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.
The 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.
The 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.
Remember 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.
If you are a manufacturer responsible for developing MSDSs, you need to document how you made your hazard determination.
1. Did you use the OSHA-designated lists?
2. Did you examine the studies involving your chemical?
3. Did you do any testing?
4. Are you relying on the data on the MSDSs?
You 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.
This 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.
You 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.
Your written program should address the following points regarding labeling:
1. Designate the person responsible for ensuring all in-plant containers are labeled;
2. Designate the person responsible for ensuring all shipped containers are labeled;
3. Describe any labeling system used, either on shipped containers or in-plant (include samples of labels used);
4. Describe 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. Procedures to review and update label information when necessary and to ensure that labels that fall off or become unreadable are immediately replaced;
6. A copy of posters and other written materials used to inform employees about the HCS, or where the information is located.
In addition to copies of the MSDSs, you should have complete documentation covering the following points:
1. Designate the person responsible for obtaining/maintaining the MSDSs;
2. Where the data sheets are kept in your facility and how employees can obtain access to them;
3. The procedure to follow when an MSDS is not received at time of first shipment;
4. A list of chemicals received without MSDSs and copies of request letters you have sent to manufacturer or supplier;
5. If you generate MSDSs, the procedure for updating the MSDS when new and significant health information is found;
6. A description of alternatives to actual data sheets used in the workplace, if any; and
7. A copy of the MSDS format used (if your company had to generate any MSDSs).
Be sure the following points are covered in your training program:
1. Designate the person responsible for conducting training;
2. List the criteria used to determine which employees will receive training (if you are training all employees, state this);
3. Discuss the format of the program that is used (audiovisual, classroom instruction, etc.);
4. Procedure to train new employees at the time of their initial assignment;
5. Procedure to retrain employees when a new hazard is introduced (for example, will personnel track the training and retraining, or will area supervisors?);
6. Include certificates signed by employees on completion of their training, if you used such a system.
To cover all situations of employee exposure, be sure to include the following non-routine procedures in your hazard communication program:
1. Describe 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. Describe how will you inform employees of the hazards of chemicals contained in unlabeled pipes in their work areas.
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