Tuesday, November 10, 2015

Steps to an effective hazcom training program for employers

Furthermore, your workers’ comprehension will also be increased, and proper work practices will be
more likely followed in your workplace.

If you are going to do the training yourself, you will have to understand the material and be prepared to motivate the workers to learn. This is not always an easy task, but the benefits are worth the effort. More information regarding appropriate training can be found in Appendix B of this guide, which provides steps to follow in setting up and conducting training.

In reviewing your hazard communication program with regard to information and training, the following items need to be considered:

  1. Designation of person(s) responsible for conducting training;
  2. Format of the program to be used (audiovisuals, classroom instruction, etc.);
  3. Elements of the information and training program (should be consistent with the elements in paragraph (h) of the standard); and,
  4. Procedure to train new workers at the time of their initial assignment to work with a hazardous chemical, and to train workers when a new chemical hazard is introduced into the workplace.

The written program should provide enough details about the employer’s plans in this area to assess whether or not a good faith effort is being made to train workers. When assessing an employer’s compliance with hazard communication training requirements, OSHA CSHOs will talk to workers to determine if they have received training, if they know they are exposed to hazardous chemicals, and if they know where to obtain substance-specific information on labels and SDSs. It should be noted that if workers do not speak English, the employer must convey the hazard communication information in the language they understand—just like other job requirements and instructions are provided. OSHA has bilingual CSHOs, and they will be speaking to workers who speak another language to determine compliance.

The standard does not require employers to maintain records of employee training, but many employers choose to do so. This may help you monitor your own program to ensure that all workers are appropriately trained. Keeping records that document who was trained, when the training was conducted, and what was covered is also helpful to document compliance with OSHA’s training requirement in case of an inspection. The standard does not require retraining on a regular schedule, it simply requires retraining if there is a new chemical hazard introduced into the work area. If your initial training program includes all potential hazards covered by HazCom 2012, there is no retraining required. However, it is good business practice to repeat and reinforce what is learned in training to make sure that workers retain the hazard information.

If you already have a hazard communication training program, you may simply have to update it to comply with HazCom 2012. In particular, by December 1, 2013, you will need to train your employees about the new label and SDS formats they will be seeing in their work areas. Additional
hazard training is not required if you have already trained under the existing hazard communication
requirements. However, after you receive all of the new labels and SDSs, and have updated your
hazard communication program, you may find that there is a type of hazard on which employees have
not yet received training. You will need to train employees on these new hazards at the time you
become aware of the new hazard. If you become aware of new hazards after December 1, 2015, you
will have until June 1, 2016 to ensure those hazards are included in the hazard communication program, the workplace labeling reflects these new hazards, and employees are trained on these new hazards.

An employer can provide employees information and training through whatever means are found appropriate. Although there will always have to be some training onsite (such as informing workers of the location and availability of the written program and SDSs), employee training may be satisfied in part by general training about the requirements of the HCS and about chemical hazards on the job which is provided by, for example, trade associations, unions, colleges, and professional schools. In addition, previous training, education and experience of a worker may relieve the employer of some of the burdens of informing and training that worker. Regardless of the method relied upon, however, the employer is always ultimately responsible for ensuring that workers are adequately trained. If the CSHO finds that the training is deficient, the employer will be cited for the deficiency regardless of who actually provided the training on behalf of the employer.

Tuesday, October 20, 2015

Steps to an effective hazcom training for employers

5. Inform and train employees (cont'd)

HazCom 2012 requires employers to both provide certain information to employees and to train employees. The standard requires employees to be informed of:
  • The general requirements of the Hazard Communication Standard;
  • Where hazardous chemicals are located in their work areas (operations where exposure may occur); and,
  • What the workplace hazard communication program includes, and where and how they can access the program.
 Training, on the other hand, is a more active process. The training conducted to comply with HazCom 2012 must address the following:
  •  Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
  • The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
  • The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees fromexposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and,
  •  The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the SDS, including the format of the SDS (where each type of information is located) and how employees can obtain and use the appropriate hazard information.
 A properly conducted training program will ensure worker comprehension and understanding. It is
not sufficient to either just read material to the workers, or simply hand them material to read. As explained in Dr. Michaels’ OSHA Training Standards Policy Statement (April 28, 2010), OSHA
requires employers to present information in a manner and language that their employees can
understand. If employers customarily need to communicate work instructions or other workplace
information to employees in a language other than English, they will also need to provide safety and
health training to employees in the same manner. Similarly, if the employee’s vocabulary is limited,
the training must account for that limitation. By the same token, if employees are not literate, telling
them to read training materials will not satisfy the employer’s training obligation.

In conducting a training program, you want to create a climate where workers feel free to ask questions. This will help you to ensure that the information is understood. You must always remember that the underlying purpose of the HCS is to reduce the incidence of chemical source
illnesses and injuries. This will be accomplished by modifying behavior through the provision of hazard information and information about protective measures. If your program works, you and your
workers will better understand the chemical hazards in the workplace, and how to protect workers from experiencing adverse effects. The procedures you establish regarding, for example, purchasing,
storing, and handling of these chemicals will improve, and thereby reduce the risks posed to workers exposed to the chemical hazards involved.

Friday, October 9, 2015

Steps to an effective hazcom program for employers

5. 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 

    The third part of the hazard communication approach in HazCom 2012 is employee information and training (paragraph (h) Employee Information and Training). The key requirement is in paragraph (h)(1):
    (h)(1) Employers shall provide employees with effective information and training on hazardous
    chemicals in their work area at the time of their initial assignment, and whenever a new  chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemicalspecific information must  always be available through labels and safety data sheets.

    For information and training to be effective, the workers in the training must comprehend the
    hazards in the workplace and ways to protect themselves. OSHA does not expect that workers
    will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools. Workers must also be aware of the protective measures available in their workplace, how to use or implement these measures, and who they should contact if an issue arises.

    Information and training may be done either by individual chemical, or by hazard classes and
    categories (such as acute toxicity or flammable liquids). If there are only a few chemicals in the
    workplace, then you may want to discuss each one individually. Where there are large numbers of chemicals, or the chemicals change frequently, you will probably want to train generally based on the hazard classes and categories. Workers must have access to the substance-specific information on the labels and SDSs.

Monday, October 5, 2015

Steps to an effective hazcom program for employers

4. Maintain Safety Data Sheets cont'd

Minimum information for SDS:

Section 1: Identification

This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. The required information consists of:
  • Product identifier used on the label and any other common names or synonyms by which the substance is known.
  • Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.
  • Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier). 1

Section 2: Hazard(s) Identification

This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards. The required information consists of:
  • The hazard classification of the chemical (e.g., flammable liquid, category1).
  • Signal word.
  • Hazard statement(s).
  • Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions of the symbols in black and white or be a description of the name of the symbol (e.g., skull and crossbones, flame).
  • Precautionary statement(s).
  • Description of any hazards not otherwise classified.
  • For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please note that this is a total percentage of the mixture and not tied to the individual ingredient(s).

Section 3: Composition/Information on Ingredients

This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of:
  • Chemical name.
  • Common name and synonyms.
  • Chemical Abstracts Service (CAS) number and other unique identifiers.
  • Impurities and stabilizing additives, which are themselves classified and which contribute to the classification of the chemical.
  • Same information required for substances.
  • The chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards and are:
    • Present above their cut-off/concentration limits or
    • Present a health risk below the cut-off/concentration limits.
  • The concentration (exact percentages) of each ingredient must be specified except concentration ranges may be used in the following situations:
    • A trade secret claim is made,
    • There is batch-to-batch variation, or
    • The SDS is used for a group of substantially similar mixtures.
Chemicals where a trade secret is claimed
  • A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required.

Section 4: First-Aid Measures

This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. The required information consists of:
  • Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion).
  • Description of the most important symptoms or effects, and any symptoms that are acute or delayed.
  • Recommendations for immediate medical care and special treatment needed, when necessary.

Section 5: Fire-Fighting Measures

This section provides recommendations for fighting a fire caused by the chemical. The required information consists of:
  • Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation.
  • Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns.
  • Recommendations on special protective equipment or precautions for firefighters.

Section 6: Accidental Release Measures

This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. The required information may consist of recommendations for:
  • Use of personal precautions (such as removal of ignition sources or providing sufficient ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing.
  • Emergency procedures, including instructions for evacuations, consulting experts when needed, and appropriate protective clothing.
  • Methods and materials used for containment (e.g., covering the drains and capping procedures).
  • Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning or vacuuming; adsorbent materials; and/or equipment required for containment/clean up)

Section 7: Handling and Storage

This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information consists of:
  • Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited).
  • Recommendations on the conditions for safe storage, including any incompatibilities. Provide advice on specific storage requirements (e.g., ventilation requirements)

Section 8: Exposure Controls/Personal Protection

This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to minimize worker exposure. The required information consists of:
  • OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available.
  • Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed system).
  • Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face, skin or respiratory protection needed based on hazards and potential exposure).
  • Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material, such as PVC or nitrile rubber gloves; and breakthrough time of the glove material).

Section 9: Physical and Chemical Properties

This section identifies physical and chemical properties associated with the substance or mixture. The minimum required information consists of:
  • Appearance (physical state, color, etc.);
  • Upper/lower flammability or explosive limits;
  • Odor;
  • Vapor pressure;
  • Odor threshold;
  • Vapor density;
  • pH;
  • Relative density;
  • Melting point/freezing point;
  • Solubility(ies);
  • Initial boiling point and boiling range;
  • Flash point;
  • Evaporation rate;
  • Flammability (solid, gas);
  • Partition coefficient: n-octanol/water;
  • Auto-ignition temperature;
  • Decomposition temperature; and
  • Viscosity.
The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust's explosive potential

Section 10: Stability and Reactivity

This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three parts: reactivity, chemical stability, and other. The required information consists of:
  • Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available.
Chemical stability
  • Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled.
  • Description of any stabilizers that may be needed to maintain chemical stability.
  • Indication of any safety issues that may arise should the product change in physical appearance.
  • Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur.
  • List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions).
  • List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation.
  • List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.)

Section 11: Toxicological Information

This section identifies toxicological and health effects information or indicates that such data are not available. The required information consists of:
  • Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact). The SDS should indicate if the information is unknown.
  • Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
  • The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a single dose.
  • Description of the symptoms. This description includes the symptoms associated with exposure to the chemical including symptoms from the lowest to the most severe exposure.
  • Indication of whether the chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions) or found to be a potential carcinogen by OSHA

Section 12: Ecological Information (non-mandatory)

This section provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment. The information may include:
  • Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available (e.g., acute or chronic aquatic toxicity data for fish, algae, crustaceans, and other plants; toxicity data on birds, bees, plants).
  • Whether there is a potential for the chemical to persist and degrade in the environment either through biodegradation or other processes, such as oxidation or hydrolysis.
  • Results of tests of bioaccumulation potential, making reference to the octanol-water partition coefficient (Kow) and the bioconcentration factor (BCF), where available.
  • The potential for a substance to move from the soil to the groundwater (indicate results from adsorption studies or leaching studies).
  • Other adverse effects (e.g., environmental fate, ozone layer depletion potential, photochemical ozone creation potential, endocrine disrupting potential, and/or global warming potential).

Section 13: Disposal Considerations (non-mandatory)

This section provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS. The information may include:
  • Description of appropriate disposal containers to use.
  • Recommendations of appropriate disposal methods to employ.
  • Description of the physical and chemical properties that may affect disposal activities.
  • Language discouraging sewage disposal.
  • Any special precautions for landfills or incineration activities

Section 14: Transport Information (non-mandatory)

This section provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea. The information may include:
  • UN number (i.e., four-figure identification number of the substance)1.
  • UN proper shipping name1.
  • Transport hazard class(es)1.
  • Packing group number, if applicable, based on the degree of hazard2.
  • Environmental hazards (e.g., identify if it is a marine pollutant according to the International Maritime Dangerous Goods Code (IMDG Code)).
  • Guidance on transport in bulk (according to Annex II of MARPOL 73/783 and the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (International Bulk Chemical Code (IBC Code)).
  • Any special precautions which an employee should be aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises (indicate when information is not available).

Section 15: Regulatory Information (non-mandatory)

This section identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS. The information may include:
  • Any national and/or regional regulatory information of the chemical or mixtures (including any OSHA, Department of Transportation, Environmental Protection Agency, or Consumer Product Safety Commission regulations)

Section 16: Other Information

This section indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here.

Employer Responsibilities

Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency. Furthermore, employers may want to designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.

Tuesday, September 29, 2015

Steps to an effective hazcom program for employers

4. Maintain Safety Data Sheets cont'd

Chemical manufacturers and importers are required to obtain or develop an SDS for each hazardous chemical they produce or import. Chemical manufacturers, importers, and distributors are responsible for ensuring that their customers are provided a copy of these SDSs, at the time of the first shipment, and when an SDS is updated with new and significant information. Employers must have an SDS for each hazardous chemical which they use. Employers may rely on the information received from their suppliers unless they know the information is incorrect. If you do not receive an SDS automatically, you must request one as soon as possible. If you receive an SDS that is obviously inadequate, with,
for example, blank spaces, you must request an appropriately completed one. If your request for an SDS or for a corrected SDS does not produce the information needed, you should contact your
local OSHA area office for assistance in obtaining the SDS. Employers must maintain the current
version of the SDS; if a new SDS is received with a shipment, they must maintain and make available
the new SDS.

The SDSs must be in English. Many larger manufacturers also produce SDSs in other languages. If you have workers who speak language(s) other than English, you may be able to obtain SDSs in those languages to ensure effective hazard communication.

Employers must maintain copies of SDSs in their workplaces, and must ensure that SDSs are readily
accessible to workers when they are in their work areas during their work shifts. This accessibility
may be accomplished in many different ways. You must decide what is appropriate for your particular workplace. Some employers keep the SDSs in a binder in a central location (e.g., in a pick-up truck on a construction site). Others, particularly in workplaces with large numbers of chemicals, provide access electronically. However, if access to SDSs is provided electronically, there must be an adequate back-up system in place in the event of a power outage, equipment failure, or
other emergency involving the primary electronic system. As long as workers can get the information
when they need it, any approach may be used. When workers must travel between workplaces during a work shift, SDSs may be kept at the primary workplace facility. No matter what system is used,  employers must ensure that workers and medical personnel can immediately obtain the required information in an emergency.

In order to ensure that you have a current SDS for each chemical in the plant as required, and that worker access is provided, OSHA’s CSHOs will be looking for the following items in your program:

1. Designation of person(s) responsible for obtaining and maintaining the SDSs;
2. How such sheets are maintained in the workplace (e.g., in notebooks in the work area(s) or electronically), and how workers obtain access to them when they are in their work area during the work shift;
3. Procedures to follow when the SDS is not received at the time of the first shipment;
4. An SDS for each hazardous chemical in the workplace, and training of workers that includes review of SDS format and use.

For employers using hazardous chemicals, an important aspect of the hazard communication program is to ensure that someone is responsible for obtaining and maintaining the SDSs for every hazardous chemical in the workplace. To ensure that your hazard communication program improves safety and health with regard to chemical use, you should review the SDSs, and use the information to choose the needed protective measures to prevent or reduce exposures in your workplace. SDSs should be used to evaluate your workplace, and establish a plan to ensure it is safe. The following is a section-by-section description of the information required for each part of the SDS from Appendix D of HazCom 2012. Become familiar with the information available in each section of an SDS so that you will be able to more quickly access this information in an emergency and make better use of the data available.

Tuesday, September 22, 2015

Steps to an effective hazcom program for employers

4. Maintain Safety Data Sheets

  • Maintain safety data sheets for each hazardous chemical in the workplace
  • Ensure that safety data sheets are readily accessible to employees
The second part in the approach to communicating information in HazCom 2012 is to maintain
SDSs (paragraph (g) Safety Data Sheets and Mandatory Appendix D). The SDSs are the source
of detailed information on hazardous chemicals. This includes information for many different
audiences—employers, workers, safety and health professionals, emergency responders, government agencies, and consumers. It is difficult for one document to serve the needs of all of these different audiences since some require much more technical information than others. Therefore, the SDS sections have generally been organized so that the information of most use to exposed workers, emergency responders, and others who do not need extensive technical detail is in the beginning of the SDS, while the more technical information most commonly read by health and safety professionals is located in the later sections. For example, a description of a chemical’s health
effects appears in Section 2, hazard identification, but the toxicological data upon which the
determination of these effects is based appears in Section 11, toxicological information. All of the
sections are available to any reader, but there is a difference between what is necessary for a broader audience (workers and emergency responders, for example), and what might be needed by others designing protective measures or providing medical services.

The SDS requirements in HazCom 2012 are based on an internationally agreed upon 16-section SDS.
This format is based on ANSI Z400.12, so it is most likely already familiar to your employees.
HazCom 2012 establishes section headings for the SDS, as well as the order in which they are to be
provided, and the minimum information required to be included in each section under Appendix D
of the standard. However, the information in some of the sections are non-mandatory because they
address information that involve the requirements of other government bodies, and thus are not
under OSHA’s jurisdiction. Even though these sections are not considered mandatory by OSHA, the headings are still required to be present on the SDS. They will provide useful information for you to address other requirements you may need to follow. The sixteen sections are as follows, with the non-mandatory sections indicated in italics:
1. Identification
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure control/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information

Tuesday, May 12, 2015

Steps to an effective hazcom program for employers

3. Ensure containers are labeled cont'd

Some employers use third-party workplace label systems, such as those that have numerical ratings to indicate the hazards (e.g., National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS)). These may be used in conjunction with the supplemental information on the label to ensure that workers have complete information, as long as the ratings are consistent with the hazard definitions in HazCom 2012, i.e., the criteria used to assign the numerical ratings reflects the hazard categories in each hazard class in HazCom 2012. One note with regard to numerical ratings—these systems
generally use the number 1 to indicate the lowest degree of hazard, and the number 4 as the highest degree. This is the opposite of the hazard category numbering in HazCom 2012. Therefore, if as an employer you are preparing such labels based on information on the SDS, you must ensure that the numbers are properly applied to reflect the accurate degree of hazard information. Category numbers do not appear on HazCom 2012 shipped container labels, and are not equivalent to the hazard rating systems.

The employer must make sure that labels in the workplace are legible and prominently displayed. While the label information must be in English, employers are free to add warnings in other languages if workers would find that helpful. OSHA has prepared QuickCards™ to describe the label elements (OSHA 3492), as well as illustrate the pictograms (OSHA 3491). These are available on the OSHA web page, or can be obtained from your local OSHA area office.

If your workplace is inspected by OSHA, CSHOs will be looking for at least the following aspects of your labeling approach:
1. Designation of person(s) responsible for ensuring compliant labeling of shipped and inplant containers;
2. Description of written alternatives to labeling of stationary process containers (if used);
3. Appropriate labels on all workplace containers, including those received from a supplier, secondary containers, and stationary process containers;
4. A description and explanation of labels on both shipped and workplace containers included in the employee training program; and,
5. Procedures to review and update workplace label information when necessary.