OSHA’s Hazard Communication Standard (HCS) is a broad, horizontal regulation, meaning it impacts almost every workplace and numerous employees within those companies. According to OSHA, that boils down to roughly five million US workplaces and approximately forty-three million employees who are affected by the standard. (1)
Most employers are aware HazCom is an essential element in their safety management systems. They’ve made Hazard Communication part of required onboarding training through safety orientations. And when the standard updated to align with the Globally Harmonized System (GHS) in 2012, employers followed through on mandatory training, to inform workers about the changes in labeling, Safety Data Sheets (SDSs), and terminology.
But the next questions are:
- What do you do beyond that?
- Are your employees following through on various aspects of HazCom or is it a somewhat dormant and overlooked safety program in your workplace?
We’ll consider those questions and more in this article.
The HCS shouldn’t be gathering dust on the shelf, nor should the HazCom training be a one-and-done method. The foundational aspects of HazCom are an ongoing, daily process for all workers who have known or potential exposure to chemicals in the course of their job duties.
However, often that is not the case. Employees may not grasp the relevance of HazCom in meaningful ways which protect them from chemical health hazards or protect the facility from physical hazards, like fire. OSHA has stated, “An employer’s training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program.” (2) In short, workers must know how to use what they’ve learned.
Of course, training for HazCom is required initially, before workers are exposed to chemical hazards, and additionally, if a new health or physical hazard is introduced.
This online hazard communication training course would be a good way to address some of this Hazard Communication training requirement.
But as HazCom training is not compulsory on an annual basis, workers can easily forget the material and the elements of the standard that keep them safe, as our article on training and the forgetting curve demonstrates.
Clearly employers must focus HCS on the workers with obvious hazards, such as those mixing or directly handling chemicals. As one of OSHA’s top ten most commonly cited standards, HCS is not one you want to forget about, either. There’s a bit more of that discussed in detail in this article on HazCom.
But other employees in your company likely have potential HCS exposure, too. And some workers might have unusual chemical exposures, by virtue of their job functions. Offering a one-time training at the company level usually isn’t sufficient for all employees to safely work with chemicals.
By reviewing the duties of those who encounter potential or unusual chemical hazards on the job, you can avoid these pitfalls. Let’s look at some examples.
Shipping and Receiving
Although S&R employees may not directly use chemicals to perform their job duties, a basic understanding of the known and potential company chemical hazards should be provided. This is necessary in the event containers get damaged during transport or through movement within the building, as well as in storage.
You may have a well-trained chemical response team which cleans up leaking or spilled containers, but your shipping and receiving workers are the first-line of defense in the facility in this regard. And further, storage of many chemicals certainly requires knowledge of incompatible products and conditions to avoid.
As a result, make sure the S&R employees know:
- Pictograms and hazard warnings on labels, packages and placards
- Health and physical hazards classes of common chemicals that may be received or shipped
- Safe handling of flammable liquids and compressed gas cylinders
- Initial response to chemical spills or leaking or broken containers (for example, should they clear the area and summon the chemical response team? Do they know how to call these team members? Are there chemicals that if spilled or leaking, require an automatic limited or full facility evacuation?)
- Incompatible materials, both in spills and in storage
- The health and physical hazards of incompatible materials
- Proper selection and use of PPE that may be necessary when shipping or storing products
In addition to these topics, safe transportation of chemicals and use of secondary containers should be reviewed.
And occasionally, workplaces receive chemicals in error. A driver pulls away and a drum is accidentally left behind sitting on the dock, and it is not yours. This product could be one that your facility is not familiar with. Until the foreign chemical can be removed from the workplace, it may present a new hazard if it’s leaking, or even in normal storage. S&R should be aware how to respond to these events.
Typically, the staffing agency and the host employer share training responsibilities for temporary workers. Generic training on the basics of HazCom is often provided to workers by the staffing agency. However, depending on the nature of the site-specific requirements of the workplace or the anticipated job duties, the staffing agency’s training may not be sufficient to protect temporary workers fully.
As a recommended practice, work closely with staffing agencies and review the nature and types of training provided. In many cases, you’ll need to supplement temporary worker HCS training. As OSHA states, “Many OSHA standards include specific safety and health training requirements to ensure that workers have the required skills and knowledge to safely perform their work.” (3) Hazard communication is one such standard that often requires specific information to be relayed to the temporary worker.
As with your other employees, ensure your temporary workers understand:
- How to read SDS, pictograms, and hazard warnings on labels, packages and placards.
- Where to get additional information, such as the location of SDS and supervisors to ask about chemical hazards.
- Health and physical hazards classes of common chemicals they will have exposure to.
- Safe handling and storage of chemicals on the job.
- Signs of exposure to chemicals.
- Selection and use of PPE needed for chemical handling.
- What to do in the event of a chemical emergency, such as a spill or first aid event.
Of all employees groups, maintenance often present the biggest challenges in compliance, especially when it comes to chemical exposure. Typically, in small to medium-sized companies, these workers are the Jacks-of-All-Trades, and like the T.V. character, MacGyver, your maintenance crew can create or repair almost anything.
This may mean they are using chemicals in non-traditional or inappropriate ways, perhaps welding in the plant near flammable products, or using multiple (and possibly incompatible) chemicals without sufficient ventilation or respirators.
And depending on the nature of your company structure, maintenance workers may also purchase chemicals and bring them into the plant without any tracking process. This can create issues with compliance, as well as safety and health. Safety Data Sheets and chemical inventories often don’t reflect these purchases, and hazards associated with these chemicals might not be included in HCS training.
There are several ways to prevent these types of inadequacies in the HazCom program, including:
- Provide additional HSC training for maintenance workers to reiterate the safe usage of various chemical products, as well as general and job-specific HCS information on labeling, secondary containers, and SDS.
- Perform JSAs for routine, and especially, non-routine maintenance duties. For example, the annual cleaning and preventative maintenance of the boiler, should have JSAs to discover potential chemical hazards, as well as other hazards.
- Create a tracking system to ensure all chemicals purchased are included in the written HCS program and inventory. Instruct maintenance workers on this system.
- Frequently examine the storage of chemical products in the maintenance shop, to ensure they are stored safety and appropriately. Retrain workers, if needed, on this topic.
Conclusion: OSHA’s Hazard Communication Standard Ensures the Worker’s “Right to Know”
Hazard Communication is meant to be a program that is regularly and consistently used, as it provides several layers of safety for your workers. HazCom compliance is the responsibility of everyone who has known (or potential) exposure to chemical hazards. But this is only possible if everyone understands how to apply the standard to their duties.
We have online Hazard Communication training courses to help bring your employees up to speed quickly. Use our courses to provide comprehensive knowledge of HazCom and supplement with any site-specific information that pertains to your workplace or employees’ duties.
You may also find the articles related to Hazard Communication below helpful.
And hey, don’t leave without downloading the free guide below too.
Effective EHS Training: A Step-by-Step Guide
Learn how to design, create, deliver, and evaluate effective EHS training by following these best practices with our free step-by-step guide.