OSHA has created six steps for employers to follow to create an effective hazard communication program: (1) learn the standard and identify responsible staff; (2) prepare and implement a written hazard communication program; (3) ensure containers are labeled; (4) maintain safety data sheets; (5) inform and train employees; and (6) evaluate and reassess your program. By adhering to OSHA’s recommendations, employers can ensure that they are complying with the hazard communication standard and protecting their employees from hazardous chemicals.The first step, learning the standard and identifying responsible staff, requires you to obtain and become familiar with the Hazard Communication Standard, 29 CFR 1910.1200. After familiarizing yourself with the standard, you should identify someone to coordinate the implementation of the standard, as well as staff for particular activities, such as training. Employers who use hazardous chemicals in their workplaces must pay attention to paragraphs: (e) written hazard communication program; (f) labels and other forms of warnings; (g) safety data sheets; and (h) employee information and training.The second step requires you to prepare a written plan which details how you will comply with all other applicable requirements of the hazard communication standard. In addition to creating written procedures, you must also identify and create a list of all hazardous chemicals known to be present in the workplace. Creating an inventory of hazardous chemicals will provide much you with the ability to obtain safety data sheets for the hazardous chemicals and identify workplace hazards.In step three, you will keep labels on any containers shipped to you, and label any workplace containers when required. You, as the employer, are required to ensure that all containers with hazardous chemicals in the workplace are labeled. When you receive containers from your chemical supplier, the necessary information will be labeled on the container, including the product identifier, signal word, pictograms, hazard statements, precautionary statements, and the responsible party. In addition to maintaining these labels, you may also supplement the labels with third party labels, such as those from the National Fire Protection Association. Any containers of hazardous chemicals must at least include the product identifier and the general information on the chemical’s hazards.Step four in the process is maintaining safety data sheets (SDS). You must have a safety data sheet for each hazardous chemical in the workplace. Generally, your supplier provides an SDS for each chemical. If you do not receive one from your supplier, you must request one. Workers must have be able to access the SDSs in their work areas during their work shifts. The type of access is at your discretion, but OSHA provides some examples. One suggestion is to create an SDS binder and place it in a central location, such as the safety office. Another suggestion is to provide electronic access to the SDSs. However, if you provide electronic access, you must still have a back-up system in place in cause of power outage, equipment failure, or other emergency that access to the electronic system. You must still have hard copies of the SDSs to provide to medical personnel in case of an emergency.Step five requires employers to inform and train their employees on the hazardous chemicals present, the requirements of the hazard communication standard, the chemical hazards, appropriate protective measures, and where and how to obtain additional information. Employees must be trained prior to being assigned to a work area with hazardous chemicals, and be retrained when new hazards are introduced into the work area. As a reminder, the current hazard communication standard had a deadline of December 1, 2013 for employers to train employees on the new label elements and SDS format. If you have not yet done so, you should provide this training to employees immediately to comply with the standard.Step six is to evaluate and reassess your hazard communication periodically to ensure that it is current and relevant. Although OSHA does not have a specific evaluation time period, you should periodically review your program to ensure that all hazardous chemicals are covered and there are no new chemical hazards that employees must be trained on. In addition to adding new chemicals, be sure to remove any chemicals that have been eliminated from the workplace.For a sample written hazard communication, view OSHA’s Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals publication, linked below.