OSHA Hazard Communication Standard and Program

When the Hazard Communication Standard (HCS) was published by OSHA in 1983, it represented a decade of painstaking, but vital, rulemaking activity.

More than thirty years have elapsed since the rule was published. And yet, HCS remains one of the most important and relevant US occupational safety and health standards. The Hazard Communication Standard (29 CFR 1910.1200), last updated in 2012 for GHS alignment, applies to a wide spectrum of workplaces and industries, and is considered one of the crown jewels in OSHA’s mission to protect workers on the job.

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Background of the Hazard Communication Standard

The HCS is also called the Right-to-Know Law, as the intent of the Standard was to ensure workers had the legal right to know about chemical hazards in their workplaces. Prior to the HCS, employees often worked with chemical substances without information on how to avoid health and safety hazards. Lacking this knowledge, employees frequently had serious acute chemically-related injuries, and were unaware of long-term effects, such as cancer-causing chemical products, found on the job.

The law was a breakthrough in workplace safety, as it required chemical manufacturers and employers to relay chemical hazard information to employees. Apart from minor amendments through the years, there were no major revisions to the HCS. But, in 2012, OSHA made changes to modify the HCS to align with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

The GHS-aligned HCS (or HazCom 2012) does not impact the framework or scope of the “old” HCS, but it does help ensure consistency in conveying chemical information to workers. OSHA has stated about the alignment with GHS, “The Standard that gave workers the right to know, now gives them the right to understand.”

The GHS update allows for a more streamlined and consistent language in communicating hazards, which really does give workers and employers a better opportunity to understand chemical hazards. And as it builds upon the existing HazCom framework, the transition has been fairly easily for employers.

What is the Hazard Communication Framework?

Under the HazCom standard, a multi-pronged approach is used to convey chemical information to workers.

These include hazard information from chemical manufacturers, a written Hazard Communication program, safety data sheets, and Hazard Communication training for employees, each of which is described more closely below.

Hazard Information from Chemical Manufacturers

Chemical manufacturers and importers of chemicals have requirements under the HCS to examine their products for hazards and then provide information on those hazards. Previously these entities were required to evaluate the hazards of their products, but often that was a fuzzy and confusing process, with no governing or clear methodology for evaluation.

Now, under provisions of the newly aligned HazCom 2012, chemical manufacturers must classify health and physical chemical hazards according to the GHS criteria set forth in the Standard (Appendices A and B of 1910.1200).

Then they must convey the hazard information downstream to those that purchase or use their chemical substances. Manufacturers and importers of these products provide this hazard information via labels on product containers and through safety data sheets.

This sample from our online Hazard Communication training course explains the different parts of an SDS.

Under HazCom 2012, these manufacturer’s labels and safety data sheets now follow a consistent format, which is composed of various pictograms, signal words and precautionary statements to identify hazards, as well as uniform language and format.

The GHS-compliant Hazard Communication chemical label elements are illustrated in the sample from our online Hazard Communication training course below.

Written Hazard Communication Program

Employers have several responsibilities to relay chemical hazards to workers under the HCS, among these requirements is a Written Hazard Communication Program. (Note: A binder stuffed full of nothing but safety data sheets is not sufficient to meet the obligations of this part of the Standard. The Written Hazard Communication Program is far more than that.)

This sample from our online Hazard Communication training course goes over the requirements.

Detailed explanations can be found in 1910.1200(e). But in general, the program consists of policies which describe how the employer will meet the requirements of the Hazard Communication Standard. An inventory list of the chemicals found in the workplace should be included in the written program, along with policies that cover the methods the employer will use to meet employee training, secondary container labeling, and other obligations under the Standard.

In addition, non-routine tasks that expose employees to chemical hazards, and the ways employers will use to inform employees of those hazards, is to be included in the written program.

If you have a multi-employer workplace, such as employees of a construction contractor working at your company, and there is a chance that those other employees may be exposed to your chemical hazards, you’ll need to cover that in the HCS written program. How will you provide those other employees information about your company’s chemical hazards and access to your safety data sheets? And what precautions do they need to take under normal working conditions and foreseeable emergencies when working at your company? These should be answered in your HCS written program.

And finally, like written programs for other standards, the HCS written program should be available to employees upon request, as well as available to OSHA, if they come calling. (In fact, it is usually one of the first programs OSHA asks for if they perform an inspection.)

Safety Data Sheets

Prior to the HazCom 2012, these were called, “material safety data sheets” or MSDS. To be sure, MSDS contained ample chemical information on fire, spill and first aid response, as well as the hazards of the chemical and necessary PPE, but they were not uniform in language or construction. It was often very challenging to read MSDSs and rapidly grasp any vital hazard information—especially during a chemical emergency.

The provisions of the HazCom 2012 alignment require these to be uniform, in a neatly and easily decipherable 16-section format, which uses consistent language. For example, hazard information is clearly laid out in Section 2, which is quickly found by anyone examining the document.

With the 2013 HazCom alignment, OSHA changed the name of these to, “Safety Data Sheets” or SDS. (That is probably the most confusing part of the entire Standard update, as many of us still want to say, “MSDS.”)

This sample from our online Hazard Communication training course explains the different parts of an SDS.

As noted earlier, SDS are created by chemical manufacturers, but employers must keep a copy for each hazardous chemical in the workplace. According to the Standard, employees must have access to these at any time throughout their shift. If you opt to keep your SDS digitally, the standard allows for that--as long as all employees can obtain them without any barriers, such as passwords on computers preventing access.

OSHA is very straightforward about this requirement, stating, “The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s).

Hazard Communication Training

The HazCom Standard requires the employers provide “effective information and training” on hazardous chemicals in their work area. Employers have a significant responsibility in this regard, as Hazard Communication training is one of the primary methods to keep workers safe during the use, handling and storage of chemicals.

If employees aren’t properly made aware of the workplace chemical hazards, disastrous consequences can occur. Your HazCom training, therefore, should be very thorough.

OSHA has a rather comprehensive list pertaining to HCS training requirements, which include:

• Requirements and purpose of the Hazard Communication Standard.
• Operations in the employees’ work areas where hazardous chemicals are present.
• Location, purpose and availability of the Written Hazard Communication Program, as well as the list of hazardous chemicals, and SDS.
• How to detect releases or presence of hazardous chemicals in the work area (such as odor, appearance of fumes or mist).
• The physical and health hazards of chemicals found in the workplace, including hazard classifications, and associated pictograms, signal words, and terminology.
• Measures employees can use to protect from chemical hazards, such as PPE, ventilation, administrative or engineering controls, etc.
• Details and explanation of labels on shipped containers, workplace labeling and SDS.

HCS training is to be given to workers at the time of their initial assignment, and if new chemical hazards are found in the workplace that were not addressed in previous training. Retraining is also given when a worker has exposure to new chemical hazards through a change in job duties or work area.

The Hazard Communication Standard was built with an excellent foundation through providing information and training to workers. Now enhanced by the 2012 alignment with the GHS, the ease and function of the Standard have been increased. Understanding the Standard and its updates, is vital to putting this into practice in your workplace.

As you can see from the list above, comprehensive training is necessary to meet the requirements of the Standard, as well as protect your workers from chemical hazards.

This online hazard communication training course is a good addition to your employee HazCom training program.

In addition to everything written above, you may also find these Haz-Com related articles helpful:

• GHS Label Requirements, Symbols, and Classifications
• Who Has Hazard Communication Duties on the Job?