Four Essential Compliance Points for Your Hazard Communication Program

The Occupational Safety and Health Administration (OSHA) releases an annual list of the most frequently cited safety and health violations, and violations of the Hazard Communication Standard (HazCom) consistently rank near the top. To prevent your organization from becoming the next statistic, it’s crucial for environment, health, and safety (EHS) managers to understand and comply with HazCom regulations.

HazCom applies to all employers whose workers may be exposed to hazardous chemicals and requires employers to inform employees of these hazards. If your workplace uses hazardous chemicals, here are four key compliance points to keep in mind:

1. Ensure a list of hazardous substances used in your workplace is readily available, along with a safety data sheet (SDS) for each substance. This list will serve as an inventory of all substances for which an SDS is required. Manufacturers, importers, or distributors must provide an SDS to customers for each hazardous chemical. If an SDS is missing, obtain it from the manufacturer, distributor, or other source.

2. Develop a written hazard communication program that outlines SDSs, labeling, and training. This program should be comprehensive, clear, and accessible to all employees. It should describe labels and other forms of warning in the workplace, SDSs, and how employee information and training requirements will be met.

3. Ensure each container holding a hazardous substance is labeled with a product identity and hazard warning. Labels must remain firmly attached and legible. Employees exposed to the chemical must know how to read the label and use the information to protect themselves. Companies can rely on standardized labels provided by suppliers, which include a harmonized signal word, pictogram, and hazard statement.

4. Develop a HazCom employee training program that includes an explanation of SDSs, their contents, and how to use them. The program should also cover “A Right to Know,” the location of physical and health hazards, specific protective measures, and how to obtain information on personal protective equipment. Training should be engaging, ensure employee retention, and promote long-term retention of information and skills.

By understanding and complying with these four key compliance points, EHS managers can prevent HazCom violations and ensure a safer working environment for their employees.