Six Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals

Employers that use hazardous chemicals in their workplaces are required by OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a written hazard communication program, outlining procedures for labeling of hazardous chemical containers, use of safety data sheets (SDSs) for hazardous chemicals, and appropriate hazard communication training to all workers who handle hazardous chemicals.

Employers can implement an effective hazard communication program by following these six steps:

  1. Learn the Standard and Identify Responsible Staff – Employers that use hazardous chemicals should review OSHA’s Hazard Communication Standard in order to obtain a detailed understanding of OSHA’s hazard communication requirements.  After determining what is required for compliance to the OSHA Standard, a manager or qualified employee should be assigned responsibility for overall coordination and implementation of the hazard communication program.
  2. Prepare and Implement a Written Hazard Communication Program – A written plan indicating how hazard communication will be addressed will help ensure that compliance with the standard is done in a systematic and coordinated way.  Employers are also required to maintain a list of all hazardous chemicals known to be present in the workplace.
  3. Ensure Containers are Labeled – Chemical manufacturers and importers are required to provide labels on shipped containers to ensure that employers receive properly labeled hazardous chemicals.  Employers may use the same supplier label or may label workplace containers using third party systems, such as the National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS).  Any container of hazardous chemicals in the workplace must at a minimum include the product identifier and general information concerning the hazards of the chemical.
  4. Maintain Safety Data Sheets (SDSs) – Safety Data Sheets are the source of detailed information on hazardous chemicals.  Employers must maintain copies of SDSs for all hazardous chemicals present in their workplaces and must ensure that SDSs are readily accessible to workers in their work areas during their work shifts.
  5. Inform and Train Employees – Employers are required to train employees on the hazardous chemicals in their work area in a manner and language that employees can understand before their initial assignment and when new hazards are introduced into the work area.  Workers should know that labels and Safety Data Sheets can provide them with information on chemical hazards and should understand how to access them.  Workers must also be aware of the protective measures available in their workplace, how to use or implement these measures, and whom they should contact if issues arise.
  6. Evaluate and Reassess Your Program – Although the HCS does not require evaluation and reassessment of hazard communication programs, it is essential for employers to review their programs periodically to ensure their effectiveness and to make revisions as appropriate to address changed conditions in the workplace, such as new chemicals, new hazards, etc.

Additional information on the Hazard Communication Standard can be found on OSHA’s Hazard Communication webpage and by consulting the OSHA Fact Sheet on Steps to an Effective Hazard Communication Program.

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