Posted by: Green Knight | April 8, 2010

Hazard Communication interview

Hooray! i got permission to post this article, which appeared the other day in the BLR’s OSHA Compliance Advisor. BLR is Business and Legal Resources, and it’s always puzzled me that the OSHA and medical trade journal subscriptions are hundred of dollars a year (tax-deductible), while the environmental ones are free, paid for by advertising. too expensive as a single layout for most of us, but one subscription per company, or fire department, or cop shop (because police just don’t get enough safety and chemical training), isn’t a bad idea. anyway, here it is:



29 CFR 1910.1200(B)

One of the most frequently cited

OSHA standards is hazard communication

(HazCom or HCS). It was created

to ensure that employers make

their employees aware of chemical

hazards on the job. The rule applies

to almost every organization and employer

covered by OSHA. It covers

chemical manufacturers, importers,

employers, and employees exposed to

chemical hazards. Hazards that must

be communicated include physical

hazards such as flammability, and

health hazards like irritation, lung

damage, and cancer.

Under HCS, all employers who manufacture,

import, distribute, or otherwise

use hazardous substances must

communicate the information about

the risks to employees who work

with them. This must be done through

a written hazcom program, labels,

material safety data sheets (MSDSs),

and an employee information and

training program.

The regulation, formerly known as

“right-to-know,” is based on the idea

that employees can better protect

themselves if they know about the

chemicals they’re exposed to. The

standard also gives employers information

to design and implement an

effective protection program.

“Together,” suggests OSHA, “these

actions will result in a reduction of

chemical source illnesses and injuries

in American workplaces.”

You Must Remember This

HazCom compliance can be complicated,

with lots of moving parts to

consider. We’ve summarized some

common concerns here.

Computer storage: If an employee’s

work area includes the area where

MSDSs can be accessed, maintaining

(continued from page 3)

the sheets on a computer is considered

compliant. But if MSDSs can only be

accessed outside the employee’s work

area, keeping them on a computer is

not sufficient.

Manufacturer duties:Manufacturers

must transmit hazard information on

MSDSs that are distributed to the customer

at the time of first shipment of a

product. And MSDSs must be updated

by the chemical manufacturer or importer

within 3 months of learning of

“new or significant” information regarding

the chemical’s hazard potential.

Commercial products: OSHA does

not require that data sheets be provided

for consumer products like

“Windex” and “White-Out” if the

products are used in the workplace

in the same way a consumer would

use them.

Training: Employees must be trained

at the time they are assigned to work

with a hazardous chemical. The idea

is to provide information before exposure

to prevent adverse health effects.

“This purpose cannot be met if training

is delayed until a later date,”

according to OSHA.

But giving an employee data sheets to

read is not enough. The training program

should explain the hazards and

how to use the information generated

through data sheets and labels. This

can be done in various ways, including

interactive video and classroom

instruction. Training should always

include an opportunity for employees

to ask questions.

Additional training is to be conducted

whenever a new physical or health

hazard—not a new chemical—is

introduced. OSHA says it is not

necessary to retrain each new hire if

that employee was trained by a past

employer, union, or other entity.

Been There, Seen That

Bob Carlson is president of Green

Knight Environmental Consulting

Services of St. Louis and consults

with diverse public and private organizations.

Although HazCom citations

are frequent, Carlson says compliance

is not really that difficult. “Do a

chemical inventory and have MSDS

documents where people can access

them at any time. Provide employee

training in reading the MSDS and

label for the products employees work

with, and train in safe use, storage,

and labeling of smaller containers

when decanting product from large

containers. Simply showing a 20-

minute video and asking people to

sign off after watching is not enough,”

says Carlson.

One of the most common training

problems is that new hires are not

immediately provided with hazcom

training. “Many organizations save

it until they do other annual safety

training, which leaves the worker

unprotected until that time,” notes

Carlson. Unlike other OSHA programs,

hazcom training need not be

conducted annually, just initially and

when new products are to be used,

or when conditions affecting safety


Another typical mistake is ignoring

nonchemical hazards. “Hazards can

be physical, chemical, biological,

or radiological,” says Carlson. “It’s

easier to pay attention to a physical

hazard like a brick falling on a

worker’s head than a slow-acting

chemical that might take years to

show ill effects.”

James Howry of the Georgia Tech

consultation program says some employers

provide a binder of MSDSs,

but fail to understand and convey

the larger purpose behind a HazCom

program. It’s not a matter of collecting

information, he says. It’s about

helping employees understand how a

particular chemical hazard relates to

their specific job duties.

Obstacles to Compliance

Howry also expresses concern about

online services for providing and

maintaining an employers’ MSDS

library. “The question is, can you

access the information readily? I’m

finding that at workplaces that rely

on an online database, employees

usually have to go through someone

who has access to the information.”

In order to comply with HazCom,

employees must be able to get directly

to the MSDS when they need it. As a

best practice, Howry recommends that

employers using online services also

print out MSDSs and collect them in a

traditional binder employees can get

their hands on “in time of need.”

When it comes to labeling, Howry

warns against a frequent and potentially

fatal mistake—pouring a small

amount of chemical from its original,

labeled container into a nonstandard

container. Dasani water bottles are

often used in this way because

sprayers can be easily attached to

them. Howry recently observed an orange

liquid in an unlabeled, 16-ounce

water bottle that could easily have

been mistaken for Gatorade.

Also, Howry encourages employers to

train their personnel to answer OSHA

inspectors’ questions about their

chemical knowledge. When conducting

HazCom investigations, OSHA

© 2010 Business & Legal Reports, Inc. (#631) 5


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