Avoid A Common OSHA Violation - Hazard Communication

According to the National Safety Council, the 2nd most common OSHA violation for 2018 was related to hazard communication. The two main reasons for those violations were failure to train and maintaining safety data sheets.

What are the requirements of under the OSHA federal Hazard Communication standard (1910.1200)?

Employers are required to have a written hazard communication program containing at a minimum:

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• Labelling information, he employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked.
• Safety Data Sheet information such as location and access to them. The employer shall have a safety data sheet in the workplace for each hazardous chemical they use.

• Employee information and training: Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets.

• A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas).

• Non-Routine Tasks: the methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.

How to avoid a violation?

Here are a few tips to stay in compliance with your hazard communication program:

Make sure your hazard communication program covers all the regulatory requirements of the standard and the practices of your facility. Do not add anything that you won’t be able to comply with. As you are writing or revising your program, discuss with your team and decide on what is reasonable for them to do; for example, for the location of the safety data sheet or for dealing with non-routine tasks.

It is necessary to have a yearly refresher training if you want to have a successful program. In your yearly training, include how to fill out labels and where to get labels or other tag that need to be replaced. I also like to ensure the employees know how to access the safety data sheets and how to get information from one. You may want to create a quiz with an example which allows them to practice.

Lastly, the most challenging can be for the employer to maintain a safety data sheet for each hazardous chemical on site. A chemical review process as part of your management of change procedure is recommended to comply with this requirement. Chemicals would be reviewed as part of the purchasing process. Until the chemical has been reviewed and the safety data sheet is on site, the chemical cannot be purchased. It can also trigger some training for new chemicals for the employee scheduled to handle the new hazardous chemical.
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If you need any assistance with you Hazard Communication Program or if you have any questions, feel free to contact Cecile Felsher, CIH 562-495-5777 or cecile.felsher@altaenviron.com