OSHA’s hazard communication standard (hazcom or HCS) requires employers with hazardous chemicals in the workplace to implement a formal hazard communication program that includes processes for managing and maintaining safety data sheets (SDSs), container labels, chemical inventory lists, a written HCS plan, and employee training on OSHA’s HCS standard specific to the employer’s work environment.

Meeting these requirements can be more difficult than it seems. For the past six years, HCS violations have ranked second on OSHA’s annual list of most-frequent standard violations, with the agency often citing employers for failing to have or for having an inadequate written plan in place.

So what can you do to avoid costly fines and ensure your program meets compliance requirements? Here, we’ll break down the six key steps for implementing an effective HCS program.

Step ONE: Know the standard and identify who will manage it

Learning OSHA’s hazard communication standard and understanding how it affects you and your workforce is an important first step for employers that produce, use or store hazardous chemicals. Without a basic familiarity of the standard, you can’t determine what is necessary for compliance.

Equally important is designating the appropriate personnel to manage it. Just creating the program once and expecting it to continue to stay relevant despite ongoing changes won’t suffice. Instead, it’s best to identify a specific employee or group of qualified individuals to implement and oversee associated activities, such as training. An often overlooked component of this step is accounting for employee turnover. If a designated employee leaves your company, you should immediately designate another individual who can quickly assume that role.

Step TWO: Prepare and implement a written plan

All workplaces where employees are exposed to hazardous chemicals must have a written HCS plan describing, in detail, how that facility will implement the standard. This plan does not have to be lengthy or complicated; think of it instead as a blueprint for implementing your program that assures all requirements have been addressed in a systematic and coordinated way.

A written HCS plan must include an inventory of all hazardous chemicals present in the workplace. OSHA recommends preparing this list using the product identifier (e.g., product name, common name, or chemical name) to more easily track the status of SDSs and labels for a particular chemical. It’s equally important that the product identifier be the same name that appears on the label and SDS for that chemical.

The plan should also reflect what you are doing in the workplace, and outline specific procedures for container labeling; maintaining, managing and deploying SDSs; and training employees. If an OSHA inspector visits your facility, one of the first things they may ask to see is your Written Plan, so it’s important that this document always be complete and up-to-date.

Step THREE: Ensure chemical containers are labeled

OSHA requires that all hazardous chemical containers in the workplace be sufficiently labeled. When it comes to workplace or secondary container label compliance, you have the option to replicate the corresponding HCS-compliant shipped label, or choose an alternative labeling system that uses a combination of the UN’s Globally Harmonized System (GHS) elements that, in conjunction with training and other information, provide employees with immediate access to information on chemical hazards.

An alternative labeling system such as the National Fire Protection Association (NFPA) and Hazardous Materials Identification System (HMIS) are also permitted for workplace containers, so long as it includes a product identifier, do not conflict with label information required under HCS, and successfully communicates all the hazards associated with a chemical through training and other information that is immediately available in the work environment.

OSHA generally views the shipped label as the benchmark for determining how well your workplace label performs, so regardless of which labeling option you choose, it must perform as well as, if not better than, the shipped label to communicate chemical hazards. Employee training is important to label performance, so a best practice is to simply replicate the compliant shipped label since workers are already required to receive training on that format.

Step FOUR: Maintain your Safety Data Sheets (SDSs)

SDSs are required for all hazardous chemicals in the workplace, and must be made accessible to employees during work shifts. Traditionally, this has been accomplished by managing physical copies of SDSs in three-ring binders. However, a more modern and cost efficient method is to use an online software system that electronically manages these documents. A good chemical management software solution stores SDSs in a secure, cloud-based library — making them readily-accessible to your employees. The best solutions offer an online database of indexed, manufacturer-original documents to help you track down and obtain newly updated or missing SDSs, and are mobile-enabled so employees can access them no matter where they are — even from remote, offline locations.

OSHA’s alignment of the HCS standard with GHS introduced significant changes to the format of SDSs. Chemical manufacturers were required to update older MSDSs to the GHS-aligned SDSs format, and send them with the first or the next chemical shipment following the update. If you’ve received a chemical shipment on or after June 1, 2015 and it didn’t include the updated SDS, you should request it from the supplier immediately. OSHA expects you to have updated SDSs for every hazardous chemical in your inventory and if you don’t, you should be prepared to demonstrate proof of your efforts to obtain them.

Step FIVE: Inform and train employees

Workers must receive training in accessing and using the information on labels and SDSs. They must also be aware of the protective measures available in the workplace, how to use or implement these measures, who to contact if issues arise, and all other aspects of your HCS program.

A key provision of OSHA’s HCS training requirement is that it occurs in a language and manner that employees understand, and reoccur whenever necessary to ensure retention. This determines both the language(s) you must train in and how you deliver it to employees.

Today’s workforce is more diverse, dynamic and spread out than ever before, which has led to the growing popularity of on-demand training courses. A good training software system makes it easier to manage and track required employee training needs from a central location, and allow you to deploy training content at desired intervals. This provides employees with the flexibility to learn at their own pace and schedules, and helps minimize the impact of training on operations compared to live classroom training.  Online training also helps you deliver required course materials in languages specific to your individual employee needs.

One area often overlooked by employers is the need to retrain employees regularly. This should occur whenever new employees come on-board, new hazardous chemicals are introduced to the workplace, or when employee retention of previous content has been lost. While federal OSHA does not require employee training to be performed at specific intervals, regular training is a best practice to help ensure workers retain critical HCS information. This is another area where training management software is useful by allowing you to more accurately track course requirements, evaluate training performance, and automatically notify employees about upcoming training deadlines.

Step SIX: Evaluate and reassess your program

Finally, your hazard communication program must remain current and relevant for you and your employees. This is best achieved by periodically reviewing your program to make sure it’s effective in protecting employees from chemical hazards and revise your Written Plan as appropriate to address any workplace changes, such as the introduction of new chemicals, new hazards, or changes to processes, policies and personnel, etc.

While a well-coordinated HCS program and thorough written plan helps demonstrate to OSHA that you are making responsible efforts to comply with its HCS Standard, the ultimate goal is to keep workers safe. Approaching your HCS program as an ongoing responsibility, rather than just a one-time requirement, helps prevent you from becoming just another citation statistic on the agency’s list of top violations.

More importantly, though, it shows your employees that you’re actively committed to their safety. This helps establish a strong workplace safety culture in the workplace, and supports the sustainability of your business overall.

To learn more about our AICC Workers Compensation Program in Massachusetts and about all of our great programs, please contact us today.

*Thanks to our friends at Industrial Safety and Hygiene News for content in this piece.

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