OSHA HAZARD
COMMUNICATION STANDARD
SUMMARY & COMPLIANCE

Introduction

The Hazard Communication Standard, oftern called HazCom or employee Right to Know law, 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.  The Standard's 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.  

The Standard

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:

1. Written Hazard Communication Program documentation,
2. Identifying and keeping an inventory of hazardous chemicals,
3. Obtaining and keeping material safety data sheets on the identified hazards,
4. Ensuring that the hazardous materials are labeled with name and hazard, and
5. Training employees on the standard, safety information, labeling and protective measures.

Hazardous Chemicals/Materials

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.  

Written Program

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 Environmental Health and Safety or can be viewed via the following web link: http:\\www.nmsu.edu\~safety\programs\chem_safety\hazcom_written_program.htm .

Chemical Inventory

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 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.  The template for the chemical inventory can be accessed at the following web address: http:\\www.nmsu.edu\~safety\programs\chem_safety\hazcom_inv_instruct_sheet.htm .

Material Safety Data Sheets (MSDS)

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   Environmental Health and Safety for assistance in such matters.

Labels

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 example).  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. 

Exposure

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."

Employee Information and Training

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).

NMSU Compliance with the
Hazard Communication Standard

Purpose

To ensure the hazards of chemicals used or present at NMSU are communicated to affected employees.

Scope

NMSU will provide information about hazardous chemicals to all employees, that are (or may be) exposed to these hazards in the workplace.  Communications of the hazards and the necessary protective measures are accomplished through the following program elements:

1. Written Hazard Communication Program,
2. Hazardous materials inventory
3. Material safety data sheets (MSDSs),
4. Labels and other forms of warning,
5. Information and training.

Program Elements

A.  Written Hazard Communications Program

NMSU has a written Hazard Communication Program maintained by EH&S.  Subsidiary programs are established and coordinated at various departments, which use hazardous chemicals on a regular basis for research, teaching or maintenance.  The written program is available during normal business hours at the EH&S offices and in departments with a subsidiary program. A model written program is available at EH&S and on the NMSU web.

B.  Hazardous Materials Inventory

As established, each department will prepare and keep an inventory of material hazards in their work areas or under their control.  The list of the hazardous chemicals in each department will be kept at the department and a copy placed in a master chemical inventory kept at EH&S.  The departmental lists shall be updated as the usage of hazardous chemicals changes and a copy provided at least annually for the master inventory. 

C.  Material Safety Data Sheets (MSDSs)

As part of the purchase agreement, all chemical suppliers to NMSU are required to provide an MSDS for their hazardous products.  Each department must maintain a MSDS copy for chemicals being used in their facilities.  Supervisors or a designated individual must ensure that MSDSs are readily available during each work shift to employees when they are in their work areas.

D.  Labels

Hazardous chemicals shall be obtained with original labels with the following:

• Identity of the chemical (common, technical name, or primary components),
• Hazard warning (flammable, corrosive, poison, etc.),
• Name and address of the chemical manufacturer (if provided by manufacture).

Department supervisors must ensure that the container original labels are not defaced.  If the labels become damaged the supervisor must ensure the label is replaced.  When a hazardous chemical or material is transferred into a secondary container, the secondary container and/or container enclosure must be labeled with the identity of the chemical and the hazard warning using the NFPA warning system or equivalent (see example)

E.  Employee Information and Training

NMSU supervisors and EH&S will provide employees with information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard is introduced into their work area. In addition to the elements of the Hazard Communication Standard and NMSU Hazcom Program, each effected employees shall be trained on:

• Any operation or location in their work area where hazardous chemicals are present.
• Definitions and information provided on MSDSs as well as the availability of other sources of information on hazardous materials (see information on MSDSs).
• Methods and observations that may be used to detect the presence or release of a hazardous chemical(s) in the work area (such as visual inspection, odor, monitoring devices, etc.)
• The physical and health hazard of the chemical, including protective measures used to protect the employee from exposure.  The may include personal protective equipment (PPE) such as safety eyewear, laboratory coats, tyvek suits, respirators, etc.  (OSHA requirements on personal protective equipment is outlined under policy and requirements.)
• An explanation of the labeling system such as the NFPA system for secondary container.

Non-routine tasks involving hazardous chemical will require additional information and training prior to implementing such tasks.  This includes hazards associated with chemicals contained in unlabeled pipes.  Training documentation will be kept with the written program and/or by workplace supervisors  EH&S provides classes on the Hazard Communication Standard requirements and the departmental supervisors provide information to supervised employees on the specific chemical hazards in the work areas.