Friday, March 27, 2015

Steps to an effective Hazcom program for employers

Employers that have hazardous chemicals in their workplaces are required by OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a hazard communication program. The program must include labels on containers of hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and training for workers. Each employer must also describe in a written program how it will meet the requirements of the HCS in each of these areas.

Employers can implement an effective hazard communication program by following these six steps:

Step 1. 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.
• Identify staff for particular activities (e.g., training).

You may obtain a copy of the Hazard Communication Standard on OSHA’s hazard communication webpage at The provisions of the standard that apply to employers using chemicals in their workplaces are found primarily in paragraphs (e) written hazard communication program; (f) labels and other forms of warning; (g) safety data sheets; and (h) employee information and training. It is important that you become familiar with these provisions to determine what is needed for compliance in your workplace.

In order to ensure that you have an effective hazard communication program, and address all of the necessary components, responsibility for implementation of hazard communication should be assigned to someone to coordinate. The person designated for overall program coordination should then identify staff to be responsible for particular activities, such as training.

Step 2. Prepare and Implement a Written Hazard Communication Program

• Prepare a written plan to indicate how hazard communication will be addressed in your facility.
• Prepare a list or inventory of all hazardous chemicals in the workplace.

Paragraph (e) of the standard requires employers to prepare and implement a written hazard communication program. This requirement is to help ensure that compliance with the standard is done in a systematic way, and that all elements are coordinated. The written program must indicate how you will address the requirements of paragraphs (f) labels and other forms of warning; (g) safety data sheets; and (h) employee information and training, in your workplace.

The written program also requires employers to maintain a list of the hazardous chemicals known to be present in the workplace. Using the product identifier (e.g., product name, common name, or chemical name) to prepare the list will make it easier for you to track the status of SDSs and labels of a particular hazardous chemical. Remember, the product identifier must be the same name that appears on the label and SDS of the hazardous chemical.

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