OSHA HAZARD COMMUNICATION STANDARD
SUMMARY & COMPLIANCE
Table of Contents (update 09/22/14 - dls)
II. The Standard
III. Hazardous Materials
IV. Written Program
XI. Program Elements
The Hazard Communication Standard (HCS), sometimes called the Right to Know law or HazCom, is a set of regulations first promulgated in 1988 by the Office of Occupational Safety and Health Administration (OSHA). It has been adopted by and is enforced by New Mexico OSHA. HCSs purpose is to ensure that the hazards of workplace chemicals are evaluated, and that information on the hazards is provided to employers and employees. Details of the Standard are provided in parts 1910.1200 of the Code of Federal Regulations (CFR) of Chapter XVII of Title 29 under the Department of Labor (a.k.a. 29CFR1910.1200). HCS covers nearly all employers and is applicable to most work operations where hazardous materials are present.
In short, the Standard requires that every effected employer establish a program to tell employees of the hazards associated with the materials in their workplace. The program must have five main components as follows:
Sometimes people think of "chemicals" as being only liquids in containers. The HCS covers chemicals in all physical forms - liquids, solids, gases, vapors, fumes, and mists - whether they are "contained" or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If it is hazardous and there is potential for exposure, the rule applies. So it covers many items, e.g. from floor cleaners, fuels, welding rods (toxic fumes), paints and adhesives (poisons) to compressed gases and concentrated acids.
Under the standard each employer (and/or department) must complete and keep a written Hazard Communication Program. The written program describes how the requirements for labels and other forms of warning, material safety data sheets (MSDSs), and employee information and training, are implemented in the workplace. It indicates who is responsible for MSDSs, labels, warning signs and training, as well as the location of the inventory, MSDSs, and other information and resources pertaining to hazardous chemicals and safety measures. An inventory list of hazardous chemicals is required to be maintained as part of the written program. A copy of NMSU written program is available at NMSU office of Environmental Health and Safety (EH&S aka the Safety Office) or can be viewed via the following web link: http:\\www.nmsu.edu\~safety\programs\chem_safety\hazcom_written_program.htm .
Look around. In order to know how to protect yourself you need to know about the hazards. If you have chemicals under your control, you or a designated individual must make an inventory of the hazardous chemicals. Identify chemicals in containers, including pipes, but also think about chemicals generated in the work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Read labels provided by suppliers for hazard information. Make a list of all chemicals in the workplace that are potentially hazardous. You need to note the typical maximum quantity, its location within the workplace, and where the MSDS for the material will be kept (see example). The HazCom Inventory is to be updated as new chemicals are brought into the workplace and a copy from each department is to be provided annually to NMSU EH&S office (more information) .
The role of the MSDS is to provide detailed information on each hazardous chemical, including its potential hazardous effects, its physical and chemical characteristics, and recommendations for appropriate protective measures (see attached example). This information is useful for designing protective programs, as well as informing the chemical user of the hazards. MSDSs must be readily accessible to users when they are in their work areas. Some departments keep the MSDSs in a binder in the individual work area or in a central location in the department.
Manufactures and distributors are responsible for ensuring that their customers are provided MSDSs. Employers must have an MSDS for each hazardous chemical that they use. The MSDS must be in English. You are entitled to receive a data sheet from your supplier, which includes all of the information required under the rule. If you do not receive one automatically, you should request one. If you receive one that is obviously inadequate, with, for example, blank spaces that are not completed, you should request an appropriately completed one. Employees should not use or be exposed to any chemicals for which the safety data have not been reviewed and appropriate safety measures implemented. Employees may contact EH&S for assistance in such matters.
Containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings. The original label must include the identity of the material, appropriate hazard warnings, and the manufacture name and address. The identity used by the supplier may be a common or trade name ("Black Magic Formula"), or a chemical name (1,1,1, -trichloroethane). The hazard warning is a brief statement of the hazardous effects of the chemical ("flammable," "causes lung damage"). Labels frequently contain other information, such as precautionary measures ("do not use near open flame"). Labels must be legible and prominent.
Secondary Containers Labels and Signs
If materials are transferred from the original container into other containers, these must be labeled as well. Depending on the employers written plan, the secondary labels may be warning symbols, text, or use a numerical hazard rating systems such as the NFPA system (see attached). Large containers or storage units containing hazardous chemicals or mixtures must also be labeled or have warning signs. It is strongly recommended that other warning or caution signs be placed in the work areas to remind individuals of the hazards and of the protective equipment that may be necessary in the area.
Each employee who may be "exposed" to hazardous chemicals when working must be provided information and trained prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes. "Exposure" or "exposed" under the rule means "an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.) and includes potential (e.g., accidental or possible) exposure."
As an employee working with hazardous chemicals, you must receive training and information on the hazard communication standard, on MSDS and labels, and protective measures. If you have others working for you, then you are responsible to provide or arrange similar training for them and otherwise comply with the program.
Information and training may be done either by individual chemical, or by categories of hazards (such as flammability or carcinogenicity). If there are only a few chemicals in the workplace, then you may want to discuss each one individually. Where there are large numbers of chemicals, or the chemicals change frequently, you will probably want to train generally based on the hazard categories (e.g., flammable liquids, corrosive materials, carcinogens). Employees must have access to the substance-specific information on the labels and MSDSs.
The underlying purpose of the HCS is to reduce the incidence of chemical source illnesses and injuries. In general, the most important aspects of training are to ensure employees are aware that they are exposed to hazardous chemicals, that they know how to read and use labels and material safety data sheets, and that, as a consequence of learning this information, they are following the appropriate protective measures (e.g. personal protective equipment, safe procedures, engineering controls).