OSHA’s Hazard Communication Standard (HCS) promotes chemical safety in the workplace by requiring that employers educate their workers regarding potential hazards and their prevention. Unfortunately, many employers are falling short.
In September, OSHA revealed its preliminary list of the Top 10 Most Cited Violations in 2019. Once again, HazCom took the number two spot.
According to agency data, during the 2019 fiscal year, OSHA issued nearly 3,600 citations and $4,600,000 in penalties. Not surprisingly, the manufacturing and construction industries were the hardest hit, accounting for more than half of the violations.
Regardless of industry, it’s in every employer’s best interest to ensure workforce safety by maintaining OSHA HazCom compliance. Admittedly, the rules became more complex in 2012, when OSHA aligned its standards with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)--the international standard managed by the United Nations. But that’s no excuse for noncompliance.
Needless to say, it’s advisable for employers—especially in high-risk industries—to be meticulous in meeting OSHA’s Hazard Communication Standard, paying special care to avoid common pitfalls as outlined below.
Key Components and Pitfalls of OSHA’s Hazard Communication Standard
According to OSHA guidelines, your Hazard Communication program should include these specific actions.
Create a Written HazCom Plan
Your plan should describe how you maintain hazard communication compliance, by:
- Evaluating chemical risks at your worksites
- Ensuring you have all required communications
- Properly training your workforce, and
- Maintaining your program
Common Pitfall: According to the National Safety Council, a surprising number of employers fail to take the basic step of creating a written HazCom plan. (During an OSHA inspection, you may be asked to produce your plan.)
Assign Responsibility for Key Tasks
As with any successful program, it’s essential to assign responsibility for various tasks. If you operate at multiple worksites, consider appointing a HazCom champion at each location.
Create a Hazardous Chemical Inventory
Whether you’re a manufacturer, distributor or end user, you must have a complete, current list of hazardous chemicals used and stored at your worksites, including where they are physically located. This list must be updated each time new hazardous chemicals are introduced onsite.
Ensure All Containers are Properly Labeled
All containers must be labeled, tagged or marked to indicate: the product identifier, signal word, universal warning pictogram, hazard warning, precautionary statement, and contact information of the responsible party.
Labels are the responsibility of the manufacturer, but should you receive unlabeled containers of hazardous chemicals, you’re responsible for requesting them ASAP.
Common Pitfall: Failure to ensure proper labeling is another common HazCom violation. To avoid oversights, make checking incoming shipments part of an employee’s job description.
Obtain and Maintain Safety Data Sheets
Safety data sheets (SDSs)—which contain extensive information about each hazardous chemical—are also prepared by the manufacturer. However, it’s your responsibility to ensure you have one for every hazardous chemical on your premises, and to keep your library current and accessible to workers.
It’s also your responsibility to request missing SDS forms. (Document all such requests, so you can demonstrate a good-faith effort to obtain them from your supplier.)
Common Pitfall: Many employers are cited for failure to maintain a complete SDS library. OSHA inspectors often ask to see them. They may also ask to see your written procedures regarding missing and incomplete SDS forms.
Conduct Employee Training
Each worker who may be exposed to hazardous chemicals must be trained before their first assignment—and again whenever hazards change. According to OSHA, you should designate a specific HazCom trainer and conduct training in a language and format that workers thoroughly understand.
Through training, all workers should learn:
- That they may be exposed to hazardous chemicals
- How to read labels and SDSs
- The risks posed by specific products
- The protective measures available to them and how to use them
- Who to contact with questions/issues
Common Pitfall: Data indicates that many employers fail to meet training requirements. It’s not only in your interest to be vigilant about HazCom training, but to keep detailed training records.
Establish Procedures for Maintaining Your Program
It is important to create processes for maintaining each aspect of your HazCom program—and include them in your written HazCom plan. OSHA inspectors may ask to see them, and they’ll help you keep your program on track.
It’s also important to implement a process for regularly evaluating and updating your HazCom program. After all, things change. For example, OSHA is in the process of updating its HazCom Standard requirements to align with GHS Revision 7, which became effective in 2017. It is expected these changes will be finalized in 2020.
Does Your HR Software Help You Maintain Labor Compliance?
EPAY’s HR and Payroll software helps employers maintain all forms of labor compliance, including OSHA—and it’s particularly suited to high-risk industries like manufacturing and construction, and other employers managing an hourly or distributed workforce.
Our online learning management system allows you to upload custom training programs and track their usage, so you can confidently meet your HazCom training requirements. Take a quick, two-minute tour, or learn how we can help you defeat OSHA’s Fatal Four.