Appoint a Hazard Communication Program Manager
I'll be honest, there is a lot to learn when starting out with the hazard communication program. OSHA's Guidelines for Compliance can be an easier place to start than going through the regulations themselves.
If your company is just implementing one, it's important to appoint one person who will be responsible for managing the Hazard Communication Program.
That person can then familiarize themselves with the requirements and help to ensure compliance.
The employee should also focus on implementing a written program and a system for managing hazardous substances that will stay in place if that person is promoted or leaves the company.
Create a Written Hazard Communication Program
What that means is, almost every company needs to have a written Hazard Communication Program.
The point of writing everything out is to provide a guide for employees and management to follow so the system can be maintained.
For more information on writing a program, click here.
The written program doesn't have to be the length of a phone book. In fact, it shouldn't be! It just needs to serve as a guide to make sure the requirements of OSHA are met and employees understand their individual responsibilities.
OSHA has specific guidance on how to write programs here. Or you could just download our easy-to-complete and be done in minutes!
The Hazard Communication Program should include what steps your company has taken to identify and mitigate hazards, how to train employees, and responsibilities of employees and management.
Keep the written program up-to-date by reviewing annually.
Keep a Hazardous Chemical Inventory
One of the main components of the Hazard Communication Program is knowing what substances you have onsite. It's only after you know what you have that you know what the hazards are and how to protect employees from exposure issues.
The written Hazard Communication Program should either include the inventory of all hazardous substances, or reference where the inventory is located.
OSHA recommends the inventor include the product identifier which is listed on the SDS. Most companies either have a hard copy binder of all SDS's or an online inventory.
Make Sure Chemicals are Labeled
It may not come as a surprise to you that a big part of complying with the Hazard Communication Program is ensuring your hazardous substances are labeled.
After all, how can you be sure you are using something appropriately if you don't know what it is?
Poor labeling practices lead to incidents like people drinking bleach water rather than potable water.... it's not pretty.
So all hazardous substances need to be sufficiently labeled.
Now, most will arrive on your site with the manufacturer's label, which, by law should already meet OSHA requirements.
But what about when an employee is transferring a gallon of a substance from a 55-gallon drum?
That's where labeling comes in.
Many companies have what is known as a secondary labeling procedure that is outlined in their Hazard Communication Program.
This may include peel-and-stick secondary labels like those found here.
Keep Your Safety Data Sheets Available
Safety Data Sheets or SDS's are a big part of an effective Hazard Communication Program.
SDS's will tell you all the information you need to know about a chemical from the health hazards, contents, first-aid measures, and proper disposal.
Now, when you're getting started with your SDS inventory, it can be confusing where to find the information.
The manufacturer is required to have an SDS for all hazardous products so you can either find them by googling the product and manufacturer or you can contact the manufacturer. Either way, they have gotten much easier to find over the last few years.
Train Employees on the Requirements of the Hazard Communication Standard
Now, the most important element of a good Hazard Communication Program, is actually communicating about the hazards.
Employees have to understand what is in the substances they are using and how to protect themselves. They must also know who to contact with questions and concerns and how to access SDS's.
Training must include the following:
- An explanation of the Hazard Communication Program
- Workplace areas where hazardous chemicals are present
- Where the chemical inventory, MSDS descriptions, written hazard evaluation procedures, and written communications program are housed
- A description of labeling systems
- How the hazard communication program is implemented, how to read and interpret labels and MSDSs, and how employees can obtain and use available hazard information
- The hazards of chemicals in the work area
- The protective measures for employees
- How workers can detect the presence of a hazardous chemical
- The specific protective procedures the employer is providing, such as engineering controls, work practices, and personal protective equipment
Training must be available in all languages spoken by employees and should be updated regularly.
Assess Your Hazard Communication Program
Once you have all your employees trained, your chemical inventory, written program, and responsible person, the next thing is to keep the Hazard Communication Program rolling.
Conduct an audit of the program periodically to make sure everything is working as it should be. An audit should be conducted at least annually but more frequently is better when the program is new.
Make sure you correct any deficiencies and note any changes made to the program in your written Hazard Communication Program.
A Last Note on the Globally Harmonized System
One thing you will notice when you start getting into Hazard Communication Program requirements is the frequent mention of the Globally Harmonized System or GHS.
This is the merging of 65 countries' chemical labeling standards so we have a consistent system 'globally'.
All the requirements have been in place for a while now. You may have even noticed some of the new chemical labels. They include more pictograms than words and are easier to interpret, regardless of language.
To read more about the GHS System, click here.
To watch our short pictogram video, click here.
You're on Your Way to Compliance with the Hazard Communication Program
If you use the steps above, you'll be well on your way to compliance with the Hazard Communication Program.
Remember, it's one step at a time. Make sure you implement the program for lasting compliance.
Also, if you need help, we're here to guide the process.