Note HereYour written program should address the following points regarding labeling:
1.  Add a Note HereDesignate the person responsible for ensuring all in-plant containers are labeled;
2.  Add a Note HereDesignate the person responsible for ensuring all shipped containers are labeled;
3.  Add a Note HereDescribe any labeling system used, either on shipped containers or in-plant (include samples of labels used);
4.  Add a Note HereDescribe written alternatives to labeling of in-plant containers, if used (for example, putting the label information on batch tickets for stationary process tanks, using posters for air emissions);
5.  Add a Note HereProcedures to review and update label information when necessary and to ensure that labels that fall off or become unreadable are immediately replaced;
6.  Add a Note HereA copy of posters and other written materials used to inform employees about the HCS, or where the information is located.

Add a Note HereMaterial safety data sheets (MSDS)
Add a Note HereIn addition to copies of the MSDSs, you should have complete documentation covering the following points:
1.  Add a Note HereDesignate the person responsible for obtaining/maintaining the MSDSs;
2.  Add a Note HereWhere the data sheets are kept in your facility and how employees can obtain access to them;
3.  Add a Note HereThe procedure to follow when an MSDS is not received at time of first shipment;
4.  Add a Note HereA list of chemicals received without MSDSs and copies of request letters you have sent to manufacturer or supplier;
5.  Add a Note HereIf you generate MSDSs, the procedure for updating the MSDS when new and significant health information is found;
6.  Add a Note HereA description of alternatives to actual data sheets used in the workplace, if any; and
7.  Add a Note HereA copy of the MSDS format used (if your company had to generate any MSDSs).

Add a Note HereEmployee training
Add a Note HereBe sure the following points are covered in your training program:
1.  Add a Note HereDesignate the person responsible for conducting training;
2.  Add a Note HereList the criteria used to determine which employees will receive training (if you are training all employees, state this);
3.  Add a Note HereDiscuss the format of the program that is used (audiovisual, classroom instruction, etc.);
4.  Add a Note HereProcedure to train new employees at the time of their initial assignment;
5.  Add a Note HereProcedure to retrain employees when a new hazard is introduced (for example, will personnel track the training and retraining, or will area supervisors?);
6.  Add a Note HereInclude certificates signed by employees on completion of their training, if you used such a system.

Add a Note HereHazards of non-routine tasks
Add a Note HereTo cover all situations of employee exposure, be sure to include the following non-routine procedures in your hazard communication program:
1.  Add a Note HereDescribe the methods you will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels). What procedures do you have to ensure that those jobs that are not part of the weekly or monthly functioning of your facility fall under your employee training system?
2.  Add a Note HereDescribe how will you inform employees of the hazards of chemicals contained in unlabeled pipes in their work areas.

Responsibilities under the Hazard Communication Standard

The HCS requires information to be prepared and transmitted regarding all hazardous chemicals. It covers both physical hazards (such as flammability), and health hazards (such as irritation, lung damage, and cancer). Most chemicals used in the workplace have some hazard potential and will be covered by the rule.

Add a Note HereChemical manufacturers, importers, and suppliers
Add a Note HereChemical manufacturers and importers have to evaluate the hazards of the chemicals they produce or import. Using that information, they prepare labels for containers and more detailed technical bulletins called material safety data sheets (MSDSs).
Add a Note HereChemical manufacturers, importers, and distributors of hazardous chemicals are required to automatically provide the appropriate labels and material safety data sheets to users when the chemicals are shipped. Every container of hazardous chemicals you receive must be labeled, tagged, or marked with the required information. A properly completed MSDS has to accompany the first shipment of the chemical and with the next shipment after the MSDS is updated.

Add a Note HereEmployers
Add a Note HereEmployers that use hazardous chemicals need to have a program in place to ensure the hazard information is provided to exposed employees. “Use” means to package, handle, react, or transfer. This is an intentionally broad scope, and includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions or in an emergency.
Add a Note HereIf your employees are exposed to chemicals, you will need to develop a written hazard communication program that covers:
§  Add a Note HereA chemical inventory list;
§  Add a Note HereContainer labels and other forms of warning;
§  Add a Note HereCollection and availability of MSDSs; and
§  Add a Note HereEmployee information and training.

Add a Note HereLimited coverage for laboratories and warehouses
Add a Note HereThere are two types of work operations where the rule’s coverage is limited. These are laboratories and operations where chemicals are only handled in sealed containers, such as in a warehouse. Basically, employers having these types of work operations need to:
§  Add a Note HereKeep labels on containers as they are received;
§  Add a Note HereMaintain material safety data sheets that are received;
§  Add a Note HereGive employees access to the MSDSs; and
§  Add a Note HereProvide information and training for employees.
Add a Note HereLaboratories and warehouse employers are not required to have written hazard communication programs and lists of chemicals.
Add a Note HereThe limited coverage of laboratories and sealed container operations addresses the obligation of an employer to the workers in the operations involved, and does not affect the employer’s duties as a distributor of chemicals. For more information, OSHA has developed a rule specifically for the safe use of chemicals in laboratories at §1910.1450.
Add a Note HereFor example, a distributor may have warehouse operations where employees would be protected under the limited sealed container provisions. In this situation, requirements for obtaining and maintaining MSDSs are limited to providing access to those received with containers while the substance is in the workplace, and requesting MSDSs when employees request access for those not received with the containers.
Add a Note HereHowever, as a distributor of hazardous chemicals, that employer will still have responsibilities for providing MSDSs to downstream customers at the time of the first shipment and when the MSDS is updated. Therefore, although they may not be required for the employees in the work operation, the distributor may need MSDSs to satisfy other requirements of the rule.

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