Hazard communication — also known as HazCom — was the second-most-cited OSHA violation in 2022. The Occupational Safety and Health Administration (OSHA) takes HazCom requirements seriously to mitigate the severe risks associated with working alongside workplace chemicals.
OSHA hazard communication requirements for compliance are designed to protect people from any illness or injury that could arise from being exposed to hazardous chemicals in the workplace. HazCom requirements are based on the premise that workers have the right to know what they are working with. Failure to provide this information could result in citations or placement in OSHA’s severe violator enforcement program.
The HazCom requirements are exhaustive and can be challenging to manage. Breaking them down into digestible chunks is the first step to compliance success.
HazCom is critical to safety in the workplace. OSHA manages the HazCom requirements and standards to improve worker safety. Workers have a right to know what chemicals they’re exposed to so they can take the appropriate safety measures.
Workers interacting with chemicals deal with many health hazards, from skin irritation to nausea and vomiting. Businesses meeting OSHA’s hazard communication requirements can promote safety by empowering workers with clear and concise information and detailed training in chemical handling and exposure protocols.
OSHA’s Hazard Communication Standard (HCS) covers labels and communication around hazardous chemicals in the workplace. In 2012, OSHA updated the HCS to integrate with international standards. This Globally Harmonized System (GHS) provided a consistent method of communicating hazards and emphasizing worker understanding.
OSHA requirements for hazard communication exist to promote worker safety. Workers can confidently perform their jobs when they have information to keep them safe from the chemicals they interact with. Ensuring you meet OSHA hazard communication requirements for compliance can reduce — or even eliminate — injuries, illnesses, health issues, and death resulting from unsafe working conditions.
In addition, workplace health and safety are compulsory. Failure to meet OSHA requirements has significant consequences, including citations and fines over $150,000, depending on the infraction. Violations come in several forms, including improper employee training in hazard communication.
Meeting the requirements for HazCom has significant benefits for your organization, including the following:
OSHA HazCom requirements are exhaustive, but there are three core elements to remember:
The above elements provide a simplistic overview of OSHA HazCom requirements. To meet OSHA standards, safety professionals must delve deeper into the process. The OSHA HazCom standard outlines five critical elements for employers and safety professionals to follow.
Safety professionals must take a complete inventory of all workplace chemicals, from cleaning to processing. Compile written records of each chemical and ensure an SDS for each one. Your inventory should be fluid and available. You can update it regularly as you add, change, and remove chemicals from the area.
A safety data sheet for each chemical is vital to hazard communication compliance. Each SDS comprises a detailed description of each chemical and its associated hazards. The information in an SDS allows you to create protection measures specific to your workplace.
An SDS should contain the name of the chemical and any of its “common” names, a listing of the components, a statement of ingredients known to be carcinogens or cause any other health hazards, and any known dangers associated with the substance.
As per the GHS, the information on your SDS is standardized and should appear in the following order:
Employers and safety managers a required to give workers complete access to safety data sheets so they don’t need to request permission to access the information. You can print them in a binder or keep electronic copies in a shared drive accessible to all employees.
While chemical manufacturers and distributors are responsible for correctly labeling items, it falls to the employer or safety manager at a specific location to ensure they are correctly labeled. That secondary container must show the same precise information if the chemical is transferred to another container for holding or mixing.
OSHA recommends that employers or safety managers use pictograms to show clear warnings about the dangers of hazardous chemicals. There are nine pictograms for a visual representation of hazards, including the following:
There are two principal types of container labels under OSHA HazCom regulations — shipping and workplace use. Any container leaving a chemical manufacturing facility must be labeled with the same format as GHS labels.
OSHA regulations around labeling these chemicals eliminate the challenge of missing or unclear chemical information. Once the chemical reaches the organization, OSHA relaxes the labeling regulations, as different layouts may be more effective for workers. There are still some primary regulations around workplace labeling, including the following:
Detailed information about the material, including worker safety protocols, must be available to workers whenever needed, but it does not have to be displayed on the label.
A written hazard communication program is often one of the primary steps an organization must take to meet OSHA requirements for HazCom. Each safety professional must build and manage a customized program outlining all aspects of the HCS. Your hazard communication program should be accessible for ongoing use.
Implementing a hazard communication program is essential for workplace safety, so it requires more than filing your written plan away somewhere. Instead, the safety management team must continue to provide all workers with accurate and up-to-date information on all health and safety hazards in their workspace and how to protect themselves.
The written hazard communication program better informs and prepares workers to be productive and safe in their workflow. If necessary, a workplace risk assessment consultant can help you pinpoint opportunities for improvement in your current safety management practices.
Employees who may be exposed to hazardous chemicals must receive adequate education and training to work with dangerous materials. Worker safety training should cover OSHA’s hazard communication requirements and the internal written communication program detailing any relevant communications on working with hazardous chemicals.
Worker training should also include the following:
Safety managers and business owners should provide safety training to all employees before working with any chemicals. They should also provide training on any new chemicals entering the work area.
OSHA does not specify a format for HazCom training. However, it should be comprehensive and easy for employees to digest.
OSHA outlines the following steps to create a proactive hazard communication program:
First and foremost, employers and business owners must obtain a copy of OSHA’s HazCom standard and familiarize themselves with the requirements. It’s a comprehensive document detailing all the steps organizations must take to maintain compliance.
To have a practical and workable hazard communication program and ensure none of the requirements slip through the cracks, you have to assign the responsibility to an individual. This hazard communication manager must implement a system to ensure your organization meets the relevant requirements. They must also select a team responsible for the activities associated with effective hazard communication, such as training and labeling.
Your written hazard communication program must cover all the methods of addressing hazard communication in detail for your organization. One of the purposes of this written program is to ensure systematic compliance with the hazard communication standard.
Your chemical inventory forms part of your written hazard communication program. It must be regularly updated to reflect the chemicals and practices used in your organization.
With all the potentially harmful chemicals cataloged in your inventory, you can now progress to correctly labeling your containers. Although all the information you need is on the label when you receive the chemicals from the manufacturer, you can choose how to label your containers internally.
Label any secondary containers you use for chemical mixing and storage, as failure is a common OSHA violation.
Safety data sheets are not static — safety management personnel must update them regularly. OSHA requires you to request SDSs from your supplier if you don’t receive them. The critical purpose of SDSs is that they are available to all employees working with hazardous chemicals. While many safety managers choose to keep hard copies in the workplace, digital versions are becoming more popular and convenient.
If you choose to have a digital copy of your SDS, you must have a backup available in case of a power outage or equipment failure. OSHA also requires you to train your workforce to access the SDSs if you store them in digital format.
As mentioned above, OSHA requires organizations to train their employees in hazard communication. While they grant some freedom in the training techniques, they do require safety personnel to provide employees with the following information:
OSHA also has a minimum training requirement for employees. While organizations should provide comprehensive training to employees, OSHA requirements include the following:
Program evaluation is critical to identify improvement opportunities. Consult with staff members and ask them for feedback on areas of your HazCom program that they find challenging and assess any incidents that have occurred. Update your written hazard communication program to reflect any changes and inform your workers so they can view the updates.
The National Association of Safety Professionals provides workplace safety training across various industries. You can earn safety certificates and participate in classroom or online training to ensure you can provide workers with the best possible information. NASP training is built for, and by, safety professionals.
Our Hazard Communication Specialist course ensures you have the skills to make your operations HazCom compliant and that your team can handle hazardous chemicals in the workplace. Whatever your training needs, you can trust NASP to update you with the latest OSHA requirements. Contact us today to learn more about how we can help you implement The Practical Approach to Workplace Safety.
Pete Nemmers serves as NASP’s Director of Training Development, bringing a wealth of expertise to the organization. With a background rooted in safety and training, Pete plays a pivotal role in shaping the training programs offered by NASP. Pete ensures that NASP remains at the forefront of safety education, equipping professionals with the knowledge and skills necessary to navigate and excel in the dynamic field of safety.
