Hazard Communication--Have You Included Everything?
In 2010 hazard communication was the third most frequently cited hazard by OSHA enforcement and was the fifth most commonly identified hazard by USF SafetyFlorida consultants. Labels and other forms of warnings followed sixth.
These rankings reflect the importance of developing a comprehensive written hazard communication program, versus just maintaining an MSDS book. A hazard communication program goes beyond MSDS. A program must also include a site specific, written hazard communication plan. It should also address commonly overlooked items, such as training, container labeling and a chemical list.
Training is important. Not only must it cover the basics, such as location of the MSDS book and how to respond to an exposure, but it should educate employees on the importance of not transferring chemicals into smaller containers without correct labeling and bringing chemicals to the worksite or facility from home, without an MSDS or approval from the company’s safety officer. These issues should be part of the company’s safety policy and communicated to current employees as well as new employees during orientation.
Employers often misunderstand OSHA container labeling requirements. Most employers believe placing a chemical's name on the container meets the standard, but this is not the case. When chemicals are transferred into another container, the container must include not only the name, but also the appropriate hazard warnings. Employers can contact the product manufacturer to assist in acquiring the proper labels.
A chemical inventory, which is part of the written plan, is required and can be placed in the MSDS book and used as a table of contents. This method gives the employer the ability to meet the standard and to create an easier and quicker way for the employee to locate an MSDS during an emergency situation, such as an exposure.
Having a complete hazard communication program can protect employees from exposures and employers from unnecessary workers' compensation cost. If you are unsure about the thoroughness of your hazard communication program, request a consultation through USF SafetyFlorida at http://www.usfsafetyflorida.com/Consultation-Request-Form. We can help you.