Hazard Communication Program covers all employees exposed to or working in areas where hazardous chemicals are used or stored, as established by Federal Regulation at 29 CFR Part 1910.1200 and who are not covered by the Laboratory Standard, 29 CFR 1910.1450.
According to OSHA, there is a standard that provides the requirements for communicating the hazards of chemical substances to which workers are exposed, also known as Your Right to Know. The purpose of this standard is to ensure that the hazards of all chemicals handled are assessed and made known to all personnel.
What are the 5 key elements of a hazard communication program? It is made up of 5 parts: The Hazard Assessment, a Written (Communication) Program, MSDS, Labeling and Warnings, and Training.
- Hazard Assessment: A chemical manufacturer or importers must assess the hazards of the substance: what are those risks (health, environment, flammability, reactivity) and the degree of hazard of it. All this information is used to prepare the SDS (Safety Data Sheets) for each substance.
- Written Program: A written program must be established (and kept updated) that includes: List of ALL hazardous chemicals used, SDSs for each listed substance, labelling and warning system. This information will be used for training.
- Safety Data Sheets (SDS): It is the basic information of chemical substances have the following information: Name of the substance, list of ingredients (hazardous or not) that contain it, physical and chemical characteristics of the chemical ( boiling point, vapour pressure, etc.), physical dangers of the substance (fire, explosion, reactivity), dangers to the health of the chemical as well as the symptoms in case of being exposed and the way to care for the user, primary routes of entering the body (skin, nose, mouth), precautions for use, environmental aspects among other things (manufacturer data, contact, etc).
- Labelling and Hazard Warnings: The manufacturer and/or importer is responsible for ensuring that each container is properly labelled with the identity of the product. Some international codes and labels help with identification (UN code, pictograms, label shapes, colours, etc.).
- Training: It is the responsibility of the company that uses the chemical products to provide information and training to all personnel when there are new personnel, new risks in the substances are detected, a new chemical is used or when there is a related incident/accident.
Hazard communication program and GHS
The US Occupational Safety and Health Administration (OSHA) issues a proposed rule to update the standard. The US Department of Labor’s Occupational Safety and Health Administration (OSHA) has just issued a Notice of Proposed Rulemaking to amend the Hazard Communication Standard – HCS (1910.1200).
The new Hazard Communication Standard (HCS or HAZCom) requirements are also an attempt to maintain compliance with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) align certain provisions with Canada and other US agencies, and address issues that have developed since the standard’s 2012 implementation.
The basic regulatory framework of the HCS will remain the same, which implies that:
- Chemical manufacturers and importers are responsible for providing information on the identification of the chemicals they produce or import and the potential hazards associated with their use.
- All companies that use hazardous chemicals in their workplaces must have a hazard communication program and provide information to employees about their risks and associated protective measures.
The globally harmonized system
What is a globally harmonized system of classification and labelling of hazardous chemicals?
The Globally Harmonized System of Classification and Labeling of Chemicals, known as GHS (Globally Harmonized System ) is an international system, used in many countries to determine the dangers of chemical substances and alert users of these substances about their dangers, through labels and safety data sheets.
In 2012, US OSHA revised its hazard communication standard to adopt GHS and incorporate its labelling and reporting system. You must first determine the hazard class and hazard category of a chemical (primarily based on test data). Once a chemical’s classification has been determined, standard signal words, hazard pictograms, hazard statements, and precautionary statements will be assigned.
Over time, various countries have developed different labelling and safety data sheet production systems. These systems clashed in some respects. Some countries did not accept the requirements for the classification of chemical substances, for example, to decide if a substance is carcinogenic or dangerous for reproduction. Thus, a chemical might have been classified as hazardous for reproduction in one country and not in another.
With globalization, these differences have caused problems, due to the international transport of chemicals. Labels and safety data sheets from one country were not necessarily used in another. As a result, workers all over the world were confused or received erroneous or no information on this topic.
Work began in 1992 to create a uniform system throughout the world. Representatives of governments, companies, trade unions and international organizations participated in the development of a classification system for health and environmental hazards, and the communication system for these hazards. Regular meetings still take place to discuss the addition of new hazard classifications and other changes.
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Classification of chemical hazards
Physical Hazards(17 classes)
- Flammable Gases
- Oxidizing Gases
- Gases Under Pressure
- Flammable Liquids
- Flammable Solids
- Self-Reactive Substances
- Pyrophoric Liquids
- Pyrophoric Solids
- Self-Heating Substances
- Substances which, in contact with water emit flammable gases
- Oxidizing Liquids
- Oxidizing Solids
- Organic Peroxides
- Corrosive to Metals
- Desensitized explosives
Health Hazards(10 classes)
- Acute Toxicity (Oral/Dermal/Inhalation)
- Skin Corrosion/Irritation
- Serious Eye Damage/Eye Irritation
- Respiratory or Skin Sensitization
- Germ Cell Mutagenicity
- Reproductive Toxicology
- Target Organ Systemic Toxicity – Single Exposure
- Target Organ Systemic Toxicity – Repeated Exposure
- Aspiration Toxicity
Environmental Hazards(2 classes)
- Hazardous to Aquatic Environment (Acute/Chronic)
- Hazardous to the Ozone Layer
Hazcom GHS pictograms
The Globally Harmonized System of Classification and Labeling of Chemicals uses two sets of pictograms. One for occupational hazards and the other for the transport of dangerous goods.
Pictogram for transportation
Written Hazard Communication Program sample
All workplaces where employees are exposed to hazardous chemicals must have a written HCS plan that describes, in detail, how that facility will implement the standard. This plan does not have to be long or complicated; Think of it as a blueprint for implementing your program that ensures all requirements have been addressed in a systematic and coordinated manner.
OSHA recommends preparing this list using the product identifier (eg, product name, common name, or chemical name) to more easily track the status of SDSs and labels for a particular chemical. It is equally important that the product identifier is by the same name that appears on the label and SDS for that chemical.
The plan should also reflect what you are doing in the workplace and describe specific procedures for labelling containers; maintenance, management and implementation of SDS; and training employees. If an OSHA inspector visits your facility, one of the first things they may ask to see is your written plan, so this document must be always complete and up-to-date.
Have you prepared a written list of all hazardous chemicals present in the workplace?
- Are you ready to update your list of hazardous chemicals?
- Do you have current Safety Data Sheets (MSDS) for all materials that appear in your list of dangerous chemicals?
- Does the list of hazardous chemicals have an index/cross-reference for identifiers on the list to refer to the SDS and warning labels?
- Have you created a system that ensures that all incoming hazardous chemicals have warning labels and the SDS?
- Does your facility have procedures to ensure that bulk storage locations, secondary-use containers, and pipes containing hazardous chemicals are properly labelled and posted?
- Do you have written procedures for how you will inform your employees about the hazards of chemicals associated that have not been labelled?
- Do you have a complete list of chemical hazards and precautions that you can provide to outside contractors?
- Have your employees been informed of the hazardous substances?
- Is your hazard communication program written and available to your employees?
Safety data sheet
SDSs are required for all hazardous chemicals in the workplace and must be accessible to employees during work shifts. Traditionally, this has been accomplished by managing physical copies of the SDS in three-ring binders. However, a more modern and cost-effective method is to use an online software system that electronically manages these documents.
A good chemical management software solution stores SDSs in a secure, cloud-based library, making them easily accessible to your employees. The best solutions offer an online database of original manufacturer-indexed documents to help you track down and retrieve recently updated or missing SDSs, and are mobile-enabled so employees can access them no matter where they are, even from remote and offline locations.
OSHA’s alignment of the HCS standard with GHS introduced significant changes to the format of the SDS. Chemical manufacturers were required to update older MSDSs to the GHS-aligned SDS format and submit them with the first or next shipment of chemicals after the update.
If you received a shipment of chemicals on or after June 1, 2015, and it did not include an updated SDS, you should request it from the supplier immediately. OSHA expects you to have up-to-date SDSs for each hazardous chemical in your inventory, and if you don’t, you should be prepared to demonstrate your efforts to obtain them.
Hazard communication training
The use of chemicals and procedures should be reviewed. The training must include a list of materials, operations or production processes where chemicals are involved, physical and health risks, use of appropriate protective equipment for substances, how to read SDS, labels (how to interpret them) and codes, as well as what to do in case of exposure to the substance.
Information and Training: Have you created an information and training program that includes the following?
- Does the training cover all types of harmful chemicals with which the employee may come into contact under everyday use and unpredictable emergency?
- Are your workers familiar with the different types of chemicals and major hazards (ie, corrosives, soluble, etc.)?
- Are your employees aware of the specific requirements found in the Hazard Communication Program (HCP)?
- Does your program train employees in (a) operations where hazardous chemicals are present and (b) location and availability of written HCP including chemical lists and SDS?
- Does your training program include an explanation of the labels and warnings that have been placed on your work areas?
- Do your employees understand the methods to detect the presence or leak of chemicals in the workplace?
- Does your training program provide information on proper first-aid procedures in an emergency?
- Are your employees trained in proper work practices and personal protective equipment related to hazardous chemicals in the work area?
- Does the training include an explanation of the labelling system and MSDS which can be obtained and used by the staff?
- Have you developed a system to ensure that new employees are trained?
- Have you developed a system with purchasing or other personnel to ensure that additional training is provided in case a new chemical is introduced into the work area?
- Do you have a system that ensures up-to-date MSDS are in work areas where chemicals are used?
- If you learn of new hazards related to the chemical being used, do you have a system to notify employees?
ACKNOWLEDGMENT OF HAZARD COMMUNICATION TRAINING
By affixing my signature to this document, I acknowledge that I have received training related to Hazard Communication. I understand that this training meets the employee training requirements of the Communication Standard of OSHA Hazard. Classroom and on-the-job training include the following:
- A personal copy of the [name of company] Hazard Communication Plan.
- Understanding the purpose and scope of the OSHA Hazard Communication Standard.
- Explanation of the existence of federal, state and local laws on the right to know.
- Definition of the classification “hazardous chemical”.
- Explanation of the situations, and the elements that must be present for a material to be considered dangerous to health.
- Explanation and interpretation of the labels, including what is required on all containers, and the System of Hazardous Materials Identification (HMIS)
- Understanding and interpretation of the Safety Data Sheets (SDS) that must be obtained for each dangerous chemical.
- Names and characteristics of all hazardous substances in my workplace.
My responsibilities as an employee of [company name]______________________________.
Name of the employee: _________________________________________________________________
Employee Signature: _________________________________ ___ Date: _____________
Company Representative: ____________________________ Date: ____________
Benefits for workers
The development of the GHS has represented progress for workers around the world towards the right to know the hazards of the chemicals they work with. Some countries, but not all, have adopted the GHS.
The implementation of the GHS in the US will preserve all the original labour protection measures, according to the hazard communication standard, and will also reinforce some. Information on labels and safety data sheets will need to be more consistent and easier to understand because the format is standard.
Warning signs about hazards have also been standardized and do not contain incomprehensible scientific language. For the first time, labels and safety data sheets will include pictograms – symbols indicating a specific danger. This is especially important for workers with a low level of reading comprehension or who do not speak English.