Friday, April 17, 2015

Steps to an effective hazcom program for employers

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), Written Hazard Communication Program, requires employers to prepare and implement a written hazard communication program. This does not need to be lengthy or complicated. The main intent of the requirement is to help ensure that compliance with the standard is done in a systematic way and that all elements are coordinated. Thus, the program must describe how the employer will address the requirements
of paragraphs (f) Labels and Other Forms of Warning; (g) Safety Data Sheets; and (h) Employee Information and Training, in the workplace. A sample written program is provided in Appendix A of this guide.
In addition, the written program must include the following items:
■ Paragraph (e)(1): A list of the hazardous chemicals known to be present in the workplace. The list may be kept using any product identifier from the SDS. Thus, the list may be kept by product name, common name,
or chemical name. The important aspect of this requirement is that the term used on the list must also be available on both the SDS and the label so that these documents can be cross-referenced. The list can be compiled in whatever way the employer finds most useful and applicable to the workplace. A list of all
hazardous chemicals in the entire workplace may be most suitable for very small facilities, where there are few work areas and all workers are potentially exposed to essentially the same products. For larger workplaces, it may be more convenient to compile lists of hazardous chemicals by work area and have
them assembled together as the overall list for the workplace. The list is an inventory of chemicals for which
the employer must ensure that there is an SDS available. Compiling the list also helps employers keep track of the chemicals present, and to identify chemicals that are no longer being used, and thus could be removed from the workplace. Removing such chemicals may also reduce potential adverse effects that could occur in the workplace.
The best way to prepare a comprehensive list may be to survey the workplace. Purchasing records may also help and employers should establish procedures to ensure that purchasing procedures result in receiving SDSs before a material is used in the workplace. Prior to purchasing chemicals, review the hazards of the chemicals and evaluate if less hazardous chemicals can be used instead.
“Product identifier” means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS.
The broadest possible perspective should be taken when doing the survey. Sometimes people think of “chemicals” as being only liquids in containers. The HCS covers chemicals in all forms—liquids, solids, gases, vapors, fumes, and mists—whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If the chemical is not hazardous, it is not covered by the standard. If there is no potential for exposure (e.g., the chemical is inextricably bound and cannot be released), the chemical is not covered by the standard.
Look around. Identify chemicals in containers, including pipes, but also think about chemicals that are generated during work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Read the labels provided by suppliers for hazard information. Make a list of all chemicals in the workplace that are potentially hazardous. For your own information and planning, you may
also want to note on the list the location(s) of the products within the workplace, and an indication of the hazards as found on the label. This will help as you prepare the rest of your program.
Paragraph (b) of the standard, scope and application, includes exemptions for various chemicals or workplace situations. After compiling the complete list of chemicals, you should review paragraph (b) to determine if any of the items can be eliminated from the list because they are exempted materials. For example, food, drugs, and cosmetics brought into the workplace for personal consumption by workers are exempt.
Once you have compiled a complete list of the potentially hazardous chemicals in the workplace, the next step is to determine if you have received SDSs for all of them. Check your files against the inventory you have just compiled. Employers are required to have SDSs for all hazardous chemicals that they use. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by keeping a copy of a letter or e-mail, or a note regarding telephone conversations. If you cannot show a good faith effort to receive the SDS, you can be cited for not having the SDS for a hazardous chemical. If you have SDSs for chemicals that are not on your list, figure out why. Maybe you do not use the chemical anymore. Or maybe you missed it in your survey. Some suppliers provide SDSs for products that are not hazardous. These SDSs do not have to be maintained.
Do not allow workers to use any hazardous chemicals for which you have not received an SDS. The SDS provides information you need to ensure that proper protective measures are implemented prior to worker exposure.
■ Paragraph (e)(1)(ii): Methods to inform employees of the hazards of non-routine tasks. The written program needs to include how an employer will inform workers of hazards that are outside of their normal work routine. While workers’ initial training will address the types of exposures they will encounter in their
usual work routines, there may be other tasks to be performed on occasion that will expose these workers to different hazards, as well as require novel control measures. For example, in a manufacturing facility, it may be necessary periodically to drain and clean out reactor vessels. For this task, workers may be exposed to cleaning chemicals that are not normally in the workplace, and the usual controls for the process may not protect them, so personal protective equipment may have to be worn. The written program needs to address how the employer will handle such situations and make sure that workers involved have the necessary information to stay protected.
■ Paragraph (e)(2): Multi-Employer Workplaces. Where there is more than one employer operating on a site, and employees may be exposed to the chemicals used by each employer, the employer’s written hazard
communication program must address:
— How on-site access to SDSs will be provided to the other employer(s).
— How such employers will be informed of needed precautionary measures.
— How such employers will be informed of the on-site labeling system if it is different from the labels specified for shipped containers under the standard.
In summary, if you are not a new employer, you should already have a written hazard communication program for your workplace. Review your written program to ensure that it is consistent with the HazCom 2012 requirements. It may need to be updated; for example, you may have to add or delete chemicals from the list in the program, or change your description of the approach to workplace labeling.
If your workers’ job assignment requires travel between various geographical locations, you may keep the written program at the primary work location.
Many trade associations and other professional groups have provided sample programs and other assistance materials to employers. These have been very helpful to many employers since they tend to be tailored to the particular industry involved. You may wish to investigate whether your industry trade groups have developed such materials. Additionally, a sample written hazard communication program is included in Appendix A
to this guide.
Although such general guidance may be helpful, you must remember that the written program has to reflect what you are doing in your workplace. Therefore, if you use a generic program it must be adapted to address the facility that it actually covers. For example, the written plan must list the chemicals present at the site, indicate who is to be responsible for the various aspects of the program in your facility, and indicate where written materials will be made available to workers.
If OSHA inspects your workplace, the OSHA Compliance Safety and Health Officer (CSHO) will ask to see your written plan.

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