Introduction
About 32 million workers are potentially exposed to one or
more chemical hazards. There are an estimated 575,000 existing
chemical products, and hundreds of new ones are being introduced
annually. This poses a serious problem for exposed workers
and their employers. Chemical exposure may cause or contribute
to many serious health effects such as heart ailments, kidney
and lung damage, sterility, cancer, burns, and rashes. Some
chemicals may also be safety hazards and have the potential
to cause fires and explosions and other serious accidents.
Because of the seriousness of
these safety and health problems, and because many employers
and employees know little or nothing about them, the Occupational
Safety and Health Administration (OSHA) issued in 1983 a rule
called "Hazard Communication" that applies to employers in
the manufacturing sector of industry. The scope of the rule
was expanded in 1987 to include employers in the non-manufacturing
sector. In 2012, the rule was revised to conform to the United
Nation's Globally Harmonized System of Classification and
Labeling of Chemicals (GHS). See Haz
Com Standard for a copy of the final rule promulgated
in February of 2012.
The basic goal of the standard
is to ensure that employers and employees know about chemical
hazards and how to protect themselves. This knowledge, in
turn, should help to reduce the incidence of chemical source
illnesses and injuries.
What
the Standard Requires
The Hazard Communication Standard establishes uniform requirements
to assure that the hazards of all chemicals imported into,
produced, or used in US workplaces are evaluated, and that
the resultant hazard information and associated protective
measures are transmitted to affected employers and potentially
exposed employees.
Chemical manufacturers and importers
must convey the hazard information they learn from their evaluations
to downstream employers by means of labels on containers and
safety data sheets (SDSs). In addition, all covered employers
must have a hazard communication program to get this information
to their employees through labels on containers, SDSs, and
training.
This program ensures that all
employers receive the information they need to inform and
train their employees properly and to design and put in place
employee protection programs. It also provides necessary hazard
information to employees, so they can participate in, and
support, the protective measures in place at their workplaces.
How
to Comply with the Standard
The following steps should aid you in complying with the standard
and in developing your hazard communication program.
Read
the standard
- Make sure you understand
the provisions of the standard.
- Know your responsibility
as an employer.
List
the hazardous chemicals in the workplace.
- Walk around the workplace,
read all container labels, and list the identity of all
materials that may be hazardous; the manufacturer's product
name, location, and telephone number; and the work area
where the product is used. Be sure to include hazardous
chemicals that are generated in the work operation but
are not in a container (e.g., welding fumes).
- Check with your purchasing
department to ensure that all hazardous chemicals purchased
are included on your list.
- Review your list and determine
whether any substances are exempt (see paragraph (b) of
the rule for exemptions).
- Establish a file on hazardous
chemicals used in your workplace, and include a copy of
the latest SDSs, and any other pertinent information.
- Develop procedures to keep
your list current. When new substances are used, add them
to your list.
Obtain
safety data sheets for all chemical substances.
- If you do not have an SDS
for a hazardous substance in your workplace, request a
copy from the chemical manufacturer, distributor, or importer
as soon as possible. (Refer to SDS
Requests for a sample letter requesting an
SDS). An SDS must accompany or precede the shipment and
must be used to obtain identifying information such as
the chemical name and the hazards of a particular substance.
- Review each SDS to be sure
that it is complete and clearly written. The SDS must
contain the physical and chemical properties of a substance,
as well as the physical and health hazards, routes of
exposure, precautions for safe handling and use, emergency
and first-aid procedures, and control measures. (Refer
to SDSs for
a sample SDS and other information).
- If the SDS is incomplete
or unclear, contact the manufacturer or importer to get
clarification on the missing information.
- Make sure the SDS is available
to employees, designated representatives, and to the Assistant
Secretary for Occupational Safety and Health.
Make
sure that all containers are labeled.
The manufacturer, importer,
or distributor is responsible for labeling containers, but
the employer must adhere to the following:
- Ensure that all containers
of hazardous substances in the workplace are labeled,
tagged or marked and include the identity of the hazardous
chemical, and the appropriate hazard warnings. Container
labels for purchased chemicals must also include the name
and address of the chemical manufacturer, importer, or
other responsible party.
- Check all incoming shipments
of hazardous chemicals to be sure that they are labeled.
- If a container is not labeled,
obtain a label or the label information from the manufacturer,
importer, or other responsible party or prepare a label
using information obtained from these sources. Employers
are responsible for ensuring that containers in the workplace
are labeled, tagged or marked.
- Do not remove or deface
existing labels on containers unless the container is
immediately marked with the required information.
- Instruct employees on the
importance of labeling portable receptacles into which
they have poured hazardous substances. If the portable
container is for their immediate use, then the container
does not have to be labeled.
Develop
and implement a written hazard communication program.
This program must include:
- Container labeling and other
forms of warnings;
- Safety Data Sheets;
- Employee training based
on the list of chemicals, SDSs, and labeling information;
and,
- Methods for communicating
hazards and protective measures to employees and others.
The following sections of this
kit will discuss each of these steps in more detail and
provide you with samples of the material discussed as well
as lists of products, services, and other resources.
Program
Implementation Checklist (PDF)
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