HazCom-What You Must Put in Writing
Thousands of former asbestos plant employees have suffered from a cancer known as Mesothelioma. This disease is directly linked to asbestos exposure. Owners of companies that used asbestos often knowingly refrained from passing along information regarding the health risks of the product their employees were using. By not informing employees most of these firms have had to make financial reparations in response to the health claims of former employees.
This is a picture of why The Occupation Safety and Health Administration (OSHA) developed rules regarding the hazard communication standard (HazCom). These rules insist it is the worker’s right to have full disclosure regarding the potential risks of chemicals they may come in contact with in the process of fulfilling their job assignments.
OSHA has been very active in citing companies that fail to provide appropriate disclosure. OSHA literature indicates that a HazCom program "helps employers design and implement appropriate controls for chemical exposures and gives employees the right to know the hazards and identities of the chemicals, as well as allowing them to participate actively in the successful control of exposures."
A HazCom program allows current and prospective employees to gain an understanding of exposure risks along with an understanding of what their employer is doing to help ensure their safety.
The Primary Objective of HazCom
- Determine the hazard
- Draft the HazCom
- Create a Material Safety Data Sheet (MSDS)
- Label all chemicals
- Train employees
- Provide fact sheets
The last year statistics were available showed that more than 2,000 violations of the HazCom rules resulted in excess of 1 million dollars in assessed penalties.
The two primary culprits cited by OSHA included employees using chemicals without proper training on the accompanying hazards along with a noted lack of an MSDS.
Written Program Compliance
Many companies may fail to develop an MSDS because they may not be sure what needs to be included. The following guidelines can help.
- Develop criteria for labeling
- Implement a warning program
- Determine person or persons responsible for labeling
- Adopt a warning label system
- Have a backup plan for labeling
- Improve updating procedures
Once these items have been established you can begin working on your MSDS. This data sheet should plainly state the point of the plan in a comprehensive manner. Include details that explain how you will implement the guidelines listed above.
OSHA inspectors will likely ask for the MSDS as their first inspection task. Because this has routinely been the issue for many companies this is the most sought after information upon the inspector’s arrival.
Can you retrieve the MSDS?
You may decide to print up the MSDS and place it in an accessible binder with other similar plans. You may also determine that an accessible computer with the information may be more appropriate. Whatever system you use for retrieval of the MSDS you will be wise to also provide a backup plan in case something were to happen to one of the systems. The company employees will also need to know where to go to find the MSDS information.
Did you know…
- If you hire an outside firm to work in your building they will need to be made aware of all hazards related to the chemicals you use that they may encounter.
- Your employee handbook should reflect the employees right to be trained with regards to all chemicals they will encounter.
- Most of the information you will need to develop an MSDS can be obtained from the manufacturer of the chemical involved.
- You will need to consider all possible applications where the chemical agent will be used and discuss the hazards of working with the chemical in that environment. This includes pipes and other non-traditional storage vessels.
- An employee may be assigned the task of developing multiple MSDS plans, but it remains the responsibility of the employer to be sure they are developed, filed, available and used by staff.
OSHA lists the role of the MSDS as “Performance-based”. What that means is you have to meet the standard of compliance, but the exact method you use may be adaptable to your company. In other words, no standard MSDS form is available. You will need to develop a comprehensive and accessible plan that serves your employees while allowing you to remain compliant with OSHA.
When you consider that there are nearly one million hazardous chemicals in use in American factories and businesses that can impact seven million businesses it becomes important to manage a self-inspection program in order to abide by OSHA requirements, remain in compliance, and protect your employees.
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Hazard Communication
The Hazard Communication Standard (HCS) provides information to workers and employers about various chemical hazards that exist in the workplace, and what protective measures they can take in order to prevent the adverse effects of such hazards. This course gives you a basic understanding of how to deal with hazardous chemicals and how workers can prevent and protect themselves from fatal chemical hazards.
