The Importance of Hazard Communication
The hazard communication standard is OSHA's most frequently cited standard for general industry for 2009. The standard applies to any chemical used in the workplace that employees may be exposed to under normal use or in a foreseeable emergency.*
As the standard's title suggests, the employer is responsible for communicating the hazards associated with the handling and use of chemicals used in the workplace. This means:
1. The employer is responsible for employees to know the location of the written hazard communication program, including the required list of hazardous chemicals and material safety data sheets (MSDS).
2. The employer is responsible to make employees aware of the observation methods that may be used to detect the presence or release of a hazardous chemical used in their workplace. This includes exposure monitoring (a free services provided by USF SafetyFlorida), continuous monitoring devices, visual appearance and odor.
3. The employer is also responsible for communicating any physical and health hazards associated with the chemicals used in their workplace, means of protection such as required PPE, work practices or engineering controls, and the labeling system used for the identification of chemical containers.
Downloading or providing a general presentation about hazard communication that discusses the finer points of an MSDS, ppm or mg/m3, vapor, TLV or PEL is not enough. Hazard communication training should include the aforementioned items associated with the specific chemicals used in the workplace. Employees have the right to know, and it is the employer’s responsibility to make sure employees know about the hazards. A training session(s) is often an effective means to address questions about the elements of a hazard communication program.
What about moving employees from one area to another? If an employer requires or asks an employee to move from one area to another, employees should be trained (if not already) about the hazards associated with the chemicals used in their new work area. For a multicultural workforce, where English is not the primary language, the employer should train employees in a language they can understand to satisfy the requirements of 29 CFR 1910.1200(h).
Looking ahead, there are some proposed changes for the hazard communication standard. Most of these changes are associated with the Globally Harmonized System of Classification and Labeling of Chemicals or GHS. The GHS system was developed by the United Nations to create a global standardization for the classification and labeling of chemicals. These changes are expected to have a direct impact on the development of MSDS or SDS and labeling. For more information about the GHS system, please visit the OSHA website http://www.osha.gov/dsg/hazcom/ghs.html.
For information about hazard communications, visit our website's Resource area for information about MSDS or request a free on-site consultation so we can assist you develop a hazard communications program.
*This standard does not apply to:
• Hazardous waste
• Hazardous substances (when the hazardous substance is the focus of removal actions as per EPA regulations)
• Tobacco products, wood products, food or alcoholic beverages for personal consumption
• Any drugs as defined by the FDA and cosmetics which are packaged for personal use
• Any consumer products or hazardous substances where the employer can show it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product and its use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonable be experienced by the consumers when used for the purpose intended
• Nuisance particulates, where the chemical manufacturer or importer can establish that they do not pose any physical or health hazards covered in the standard
• Ionizing and non-ionizing radiation and biological hazards