Many times a Hazard Communications class is started with the instructor asking the question “What hazards does OSHA’s Hazard Communications Standard address?” Often times the answers deal with safety signs or the way that hazards get communicated. Makes sense, but aren’t the correct answers. Hazard Communications deals with the chemical hazards of products. Another term that is used to describe the program is the “Right to Know” standard. Employees have the right to know and understand the hazards of chemicals.
The Hazard Communications year after year is on OSHA’s Top Ten List of Standards that are cited in inspections. There are many required elements of the standard and companies may find that they are in compliance with only part of the standard. This is even more likely the case with OSHA’s recent adoption of the Globally-Harmonized System for hazard communications into its standard.
Here are some important questions to ask in order to determine is your company is in compliance. Here is a link to the Haz Com standard. http://1.usa.gov/1qgjP3X to use as a reference.
Do we have a written plan that meets the requirements of the Hazard Communications standard? Where is the written plan located?
Have we conducted an inventory and developed a list of hazardous chemicals in the workplace? Where is this list located?
Do we have a system in place in our receiving process to make sure chemical products are properly labeled before they are accepted?
Do we have Safety Data Sheets available for each hazardous chemical listed in our inventory?
Have we conducted employee training? Have we conducted employee training relating to the new Globally Harmonized System elements that were adopted by OSHA? That training was to have been done by December 1, 2013.
Are all secondary containers of hazardous chemicals i.e. quart or gallon jugs, properly labeled?
If we have incompatible chemical products, are they stored separately in a safe manner?
What hazard control methods have we put in place to safely handle hazardous chemicals?
Do we have all of the personal protective equipment needed to work safely with chemicals? Are employees using the personal protective equipment?
If your program is addressing the issues raised by the questions, you are well on your way to having a Hazard Communications program that is not only in compliance with OSHA, but also promotes safe chemical use in your workplace.
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