Monday, April 6, 2015

Steps to an effective hazcom program for employers

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 are already on your way to accomplishing Step 1 by reading this guide. It is always best to review the actual provisions of the standard to ensure you are in full compliance. OSHA provides online access to the standard, as well as guidance, interpretations, and other relevant materials on its hazard communication web page: www.osha.gov/dsg/hazcom. The full regulatory text can be found at: www.osha.gov/dsg/hazcom/
HCSFinalRegTxt.html.

As noted above, the provisions that apply to employers simply using chemicals in the workplace, rather than those that produce or import chemicals, are found primarily in the following paragraphs:
(e) Written Hazard Communication Program;
(f) Labels and Other Forms of Warning;
(g) Safety Data Sheets; and
(h) Employee Information and Training.

You can focus on the requirements in these paragraphs to determine what is needed for compliance in your workplace. There may also be other provisions of the standard that help establish compliance requirements in some workplaces.

Paragraph (b), Scope and Application, specifies two types of work operations where the coverage of the rule is limited. These are laboratories and operations where chemicals are only handled in sealed containers (e.g., a warehouse). Employers with these types of work operations have reduced obligations under the HCS and basically only need to keep labels on containers as they are received; maintain SDSs that are received, and give employees access to them; and provide information and training to employees. Laboratories and operations where chemicals are only handled in sealed containers do not have to have written hazard communication programs and lists of chemicals.

The limited coverage for laboratories and sealed container operations addresses your obligation to your own workers in the operations involved. However, when laboratory employers or employers where only sealed containers are involved act as chemical manufacturers, distributors or importers, they must fulfill their duties as suppliers. For example, in warehouse operations where the employees are only exposed to sealed containers, paragraph (b)(4) of the standard would apply. When these chemicals are distributed to downstream users, paragraph (b)(4) requires the company to provide HazCom 2012-compliant labels and SDSs to downstream customers at the time of the first shipment and when the SDS is updated.

Paragraph (c), Definitions, can be used to determine the meaning of some provisions in HazCom 2012 through the definitions provided for the terms used in them. This guide will highlight some of these definitions, but you may want to consult the definitions for other terms to help ensure you fully understand your  compliance obligations in the workplace.

Hazard communication must be a continuing program in your facility. Compliance with the HCS is not a “one shot deal.” In order to have a successful program, it will be necessary to assign responsibility to staff for both the initial and ongoing activities needed to comply with the standard. In some cases, these activities may already be part of current job assignments. For example, site supervisors are frequently responsible for on-the-job training sessions. Early identification of the responsible workers, and their involvement in the development of your plan of action, will result in a more effective program design.

In order to ensure you have an effective program and address all of the necessary components, responsibility for implementation of hazard communication should be assigned to someone to coordinate. While different
people may be responsible for certain parts of implementation, there should nevertheless be someone who has overall responsibility. Approaching compliance consistently, and comprehensively, is the key to success.

The person responsible for the overall coordination may not be the best person to accomplish all of the elements. For example, training workers may require different expertise than coordinating compliance. The standard allows employers the flexibility to do what is best in their own facilities as long as compliance with all elements is achieved.

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