HazCom: Simplified Program Ideas for Safety Managers

Many hazardous substances and materials enter the workplace, but some industries certainly use more hazardous materials than others. Even if your facility only uses one hazardous chemical, though, your company is still required to comply with OSHA’s Hazard Communication Standard (HazCom or HCS). This standard states employees have a right to know the names of the chemicals they may be exposed to while at work, what hazards may be involved in working with those chemicals and how to protect themselves from those hazards. While HazCom does require attention to detail on the part of employers, evaluating current practices and developing a plan suitable to a particular workplace will help safety managers create safe, efficient work environments. In this article we will address topics including:

-Assessing Substances Currently in Use
-Making Management Plans
-Communicating with Employees

Take Inventory of All Potentially Hazardous Substances

HazCom, Labels
The first step to ensuring your workplace is compliant with HazCom is to take stock of all the substances currently being used. Check each substance’s labels and safety data sheet (SDS) for any warnings from the manufacturer. Any substance that may harm people or the environment needs to be handled carefully, and a plan for making sure that happens must be put in place.

During your assessment, take note of what kinds of chemicals are used, how they’re used and how they’re stored. Also consider how they are transported (if applicable), what potential health hazards (such as toxicity, irritation or carcinogenicity) or physical hazards (such as flammability and corrosion) are associated with the substances and where emergency response equipment is located.

While investigating all substances used by your company, keep in mind that even substances like bloodborne pathogens—not just manufactured chemicals—must be considered and handled accordingly.

Create a Detailed HazCom Management Program

Once safety managers have identified all hazardous substances that come through the workplace—even in small amounts—it’s time to construct a management plan that relies on preparedness. Look at notes from the assessment process and determine what kind of education employees will need to handle these materials. To be compliant, you will need to explain the OSHA standard to employees, provide employees with information about the hazardous materials gathered in your assessment, and create a written hazard communication program for employees to reference. (OSHA provides a complete list of items to include in this written program.)

Specific best practices can help your company handle hazardous materials safely on a daily basis, so consider what procedures will make your facility safest. In the workplace, prevention is key to limiting workers’ improper exposure to hazardous substances, so it’s a good idea to implement a system that requires employees to check for potential problems before beginning work. This process could include removing food and potentially flammable substances from pockets and changing out of inappropriate street clothing. Then at the end of a shift, employees should follow specific practices for cleanup to reduce the risk of exposure. Depending on your company’s operations, this could include disposing of waste, changing clothes or washing up.
HazCom, Label, Pictogram
Also keep in mind that proper labeling is an important part of any hazard communication program because it will help employees keep the workplace safe. Containers of hazardous chemicals should already have manufacturer labels on them, but if hazardous substances are moved from one container to another, you will need to provide additional labels for those containers. You might also want to consider posting general signs for employees explaining some of the hazard imagery typically used on labels such as the skull and crossbones, flame and exclamation mark.

Tips for Safety Managers:
To guarantee your program runs smoothly, keep the following key details in mind:

  • SDSs and other written information need to be easily accessible for employees. Try designating a space—perhaps a labeled filing cabinet—for these materials and remind employees of where it’s located.
  • Accommodations may be necessary so employees who do not speak English understand the policies and procedures. If you have a bilingual member of your staff who is familiar with the details of your program, you could post a sign indicating any employees with questions should contact that person.
  • Communication with contractors and their employees about hazards may require extra attention. Check in with new contractors to alert them to potential safety hazards so they can educate their employees appropriately.

Creative Safety Supply

Train and Re-Train Workers

To remain compliant with HazCom, a company’s employees must be able to demonstrate they understand procedures for handling hazardous substances. Consequently, it’s a good idea for safety managers to discuss these topics routinely at meetings and to conduct follow up training whenever a procedure changes. These trainings can be conducted using whatever medium most effectively conveys the information including online instruction and training in the workplace.

When an employee is first hired, there are specific subjects that must be discussed before the employee begins work. First, explain OSHA regulations and your company’s specific hazard communication program. Make sure to indicate where written materials pertaining to the program can be found in your workplace. Then cover which operations at your company involve hazardous substances and how those substances are used. Be sure to show new employees how to read labels and SDSs, which contain 16 parts because of new guidelines. Also clarify the safety precautions taken at your company when using chemicals including any protective gear that may be necessary. Finally, provide information about how employees can detect a spill; the chemicals you use may have distinct smells or other characteristics.

Communication is vital to a safe work environment, so it’s important to reconnect with employees about your hazard communication program regularly. According to the National Institute for Occupational Safety and Health (NIOSH), improper training, inadequate emergency procedures and a failure to follow procedures lead to many instances of exposure to hazardous chemicals in the workplace, so routinely providing thorough training can help decrease the odds of an incident. Posting signs indicating potential dangers and explaining the location of emergency equipment can also help reinforce HazCom safety procedures.

Main Points to Remember

  • Safety managers can keep their hazard communication programs up to date by regularly assessing the hazardous substances used on the job site.
  • Employees need easy access to this program’s written documentation both so they can help maintain a safe work environment and so the company can comply with OSHA regulations.
  • Regular training in how to handle hazardous substances is necessary, and keeping open communication with employees will help reinforce best practices and eliminate confusion.

In future posts, we’ll dive deeper into some of these topics including how to deal with chemical spills in the workplace and how to prepare for different types of chemical hazards.

Additional Resources