Hazard communication often lands in the top half of OSHA’s annual Top 10 Violations list. For fiscal years 2017 – 2020, Hazard Communication was the second most cited standard under OSHA. Hazard Communication dropped to number 4 for fiscal year 2021 which still places it in the top half of the list. The top 5 areas where companies fall short of meeting Hazard Communication requirements are listed below.
1. Written Hazard Communication Program
During an inspection, the written plan is often the first piece of the Hazard Communication system an inspector will ask to see. An employer must develop and implement a written hazard communication program that is maintained at each workplace. It must include how employees will receive information and training, in regard to, labels, other forms of warning and safety data sheets. It should include a list of hazardous chemicals known to be present in the workplace. Additionally, a description must be included of the methods used by the employer to inform employees of hazards associated with non-routine task and those associated with chemicals contained in unlabeled pipes in their work areas.
2. Employee Training
Employers much provide effective training to employees regarding hazardous chemicals in their work area. Training should include the location (work area) where hazardous chemicals are present and the nature of those hazards. Information should be provided on how to detect the presence of or release of a hazardous chemical through methods and observations (such as monitoring and the visual appearance and odor of hazardous chemicals). The location and availability of the written hazard communication program, list of hazardous chemicals and safety data sheets must be made known to employees. An explanation of the labeling system and how to utilize and understand the safety data sheet should be included in training. Additionally, employees should be trained on the proper measures to prevent chemical hazards and exposure with appropriate work practices, emergency procedures and the proper use of personal protective equipment.
3. Accessibility of Safety Data Sheets
Workplace copies of safety data sheets for each hazardous chemical must be maintained and be accessible. They must be easily and readily available to employees, during each work shift, while in their work area. Electronic access to safety data sheets is permitted if such access does not create a barrier to immediate employee access.
4. Workplace Labeling
Each container of hazardous chemicals in the workplace must be appropriately labeled, tagged or otherwise marked with the appropriate identifier, words, pictures and symbols that effectively convey general information regarding the hazards of the chemical. Proper labelling, in conjunction with other information available to employees under the hazard communication program should provide employees with specific information regarding the physical and health hazards of a chemical.
5. Safety Data Sheets
Employers must have a safety data sheet in the workplace for each hazardous chemical used. Chemical manufacturers and importers must obtain or develop a safety data sheet for each hazardous chemical produced or imported. The preparer of the safety data sheet must ensure that it is in in English, although copies in other languages may be maintained as well. Safety Data sheets must be in the proper 16 section format with the correct headings and associated information for each heading as outlined in Appendix D of 1910.1200.
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