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The Safety & Health Consultation Program
GUIDEANCE FOR HAZARD COMMUNICATION STANDARD
Table of Contents
CHANGES to OSHA’s HAZARD COMMUNICATION PROGRAM 2
Figure 1: Sample Label 3
Figure 2: Pictograms 4
Figure 3: Safety Data Sheet 5
HAZARD COMMUNICATION PROGRAM TEMPLATE 6
1. GENERAL INFORMATION 6
A. Container Labeling 6
B. Safety Data Sheets (SDSs) 6
C. Employee Training and Information 7
2. LIST OF HAZARDOUS CHEMICALS 8
3. HAZARDOUS NON-ROUTINE TASKS 8
4. INFORMING CONTRACTORS 8
EMPLOYER COMPLIANCE PROGRAM 10
HAZARD COMMUNICATION TRAINING DOCUMENTATION 12
This document is intended to aid companies in the development and implementation of a written hazard communication program in compliance with the OSHA Hazard Communication Standard, 29 CFR 1910.1200. Within this document is a summary of recent major changes to the Hazard Communication Standard and a program template modified to reflect the recent changes. This program template must be adapted to address the specific hazardous chemicals and processes used at a specific facility. The program must be administered by a suitably trained program administrator. After the policies described in the hazard communication program have been developed, they must be implemented, maintained, and enforced.
CHANGES to OSHA’s HAZARD COMMUNICATION PROGRAM
The U.S. Occupational Safety and Health Administration (OSHA) issued its final revisions to the Hazard Communication Standard on March 20, 2012, aligning it with the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. The alignment with GHS will mean changes for U.S. companies that produce, transport or handle chemicals, including different language in safety data sheets (previously called Material Safety Data Sheet (MSDS)) and safety labels. The rule also will create a new category for “hazards not otherwise classified,” which includes combustible dust.
The final rule will be phased in over a period of time, and facilities will have until June 2016 to fully comply with the rule. Employers will have to update their safety data sheets (SDS) when new ones become available, provide training on the new label elements and update their hazard communication programs if new hazards are identified.
Below is a list of the deadlines for full implementation of the revised Hazard Communication Standard:
Dec. 1, 2013–Employers must have finished training employees on new label elements and SDS format.
June 1, 2015–Chemical manufacturers, importers, distributors and employers must comply with all modified provisions of the final rule. Distributors may continue to ship products labeled under the old system until Dec. 1, 2015.
June 1, 2016–Employers must update alternative workplace labeling and hazard communication programs as necessary and provide additional employee training for newly identified physical or health hazards.
During the transition period, the final, current or both standards may be followed.
Major changes to the Hazard Communication Standard:
Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. (See Figure 1: Sample Label) As of June 1, 2015, the Hazard Communication Standard (HCS) will require pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification. (See Figure 2: Pictograms)
Safety Data Sheets: Material Safety Data Sheets (MSDS) renamed to just Safety Data Sheets or SDS. The new SDS is required to be in a uniform format, and include the section numbers, the headings, and associated information under the headings below: (See Figure 3: Safety Data Sheet)
Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.
For more information, please go to OSHA’s website:
Figure 1: Sample Label
Figure 2: Pictograms
Figure 3: Safety Data Sheet
Identification: includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
Hazard(s) identification: includes all hazards regarding the chemical; required label elements.
Composition/information on ingredients: includes information on chemical ingredients; trade secret claims.
First-aid measures: includes important symptoms/ effects, acute, delayed; required treatment.
Fire-fighting measures: lists suitable extinguishing techniques, equipment; chemical hazards from fire.
Accidental release measures: lists emergency procedures; protective equipment; proper methods of containment and cleanup.
Handling and storage: lists precautions for safe handling and storage, including incompatibilities.
Exposure controls/personal protection: lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
Physical and chemical properties: lists the chemical's characteristics.
Stability and reactivity: lists chemical stability and possibility of hazardous reactions.
Toxicological information: includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
Other information, includes the date of preparation or last revision
HAZARD COMMUNICATION PROGRAM TEMPLATE
1. GENERAL INFORMATION
To ensure that information about the dangers of all hazardous chemicals used by (Name of Company) is known by all affected workers, the following Hazard Communication Program has been implemented. All work areas that involve potential exposure to chemicals are included within this program. The written program will be available in the (Location) for review by any interested employee.
A. Container Labeling
The (Person/Position) will verify that all containers received for use will be clearly labeled in accord with the OSHA requirements including:
A product identifier;
Signal word; and
Precautionary statements; as well as
The name and address of the supplier.
The (Person/Position) in each work area will ensure that all secondary containers are labeled with either an extra copy of the original manufacturer's label or an alternative workplace label. Labels of secondary containers must be marked with, at minimum, a product identifier and words, pictures, symbols or combination thereof identifying the hazards of the chemicals. For help with labeling, please see (Person/Position).
(If written alternatives to labeling of in-plant containers are used, add a description of the system used.)
The (Position/Person) will review the company's labeling system and update the system as required. This review will occur every (Provide schedule).
B. Safety Data Sheets (SDSs)
The (Position/Person) will be responsible for establishing and monitoring the SDS system for the company. (Position/Person) will review in-coming data sheets for new and significant health/safety information. He/she will see that any new information is passed on to the affected employees, and will initiate any needed changes in workplace practices.
Copies of SDSs for all hazardous chemicals to which employees of this company may be exposed will be kept in (Location) and (Location).
SDSs will be available to all employees in their work areas for review during each work shift. (If alternatives to SDSs are used, provide a description of the format used and how workers can access the SDSs.)
If SDSs are not available, contact (Position/Person).
If an SDS is not received at the time of initial shipment, the procedure below will be followed: (describe procedure to follow here).
When revised SDSs are received, the following procedures will be followed to replace old SDSs: (describe procedures).
If a chemical is no longer used, or if a chemical formulation changes requiring an updated SDS, the employer will archive and maintain the old SDSs for 30 years in order to comply with the OSHA standard 1910.1020, Access to employee Exposure and Medical Records.
Please note: Employers must replace their MSDSs with OSHA compliant SDSs as they become available: all SDSs should be compliant by June 1, 2015. All labels, the written hazard communication program, and training must be updated to comply with the revised Hazard Communication Standard by June 1, 2016.
C. Employee Training and Information
(Person/Position) is responsible for the employee training program. He/she will ensure that all elements specified below are carried out.
As of December 1, 2013, all current employees have been trained on new label elements and SDS format as outlined in the revisions of the Hazard Communication Standard.
Prior to starting work, each new employee of (Company) will attend a health and safety orientation and will receive information and training on the following:
An overview of the requirements contained in the Hazard Communication Standard, 29 CFR 1910.1200;
Chemicals present in their workplace operations;
Location and availability of our written hazard program;
Physical and health effects of the hazardous chemical;
Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area;
How to lessen or prevent exposure to these hazardous chemicals through usage of control/work practices and personal protective equipment;
Steps the company has taken to lessen/prevent exposure to these chemicals.
Emergency procedures to follow if they are exposed to these chemicals;
Location of SDS file and location of hazardous chemical list;
Details of the company’s hazard communication program, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.
Until full implementation of the updated OSHA requirements has been achieved, all employees must be trained on both existing labels and updated labels, and how to read and understand both MSDSs and SDSs.
After attending the training class, each employee will sign a form to verify that they attended the training, received our written materials, and understood this company's policies on Hazard Communication. (This is an optional item which OSHA recommends for the employer to use to track employee training.)
Before a new chemical hazard is introduced into any department of this company, each employee of that department will be given the hazard communication information outlined above. (Person/Position) is responsible for ensuring that SDSs on the new chemical(s) are available.
2. LIST OF HAZARDOUS CHEMICALS
A list of all known hazardous chemicals in the workplace is attached to this program. The hazardous chemical inventory is compiled and maintained by (Person/Position). This inventory list includes the name of each chemical and the work area(s) in which each of the chemicals is used. When new chemicals are received, this list is updated within (x) days of introduction into the workplace. To ensure that any new chemical is added in a timely manner, the following procedures shall be followed: (describe procedures to be followed).
3. HAZARDOUS NON-ROUTINE TASKS
Periodically, employees are required to perform non-routine tasks that are hazardous. Examples of non-routine tasks are: confined space entry, tank cleaning, and painting reactor vessels. Prior to starting work on such projects, each affected employee will be given information by (Person/Position) about hazardous chemicals to which they may encounter during such activity.
This information will include:
Specific chemical hazards;
Protective/safety measures the employee should use;
Measures the company is taking to lessen the hazards, including ventilation, respirators, the presence of another worker, and emergency procedures.
The following are the non-routine tasks performed by the employees of this company, and the hazardous chemicals associated with that task, and the safety measures to take:
Task Hazardous Chemicals Safety Measures
4. INFORMING CONTRACTORS
It is the responsibility of (Person/Position) to provide contractors and their employees (including temporary workers) with the following information prior to work being started:
Hazardous chemicals to which they may be exposed while on the job site;
Precautionary measures employees may take to reduce the possibility of exposure;
SDSs of the hazardous chemicals generated by our company’s operations;
Hazard labels used by our company, including alternative workplace labeling when used.
(Person/Position) will be responsible for contacting each contractor before work is started at the company to gather information concerning the chemical hazards that the contractor is bringing to our workplace. This hazard information will be provided to all employees at the company who may be exposed to these chemicals.
EMPLOYER COMPLIANCE PROGRAM
Employer Checklist for Hazard Communication Program Requirements
The key elements that each employer must implement are a written program, employee training, and record availability and storage.
A. THE WRITTEN HAZARD COMMUNICATION PROGRAM
Have you prepared a written list of all the hazardous chemicals present in the workplace?
Are you prepared to update your hazardous chemical list?
Do you have up-to-date Safety Data Sheets (SDSs) for those materials on your hazardous chemical list?
Is the list of hazardous chemicals cross-referenced so that identifiers on the list refer to the SDSs and warning labels?
Have you developed a system to ensure that all incoming hazardous chemicals are received with proper labels and SD sheets?
Do you have procedures in your workplace to ensure proper labeling or warning signs for bulk storage or secondary usage containers that hold hazardous chemicals?
Do you have a complete list of the chemical hazards and precautions that you can give to outside contractors?
Do you have written procedures on how you will inform your employees of the chemical hazards associated with unlabeled pipes?
Have your employees been informed of the hazards associated with performing non-routine tasks (i.e., confined space, repair and maintenance operations)?
Is your hazard communication program in writing and accessible to your employees during their work shift?
B. INFORMATION AND TRAINING
Have you developed an employee information and training program which includes the following:
Does the training cover all types of harmful chemicals with which the employee may come into contact under normal usage and foreseeable emergency?
Are your workers familiar with the different types of chemicals and the major hazards associated with them (i.e., solvents, corrosives)?
Are your employees aware of the specific requirements of the Hazard Communication Program?
Does your program train employees in:
operations where hazardous chemicals are present;
location and availability of your written hazard communication program, including lists of chemicals and SDSs?
Does your training program include the explanation of labels and warnings that have been established in their work areas?
Do your employees understand methods to detect presence or release of chemicals it the workplace?
Does your training program provide information on the appropriate first-aid procedures in the event of an emergency?
Are employees trained in the proper work practices and personal protective equipment in relation to the hazardous chemicals in the work area?
Does the training include explanation of the labeling system and SDSs the employee can obtain and use?
Have you worked out a system to ensure that new employees are trained?
Have you developed a system with purchasing or other staff to make sure that additional training is provided if a new hazardous substance is introduced into the work area?
Do you have a system to ensure that the current (up-to-date) SDSs are in work areas where the chemicals are used?
HAZARD COMMUNICATION TRAINING DOCUMENTATION
Summary of training:
An overview of the requirements contained in the Hazard Communication Standard, 29 CFR 1910.1200;
How to read labels and review SDSs to obtain hazard information;
Location of SDS file and location of hazardous chemical list.
Hazard Communication: Training Documentation Page 12PLIANCE PROGRAM
Does your training program include the explanation of labels and warnings