OSHA first established the Hazard Communication Standard (HCS) on November 25, 1983; and with its complexity, it is often one of the most misunderstood of the agency’s standards and the one most frequently cited for violations. The core concept for the rule is “that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring.”
The HCS requires that both the physical and health hazards be communicated for all hazardous chemicals. Since the majority of chemicals used in the workplace have some hazardous consequences, they will be included in this mandate.
The communication paradigm begins with chemical manufacturers and importers. They are required to evaluate the hazard potential of the chemicals they produce or import. This information becomes the basis for labels they prepare for containers, and for the more detailed specification sheets called Material Safety Data Sheets (MSDS). Chemical manufacturers, importers, and distributors of hazardous chemicals are obliged to provide the labels and material safety data sheets to the purchasers of these chemicals.
Any workplace in which employees are exposed to hazardous chemicals must have a written plan, which describes how the communication standard is being carried out. OSHA is not looking for something that is lengthy and convoluted. An inspector wants to see a realistic system for meeting the requirements for labeling, accessibility of material safety data sheets, and employee training.
To comply with the labeling provision of the rule, employers can make use of the labels provided by their suppliers. The information specified on the label must include the name of the material and any possible physical or health hazards associated with its use. Labels must be easy to read, and prominently displayed. OSHA doesn’t mandate any specific requirements in terms of size, color or text.
If an employer transfers the hazardous chemical from a labeled container to another container, the employer is required to label the second container unless it is subject to the portable container exemption. To be considered portable, the container must be used for the immediate transfer of hazardous chemicals from labeled containers, and the employee who performs the transfer will be the only one to use it.
The purpose of the Material Safety Data Sheets (MSDS) is to provide detailed information about a chemical’s potential hazardous effects, its physical and chemical characteristics, and recommendations for protecting oneself when using it. OSHA doesn’t specify a format for the MSDS.
All MSDSs must be easily accessible to employees during their shifts. OSHA does not mandate the methodology for accomplishing this. Any methodology is acceptable as long as it meets the principal standard that employees can get the information when they need it.
If you plan to conduct your own hazard communication training, you may want to investigate Training Requirements in OSHA Standards and Training Guidelines, which was developed by OSHA’s Training Institute. You can get a copy from the Superintendent of Documents, Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-7954.
After designing your hazard communication strategy, give it the acid test for compliance by seeing if it meets the following OSHA checklist:
• Obtain a copy of the rule
• Read and understand the requirements
• Assign responsibility for tasks to a specific employee
• Prepare an inventory of chemicals
• Ensure that containers are labeled
• Obtain an MSDS for each chemical
• Prepare a written program
• Make MSDSs available to workers
• Conduct training
• Establish procedures to maintain current program
• Establish procedures to evaluate effectiveness