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:
As we mentioned in the introduction, the HCS 2012 is aligned with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) that provides many benefits, including the following:
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!
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The purpose of the HCS 2012 is to make sure that:
Classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, may include:
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!)
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:
(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.
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.
"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.
The HCS applies to laboratories only as follows:
Note: Laboratory employers that ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor, and thus must:
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:
HCS Labeling Requirements are not required in the following instances:
The Hazard Communications Standard does not apply to:
Articles. Manufactured items other than fluids or particles:
Consumer products or hazardous substances where the employer can show that:
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:
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.
"Classification" is a process to:
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.
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.