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Course 705 - Hazard Communication Program

Safety guides and audits to make your job as a safety professional easier

General Responsibilities

Introduction

employer and employee shaking hands
Primary responsibility: communications.

In order to ensure chemical safety in the workplace, the employer must make sure employees have information and understand the identities and hazards of chemicals with which they work. OSHA's Hazard Communication Standard (HCS) requires employers and manufacturers to develop and distribute chemical information as stated below:

  • Chemical manufacturers and importers must classify the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers;
  • All employers with classified hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train workers to handle the chemicals appropriately.

As we mentioned in the introduction, the new HCS 2012 is now aligned with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) that provides many benefits, including the following:

  • Provides a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets;
  • Improves the quality and consistency of hazard information in the workplace;
  • Helps reduce trade barriers;
  • Results in productivity improvements for American businesses that regularly handle, store, and use classified hazardous chemicals;
  • Provides cost savings for American businesses that periodically update safety data sheets and labels for classified chemicals.

Remember, the old HCS 1994 gave workers the right to know, but the new HCS 2012 gives workers the right to understand: this is a very important change, so look for it on the final exam!

Purpose of the Standard

29 CFR 1910.1200
29 CFR 1910.1200

The purpose of the HCS 2012 is to make sure that:

  1. the hazards of all chemicals produced or imported are classified, and
  2. information about the classified hazards is transmitted to employers and employees.

Classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, may include:

  • Developing and maintaining a written hazard communication program;
  • Listing the hazardous chemicals present;
  • Labeling containers of chemicals in the workplace;
  • Labeling containers of chemicals being shipped to other workplaces;
  • Preparing and distributing SDSs to employees and downstream employers;
  • Developing and implementing employee training programs.

Remember, OSHA's new HCS 2012 is intended to be consistent with the provisions of the United Nations' GHS. (This will be on the exam!)

Scope of 1910.1200
How the HCS Works
Click to Enlarge.

Scope of the Standard

The HCS 2012 requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import. It requires all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of:

  1. a hazard communication program,
  2. labels and other forms of warning,
  3. safety data sheets, and
  4. information and training.

(Be sure you know what these four requirements mean!)

In addition, the HCS requires distributors to transmit the required information to employers.

Employers who do not produce or import chemicals need only focus on those parts of this rule that deal with establishing a workplace program and communicating information to their workers.

Application

The HCS 2012 applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

shelf
The HCS 2012 applies to any chemical which is known to be present

"Foreseeable emergency" means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.

The phrase "known to be present" is important. If a hazardous chemical is known to be present by the chemical manufacturer or the employer, it is covered by the standard.

"Hazardous chemical" means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

This includes chemicals to which employees may be exposed during normal operations or in a foreseeable emergency. This means that even though an employer was not responsible for the manufacture of the hazardous chemical, the employer has the responsibility for transmitting information about the hazardous chemical to his or her employees.

Employee - Employees, such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. For example, an office worker who occasionally changes the toner in a copying machine would not be covered by the standard. However, an employee who operates a copying machine as part of her/his work duties would be covered by the provisions of the HCS.

lab
Laboratory employers who ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor.

What about Laboratories?

The HCS applies to laboratories only as follows:

Employers must:

  1. ensure labels on incoming containers of hazardous chemicals are not removed or defaced;
  2. maintain any safety data sheets that are received with incoming shipments of hazardous chemicals;
  3. ensure safety data sheets are readily accessible during each workshift; and
  4. provide appropriate information and training about the hazards of the chemicals laboratory employees use.

Note: Laboratory employers that ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor, and thus must:

  1. properly label any containers of hazardous chemicals leaving the laboratory, and
  2. provide a safety data sheet to distributors and other employers as required by the HCS.
containers
Chemicals in sealed containers

Employees Handling Chemicals in Sealed Containers

In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use (such as are found in marine cargo handling, warehousing, or retail sales), employers must do the following:

  1. Ensure labels on incoming containers of hazardous chemicals are not removed or defaced.
  2. Maintain copies of any safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals.
  3. Obtain a safety data sheet as soon as possible if sealed containers do not have safety data sheets.
  4. Ensure the safety data sheets are readily accessible during each work shift.
  5. Provide appropriate information and training about the hazards of the chemicals employees use.
  6. Protect employees in the event of a spill or leak of a hazardous chemical from a sealed container.
food
Labels are not usually required for food containers.

HCS Labeling Exceptions

HCS Labeling Requirements are not required in the following instances:

  • Regulated pesticides;
  • Any chemical substance or mixture as defined in the Toxic Substances Control Act when subject to the labeling requirements of that Act and the EPA;
  • Regulated food, food additives, color additive, drug, cosmetic, or medical or veterinary device or product, including materials intended for use as ingredients (e.g. flavors and fragrances);
  • Regulated distilled spirits (beverage alcohols), wine, or malt beverage intended for non-industrial use;
  • Any consumer product or hazardous substance as those terms are defined in the Consumer Product Safety Act and Federal Hazardous Substances Act when subject to a consumer product safety standard or labeling requirement of those Acts, or regulations issued under those Acts by the Consumer Product Safety Commission; and,
  • Regulated agricultural or vegetable seed treated with pesticides and labeled in accordance with the Federal Seed Act and the labeling regulations issued by the Department of Agriculture.
waste
Hazardous waste site.

HCS Application Exceptions

The Hazard Communications Standard does not apply to:

  • Regulated hazardous waste when the hazardous substance is the focus of remedial or removal action;
  • Tobacco or tobacco products;
  • Wood or wood products, including lumber which will not be processed. Wood or wood products which have been treated with a hazardous chemical. Wood which may be subsequently sawed or cut, generating dust, are not exempted);
  • Articles. Manufactured items other than fluids or particles:

    • which are formed to a specific shape or design during manufacture;
    • which have end use function(s) dependent in whole or in part upon its shape or design during end use; and
    • which under normal conditions of use do not release more than minute or trace amounts of a hazardous chemical and do not pose a physical hazard or health risk to employees;
  • Food or alcoholic beverages which are sold, used, or prepared in a retail establishment, and foods intended for personal consumption by employees while in the workplace;
  • Cosmetics which are packaged for sale to consumers in a retail establishment, and cosmetics intended for personal consumption by employees while in the workplace;
  • Consumer products or hazardous substances where the employer can show that:

    • they are used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and
    • the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended;
  • Nuisance particulates where the chemical manufacturer or importer can establish that they do not pose any physical or health hazard;
  • Ionizing and non-ionizing radiation; and
  • Biological hazards.
manuf
Chemical manufacturers and importers must evaluate chemicals.
Click to Enlarge

Evaluating Chemicals

Requirements for chemical manufacturers, distributors, and importers are different than those for employers who only use manufactured chemicals.

Chemical manufacturers and importers must evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with the HCS 2012.

Employers are not required to classify chemicals. The only exception to this is if the employer chooses not to rely on the classifications performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.

Employer general responsibilities under the HCS 2012 include:

  1. ensure proper container labeling,
  2. Safety Data Sheet maintenance and use,
  3. provide information and training, and
  4. develop and implement a written hazard communication plan.

Throughout the rest of the course, pay special attention to those areas you've listed as inadequate. You may gain some good ideas about how to improve those areas.

Classifying the Hazards

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Chemical manufacturers and importers must determine hazard classes.

"Classification" is a process to:

  1. identify the relevant data regarding the hazards of a chemical;
  2. review those data to ascertain the hazards associated with the chemical; and
  3. decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical.

In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards.

For each chemical, the chemical manufacturer or importer must determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified.

Chemical manufacturers, importers and employers classifying chemicals must identify and consider the full range of available scientific literature and other evidence concerning the potential hazards.

There is no requirement to test the chemical to determine how to classify its hazards.

Employers are not required to classify chemicals if they choose to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.

Mixtures

When classifying mixtures they produce or import, chemical manufacturers and importers of mixtures may rely on the information provided on the current safety data sheets of the individual ingredients except where the chemical manufacturer or importer knows, or in the exercise of reasonable diligence should know, that the safety data sheet mis-states or omits information required by OSHA standards.

Video

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

1. The purpose of the hazard communication program is to ensure that the hazards of ______ chemicals are assessed and that information is transmitted to employers and employees.

2. Which of the following is not a primary method in the hazard communication program to inform employees of the hazards in the workplace?

3. Employees are required to be educated about all of the following hazard communication program subjects, except _____.

4. Employers are responsible for conducting research and producing SDSs?

5. In the hazard communication program, employees should be trained in which of the following?


Have a great day!

Important! You will receive an "error" message unless all questions are answered.