OSHA Top 10 Mini-Series: Hazard Communication

OSHA Top Ten List of Cited Violations for 2018

Every year, the Occupational Safety and Health Authority publishes its list of the Top
10 Most Cited Violations according to Federal OSHA. As of September 30th 2018,
the top two most frequently cited standards following OSHA worksite inspections are violations
relating to the Fall Protection Standard (29 CFR 1926.501) and the Hazard Communication Standard
(29 CFR.1200). In 2018, there was a whopping 7,216 citations for Fall Protection, while over
4,000 Hazard Communication citations were recorded. Both of these standards frequently fall in
to the Top 10 category, and violations often result in what could be considered easily
preventable injuries. We will therefore be dedicating the next two articles to focusing on
firstly on the Hazard Communication standard, and secondly examining the Fall Protection
standard to give our readers important insights into compliance with both regulations.

Hazard Communication: What is it?

As a small business owner, you will most likely come across chemicals in the workplace, whether
it be in the office or at a worksite.  Chemicals may range from cleaning fluids, paints and
pesticides, to more obvious hazardous chemicals such as chlorine or ethanol.  Chemicals are
as prevalent in the workplace as they are diverse, and with many beneficial and oftentimes
innocuous applications, it is difficult to always see the adverse effects that they may cause to
people.  However, employers should be aware that chemicals may pose health threats as well
as physical hazards in the workplace and should therefore be documented carefully to avoid
injuries or environmental/property damage.  Wherever workplaces use or store hazardous
chemicals, they must have a written hazardous communication program in order to inform employees
how the OSHA standard is applied at that facility.

What is a Hazardous Chemical and Do I Have Any at My Workplace?

It is important to note that prior to 2012, there were two systems for classification of
chemicals in the United States.  As of 2012, the Hazard Communication Standard was updated
so that its system of classification is aligned to the United Nations Globally Harmonized System
of Classification and Labeling of Chemicals (GHS).  These two systems are often referred to
in Hazard Communication so it is important to be aware of both systems.

Chemicals are classified as hazardous where they pose a risk as either a physical or health
hazard.  These risks may include for example- flammable liquids, combustible dusts,
carcinogenic materials or asphyxiants. Employers who receive chemicals that are considered
hazardous must also receive information about the chemical to determine the risks it may pose.
This information may be provided in the form of labeling, or may also be found on the chemical
Safety Data Sheets (SDS).  Chemicals fall into a variety of hazard classes, and may be
further subdivided in to hazard categories under the Hazard Communication Standard (see
infographic below).  Hazard classifications are typically completed by the manufacturer of
the chemical, while the end user (you) is responsible for being aware of the hazards of a
particular chemical as identified by labeling or the SDS.

https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf

What Should Be Included in a Hazard Communication Program?

As highlighted above, employers who use, transport, store chemicals, or maintain any working
environment where employees may be exposed to hazardous chemicals must have a written hazard
communication program. Also termed ‘Right to Know’, employees have the right to be aware of any
chemicals that they may be exposed to that can pose a threat to their physical safety or health.
It is also beneficial for employers to maintain a hazard communication program in order to
manage their workplace, substitute hazardous chemicals for less harmful ones where possible, and
reduce the likelihood of worker injury resulting in increased worker’s compensation costs. Small
businesses looking to create a Hazard Communication program should follow as a guide these six
steps in order for it to be effective:

1. Obtain a copy of the OSHA Hazard Communication standard and read/understand its
   requirements
2. Create a written Hazard Communication Plan
3. Label all chemical containers
4. Create a folder with the most up-to-date SDS documents for all chemicals onsite
5. Train employees on chemical hazard identification
6. Periodically review and update Hazard Communication Program

1. Understand CFR 29 1910.1200: Hazard Communication
Standard

This standard can be accessed online and provides specific information on what should be
included in the program, how containers should be labelled, information on Safety Data Sheets
and also includes requirements for training.  Some worksites have limited applications
under the hazard communication standard so it is important for employers to clearly understand
the scope of the standard and how it directly applies to their business.

2. Create a Written Hazard Communication Program

Employers should create a written hazard communication program that specifies how they intend to
comply with 1910.1200 by documenting their compliance with the standard. This includes how they
will incorporate warnings and labels for the hazardous chemicals as well as how employees will
be informed and trained on hazards and how to manage them where possible.  The plan should
also identify key individuals responsible for managing the program. The plan should include an
inventory of all hazardous chemicals at the worksite, how the employer will inform employees
about hazards including those posed by non-routine tasks, and what considerations will be taken
for multiple worksites.

3. Label All Chemical Containers

Labeling is a crucial step in any Hazard Communication Program. Labels should include a product
identifier (product name), signal word (identifies the hazard severity), hazard statement, a
pictogram depicting the type of hazard, and the contact information of the chemical manufacturer
or responsible party.

Pictograms are an easily identifiable way of displaying to an observer the hazards associated
with a particular chemical.  Some common symbols include:

https://www.osha.gov/Publications/OSHA3491QuickCardPictogram.pdf

OSHA also provides a quick reference
guide to the Hazard Communication Standard for labels and pictograms that provides a concise
look at how this exercise should be completed for all chemicals at a workplace.

4. Create a Folder with the Most Up-to-date SDS Documents for all Onsite Chemicals

All companies should maintain a Safety Date Sheet (SDS) folder that contains the SDS documents
for all chemicals onsite.  This folder should have the most up-to-date SDS for a particular
chemical on file and should be periodically reviewed to ensure that old SDS documents are
removed and new chemicals have an SDS on file. SDS documents contain the following sections,
organized in such a way that important emergency response information is provided first and
technical chemical and manufacturer information is documented in later sections:

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

SDS document folders or inventories should be kept in a central location that is easily
accessible to workers and should be maintained in English. Some companies choose to have this
information electronically, but it is wise to keep paper files on location in case of a power
outage as companies should always have these files available to employees.

5. Train Employees on Chemical Hazard Identification

Employees must be trained on the various hazards of chemicals onsite. Employers should therefore
create a training that is effective in identifying hazardous chemicals in their workplace, the
hazards associated with those chemicals, and the ways in which workers can protects themselves.
Employees should also be informed of typical locations where these chemicals may be present as
well as the methods of identifying a potential release of the chemicals. Training should also
brief employees on the general requirements of a hazardous communication program and the forms
of labeling and SDS files that are used and kept onsite.

6. Periodically Review and Update Hazard Communication Program

The use of chemicals at a workplace is a dynamic operation that can change quite frequently
depending on the type of operations at a particular site. Therefore, it’s critical that
employers review their hazardous communication program periodically to ensure that it is
up-to-date.  To do this, employers must consider:

1. Determining if there are any changes to 1910.1200 and if any changes are required to
   their hazardous communication program
2. Responsible persons are fulfilling their tasks under the program
3. SDS inventory is up-to-date
4. Training is up-to-date
5. Procedures are accurate
6. Labeling of all containers is accurate
7. The program is effectively communication chemical hazards

OSHA provides many resources for small businesses to comply with the Hazardous Communication
Standard.  For the most up-to-date information, visit their website to learn more.

To see how we can solve your company’s hazard communication needs, check out our products and
services here or call
us at (866) 329-5407 today.