Breaking down the elements of a written HazCom program

Employers who fall under OSHA’s Hazard Communication (HazCom) Standard at 1910.1200 must develop, implement, and maintain a written HazCom program. Any employer with one employee and one hazardous chemical is covered. Most chemicals used in the workplace have some hazard potential and will be covered by the standard.

What’s required?

The written program is simply a record of how your organization will comply with the HazCom Standard. It doesn’t have to be lengthy or complicated. However, it should provide enough details to assess whether a good faith effort is being made to train and inform employees. Your written program must address:

• Labels and other forms of warning,
• Safety Data Sheets (SDSs),
• Employee information and training,
• The chemical inventory/list,
• Multi-employer workplaces,
• Hazards of non-routine tasks, and
• Hazards associated with chemicals in unlabeled pipes in employees’ work areas.

How to address the required elements

Labels and other forms of warning

Include the name or title of the person responsible for ensuring proper labeling of any shipped and in-house containers of hazardous chemicals. Describe the labeling system used on in-house containers of hazardous chemicals if it’s different than that on shipped containers, such as NFPA or HMIS® III.

SDSs

Include the name or title of the person responsible for obtaining and maintaining SDSs. Explain where SDSs are located in your facility (e.g., on computers and/or binders in the work areas) and how employees can access them. Describe the procedure(s) to be followed if you don’t receive an SDS at the time of first shipment and what steps employees should take if they can’t find an SDS.

Employee information and training

Describe who you’re going to train – all employees or just those exposed to hazardous chemicals? Will you use classroom training, online or computer-based modules, hands-on training, etc.? What topics will you cover? How often will you conduct training?

Chemical inventory/list

This is a list of hazardous chemicals known to be present in the workplace that you need to have an SDS for. It must contain a product identifier that can be referenced with an associated label and SDS. The list may be compiled for the workplace as a whole or for individual work areas.

Multi-employer workplaces

If there are multiple employers onsite (for example, a construction site), you must describe how the other employers are provided with access to your SDSs and informed of protective measures and labeling systems, where appropriate.

Hazards of non-routine tasks

There may be tasks to be performed on occasion that will expose employees to different chemical hazards than they’re used to. For example, confined space entry or tank cleaning. How will you handle these situations and ensure that employees involved have the necessary information to stay protected?

Hazards associated with chemicals in unlabeled pipes

Work activities may be performed by employees in areas where chemicals are transferred through unlabeled pipes. Prior to starting work in these areas, employees must be informed about the identity and hazards of the chemicals in these pipes, as well as required precautionary measures. How will you inform employees of these hazards and precautionary measures?