OSHA Publishes Hazard Communication Guidelines for Employers That Use Hazardous Chemicals

As part of an ongoing campaign to help small employers comply with the Occupational Safety and Health Administration’s Hazard Communication Standard (HCS), OSHA recently published Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals to specifically address employer responsibilities under the HCS.  Since many of the provisions of the HCS apply only to chemical manufacturers, importers, or distributors, this guide focuses on assisting employers that use rather than produce chemicals in order to identify the parts of the rule that apply to their facilities and help them develop and implement an effective hazard communication program.

The HCS incorporates what is referred to as a downstream flow of informationfrom chemical manufacturers, importers and distributors, to employers.  The standard requires chemical manufacturers, importers and distributors to classifythe hazards of the chemicals they produce, import or distribute, and to prepare appropriate labelsand safety data sheets(SDSs) to convey the hazards, as well as recommended protective measures.

The HCS requires employers to make sure that all chemicals received from their suppliers are appropriately labeled with accompanying safety data sheets.  In order to protect workers from health hazards, such as carcinogenicity and sensitization, and physical hazards, including flammability and reactivity properties, employers need the detailed chemical hazard information and recommended protective measures contained on labels and SDSs.  Workers have both a right and a need to know this information so that they can take steps to protect themselves when necessary.

The Small Entity Compliance Guide outlines employer requirements under the HCS to establish a hazard communication program, provide workers with access to labels and SDSs, and inform and train workers.  The Guide provides a detailed program for implementing an effective hazard communication program in six steps, including:

  1. Learn the Standard and Identify Responsible Staff
  2. Prepare and Implement a Written Hazard Communication Program
  3. Ensure Containers are Labeled
  4. Maintain Safety Data Sheets
  5. Inform and Train Employees
  6. Evaluate and Reassess Your Program

OSHA believes that the Hazard Communication Standard is of critical importance to ensuring that hazardous chemicals are identified, and that proper measures are implemented in workplaces to achieve safe use and handling. By understanding chemical hazards and using available information to implement the proper control measures to address these hazards, employers can maintain compliance with the HCS as well as protect their exposed workers.

Additional information on the Hazard Communication Standard can be found on OSHA’s Hazard Communication webpage and by consulting OSHA’s Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals.

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