1 Fact Sheet Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals Employers that have hazardous chemicals in their workplaces are required by 29 CFR 1910.1200 , to implement a OSHA’s Hazard Communication Standard (HCS), hazard communication program. The program must include labels on containers of hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and training for workers. Each employer must also describe in a written program how it will meet the requirements of the HCS in each of these areas. Employers can implement an effective hazard coordination should then identify staff to communication program by following these be responsible for particular activities, such as training. six steps: Step 2. Prepare and Implement a Written Step 1. Learn the Standard/Identify Hazard Communication Program Responsible Staff Obtain a copy of OSHA’s Hazard • • Prepare a written plan to indicate how Communication Standard. hazard communication will be addressed • Become familiar with its provisions. in your facility. • Prepare a list or inventory of all hazardous Make sure that someone has primary • responsibility for coordinating chemicals in the workplace. implementation. Paragraph (e) of the standard requires employers Identify staff for particular activities • to prepare and implement a written hazard training). (e.g., communication program. This requirement is to You may obtain a copy of the Hazard help ensure that compliance with the standard is Communication Standard on OSHA’s hazard done in a systematic way, and that all elements www.osha.gov/ communication webpage at are coordinated. The written program must . The provisions of the standard dsg/hazcom indicate how you will address the requirements that apply to employers using chemicals in their of paragraphs (f) labels and other forms of workplaces are found primarily in paragraphs warning; (g) safety data sheets; and (h) employee (e) written hazard communication program; (f) information and training, in your workplace. labels and other forms of warning; (g) safety The written program also requires employers data sheets; and (h) employee information and to maintain a list of the hazardous chemicals training. It is important that you become familiar known to be present in the workplace. Using the with these provisions to determine what is product identifier (e.g., product name, common needed for compliance in your workplace. name, or chemical name) to prepare the list will In order to ensure that you have an effective make it easier for you to track the status of SDSs hazard communication program, and address and labels of a particular hazardous chemical. all of the necessary components, responsibility Remember, the product identifier must be the for implementation of hazard communication same name that appears on the label and SDS of should be assigned to someone to coordinate. the hazardous chemical. The person designated for overall program
2 This accessibility may be accomplished in Step 3. Ensure Containers are Labeled many different ways. You must decide what • Keep labels on shipped containers. is appropriate for your particular workplace. • Label workplace containers where required. Some employers keep the SDSs in a binder in Chemical manufacturers and importers are a central location (e.g., outside of the safety required to provide labels on shipped containers office, in the pick-up truck on a construction with the following information: product identifier, site). Others, particularly in workplaces with signal word, pictograms, hazard statements, large numbers of chemicals, provide access precautionary statements, and the name, electronically. However, if SDSs are supplied address and phone number of the responsible electronically, there must be an adequate party. Therefore, when an employer receives a back-up system in place in the event of a hazardous chemical from a supplier, all of this power outage, equipment failure, or other information will be located together on the label; emergency involving the primary electronic however, additional information may also appear. system. In addition, the employer must ensure that workers are trained on how to use the As the employer, you are required to ensure system to access SDSs and are able to obtain that containers in the workplace are labeled. hard copies of the SDSs. In the event of a You may use the same label from the supplier medical emergency, hard copy SDSs must be or you may label workplace containers with immediately available to medical personnel. alternatives, such as third party systems (e.g., National Fire Protection Association (NFPA) Step 5. Inform and Train Employees or Hazardous Materials Identification System Train employees on the hazardous chemicals • (HMIS)) in addition to the other required in their work area before initial assignment, information. Any container of hazardous and when new hazards are introduced. chemicals in the workplace must at a minimum Include the requirements of the standard, • include the product identifier and general hazards of chemicals, appropriate protective information concerning the hazards of the measures, and where and how to obtain chemical. Whatever method you choose, your additional information. workers need to have access to the complete hazard information. Paragraph (h) of the HCS requires that employers train employees on the hazardous chemicals in Step 4. Maintain Safety Data their work area before their initial assignment Sheets (SDSs) and when new hazards are introduced into the • Maintain safety data sheets for each work area, and this training must be conducted hazardous chemical in the workplace. in a manner and language that employees can • Ensure that safety data sheets are readily understand. Workers must understand they are accessible to employees. exposed to hazardous chemicals. They must know that labels and safety data sheets can Safety data sheets are the source of detailed provide them with information on the hazards of information on a particular hazardous chemical. a chemical, and these items should be consulted Employers must maintain copies of SDSs when needed. In addition, workers must have for all hazardous chemicals present in their a general understanding of what information is workplaces. If you do not receive an SDS provided on labels and SDSs, and how to access from your supplier automatically, you must them. They must also be aware of the protective request one. You also must ensure that SDSs measures available in their workplace, how to are readily accessible to workers when they use or implement these measures, and whom are in their work areas during their work shifts. they should contact if an issue arises.
3 its objectives and to revise it as appropriate to Step 6. Evaluate and Reassess address changed conditions in the workplace Your Program (e.g., new chemicals, new hazards, etc.). • Review your hazard communication program periodically to make sure that it is still working Additional Information and meeting its objectives. See Hazard Communication: Small Entity Revise your program as appropriate to • Compliance Guide for Employers That address changed conditions in the workplace Use Hazardous Chemicals for more (e.g., new chemicals, new hazards, etc.). detailed information on how to implement Although the HCS does not require you an effective hazard communication program. to evaluate and reassess your hazard Additional information on the Hazard communication program, it must remain current Communication Standard can be found on and relevant for you and your employees. OSHA’s Hazard Communication webpage at The best way to achieve that is to review your www.osha.gov/dsg/hazcom . hazard communication program periodically to make sure that it is still working and meeting This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards. It does not impose any new compliance requirements. For a comprehensive list of compliance requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. This information will be made available to sensory-impaired individuals upon request. The voice phone is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627. DSG FS-3696 03/2014