By: Mike Huss
Risk Solutions Consultant
Chemicals have become an important element of almost every aspect of modern life. All of these chemicals—from cleaning fluids to pharmaceuticals, pesticides, and paints—are produced in workplaces, and may be used in workplaces downstream. While these chemicals have utility and benefits in their applications, they also have the potential to cause adverse effects. These adverse effects include both health hazards (such as carcinogenicity and sensitization), and physical hazards (e.g., flammability and reactivity properties). In order to protect workers from these effects—and to reduce the occurrence of chemical source illnesses and injuries—employers need information about the hazards of the chemicals they use, as well as recommended protective measures. Workers have both a right and a need to know this information too, especially so that they can take steps to protect themselves when necessary.
OSHA’s Hazard Communication Standard, 29 (CFR) 1910.1200, addresses the informational needs of employers and workers with regard to chemicals. The HCS was first promulgated in 1983, and covered the manufacturing sector. It was later expanded to cover all industries where workers are potentially exposed to hazardous chemicals. In 2012, the HCS was modified to align its provisions with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Many benefits resulted from revising the HCS to be consistent with the GHS. In particular, the GHS helps to ensure that imported chemicals will be accompanied by consistent hazard and precautionary information to protect workers exposed in the US. In addition, the revised HCS can facilitate trade in chemicals since it reduces potential barriers posed by differing global requirements for classification and labeling of chemicals.
The standard requires chemical manufacturers and importers to classify the hazards of the chemicals they produce or import, and to prepare appropriate labels and safety data sheets (SDS’s) to convey the hazards, as well as recommended protective measures. Chemical manufacturers, importers, and distributors must ensure that the containers of these hazardous chemicals are labeled when shipped, and that SDS’s are provided downstream with the first shipment and when the SDS’s are updated.
Six steps to an effective hazard communication program
- Learn the standard/identify responsible staff - obtain a copy of OSHA’s Hazard Communication Standard, become familiar with its provisions, make sure that someone has primary responsibility for coordinating implementation, and identify staff for particular activities (e.g., training)
- Prepare and implement a written hazard communication program - prepare a written plan to indicate how hazard communication will be addressed in your facility, and prepare a list or inventory of all hazardous chemicals in the workplace
- Ensure containers are labeled - keep labels on shipped containers, and label workplace containers where required
- Maintain safety data sheets - maintain safety data sheets for each hazardous chemical in the workplace, and ensure that safety data sheets are readily accessible to employees
- Inform and train employees - train employees on the hazardous chemicals in their work area before initial assignment, and when new hazards are introduced, include the requirements of the standard, hazards of chemicals, appropriate protective measures, and where and how to obtain additional information
- Evaluate and reassess your program - review your hazard communication program periodically to make sure that it is still working and meeting its objectives, revise your program as appropriate to address changed conditions in the workplace (e.g., new chemicals, new hazards, etc.)
OSHA believes that the Hazard Communication Standard is of critical importance to ensuring that hazardous chemicals are identified, and that proper measures are implemented in workplaces to achieve safe use and handling. By understanding the hazards of the chemicals, and using available information to pick the proper control measures to address these hazards, employers can achieve many benefits for themselves, as well as for their exposed workers. Additional information on this program can be found at: osha.gov.
Source: Occupational Safety and Health Administration
*Markel Specialty is a business division of Markel Service, Incorporated, the underwriting manager for the Markel affiliated insurance companies.