Employer’s guide to OSHA’S Hazard communication standard

OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, creates obligations for employers using hazardous chemicals in the workplace. These requirements inform employees about the chemical hazards present in the workplace. OSHA updated its HCS in 2012 to align U.S. regulations with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in order to standardize important chemical safety information for employees. The GHS also reduces trade barriers by simplifying the classification and labeling of chemicals sold internationally.

WHY IS IT IMPORTANT TO COMPLY WITH THE GHS SYSTEM?

Employees must be informed of the dangers and hazards associated with the chemicals used in the workplace. Providing the information required under the HCS ensures that employees can protect themselves from chemical hazards and employers comply with chemical regulations.

IMPORTANT PROVISIONS OF THE HCS

Employers using hazardous chemicals have four main requirements: ensuring the proper chemical labeling ; providing safety data sheets ; training employees ; and creating a written hazard communication program.

Labeling : Employers must ensure that all hazardous chemical containers are properly labeled, tagged, or marked with either the appropriate shipping labels or information regarding the chemical’s hazards. Labels or other warnings must be legible, in English, and prominently displayed on the container or readily available in the work area. Employers may also add the information in other languages for workers who speak other languages, provided that the information is always presented in English as well.

Safety data sheets : Employers must keep a safety data sheet (SDS) for all hazardous chemicals used in the workplace. While employers may keep electronic copies of an SDS, employees must have immediate access to an SDS in their work area even if the power or internet connection is lost.

Employee training : Employees must be provided training and information about all hazardous chemicals in their work area prior at the time they are assigned to a work area. Employees must be trained on how to detect hazardous chemicals, the hazards located in their work area, how to protect themselves against the hazards, and the hazard communication program. New training is not required for all new chemicals, but only when a new type of hazard is introducted to the workplace. Employees must be aware of the requirements of the HCS, the operations where hazaardous chemicals are present, and the location of the written hazard communication program, list of hazardous chemicals, and all SDS.

Written hazard communication program : An employer must create a written hazard communication program which outlines the manner in which the employer will adhere the the labeling, SDS, and training and information requirements of the HCS. The program must also include a list of hazardous chemicals and the methods of informing employees of the hazards of non-routine tasks and chemicals in unlabeled pipes.

IMPORTANCE OF IMPLEMENTING AN ACTIVE REGULATORY WATCH ON CHEMICAL & HAZARDOUS PRODUCTS

Employees must be provided additional training when new chemical hazards are introduced to the workplace. Although new training is not required when adding new chemicals that present similar hazards to those currently existing in the workplace, chemical specific information must always be maintained and available through labels and safety data sheets.

WHAT IS A HAZARDOUS CHEMICAL?

OSHA defines “hazardous chemical” as a chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

WHICH EMPLOYEES ARE COVERED?

Employees that must be protected under the Hazard Communication Standard are those employees who may be exposed to hazardous chemicals under normal working conditions. Employees who encounter hazardous chemicals only in isolated instances are not covered. Examples of employees who are not covered would be office workers or lawyers.

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