How To Create a Hazard Communication Program
Everything Your Business Needs for Hazard Communication
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Step 1 - Review Regulations and Identify Responsible Staff
Review Hazard Communication Regulations
Review the Hazard Communication Regulations. These regulations, and the Hazard Communication Small Entity Compliance Guide will provide all the information you need.
Designate a Hazard Communication Coordinator
Select an employee to be the Hazard Communication Coordinator. This person has responsiblity for the implementation, administration, and monitoring of the company hazard communication program. This person should:
- Have the authority to direct employees.
- Have understanding of the work processes.
- Be famiilar with chemicals used.
- Be familiar with Hazard Communication rules.
- Have sufficient time to monitor program.
- Be designated in the written HazCom Plan.
Note: A Competent Person designation is not required for HazCom - but it is a good practice to designate competent persons.
Step 2 - Prepare a Written Hazard Communication Program
Take A Chemical Inventory
Make a list of every hazardous chemical present in the workplace. The chemical name that you use on the inventory must be present on both the chemical safety data sheet and the label, so they can be cross referenced.
The list can be kept by:
- Product Name
- Common Name
- Chemical Name
Remember to include all chemicals in the workplace, whether they are "contained" or not. Vehicle exhaust, fumes, mists and vapors all count as hazardous chemicals. If solid material, such as wood and metal, are being cut, they are likely a hazardous chemical.
Create a Written Hazard Communication Program
Lack of a written Hazard Communication Program is usually the #1 OSHA violation. The employer must create a plan that explains the company policy for communcating chemical hazards to employees. This written program must include:
- List of hazardous chemicals in the workplace.
- Methods for labeling chemicals.
- Location and availability of Safety Data Sheets.
- Methods for informing and training employees.
- Methods for informing employees of hazardous non-routine tasks.
- Hazards associated with chemicals in unlabeled pipes in the work area.
Step 3 - Label Chemical Containers
Chemical Shipping Container Requirements
All chemical shipping containers must be labeled with:
- Product Identifier
- Signal Word
- Hazard Statement(s)
- Precautionary Statement(s)
- Manufacturer Contact Info
Workplace Chemical Labeling Requirements
All chemical containers in the workplace must be labeled. There are two acceptable labeling methods:
- Use the information from the Chemical Shipping Container Label.
- Use the Product Identifier, and a combintion of words, pictures and symbols that adequately communicates the hazards to employees.
Step 4 - Maintain Safety Data Sheets
Every Chemical Must Have A Safety Data Sheet
Every chemical in the workplace must have a current Safety Data Sheet. This can be obtained from the manufacturer or chemical distributor.
Note: If the word "Material" is on the Safety Data Sheet, it is definately out of date. They have not been called "Material" safety data sheets for many years.
Make Safety Data Sheets Available To Employees
Safety Data Sheets must be readily available to employees. They can be kept in a physical binder, or electronically. If the Safety Data Sheets are stored electronically, a backup method must be in place in the event of a system crash or power outage.
Tips for Safety Data Sheets
- Mark the safety data sheet storage location with signs.
- Remove safety data sheets for chemicals that are no longer in use.
- Make safety data sheet storage work area specific for easy reference.
- Post key information from the SDS in the work area.
- Incorporate SDS information into work procedures.
- Review SDS contents as part of regular workplace safety briefings.
Step 5 - Inform and Train Employees
The Hazard Communication DVD Compliance Kit contains a training video, E-Learning Module, and PowerPoint Presentation. It also includes a written Hazard Communication Program Template, and all required forms.
All employees must be informed of:
- The requirements of the Hazard Communication Standard.
- The location and use of hazardous chemicals in the work area.
- The contents of the written Hazard Communication Program and how to access it.
Formal Employee Training
Employees must receive formal training on:
- Methods and observations used to detect the release of hazardous chemicals.
- The hazards of the chemicals in the work area.
- Procedures and equipment neccessary to protect themselves from chemical hazards.
- Details of the company hazard communication program.
Note: Watching a video or completing an online course will not, by itself, meet the requirements for Hazard Communication Training. It must include a workplace specific training and evalution.
Step 6 - Evaluate and Reassess
Review the Effectiveness of the Company Hazard Communication Program
Once the Hazard Communication Program has been implemented, the Hazard Communication Coordinator should periodically review the program for effectiveness.
Here are some items to check:
- Chemical inventory is current.
- All chemicals in the workplac are labeled.
- Employee understanding of the company hazard communication program.
- Safety Data Sheet storage is current.
- Employees have access to SDSs.
- Review any chemically related workplace accidents for possible program improvements.