Hazard Communication Pitfalls

Violations of the Occupational Safety and Health Administration’s hazard communication standard have often landed near the top of the administration’s citation list throughout the last decade. One of the leading causes of these violations is that the rule requires extensive documentation and is considered “paper-intensive.” Given the substantial amount of chemicals in the average facility, a hazard communication program must be managed daily to ensure continued compliance.

According to OSHA statistics, approximately 32 million U.S. workers are potentially exposed to one or more chemical hazards daily to ensure continued compliance. Due to the potential health and safety risks associated with these chemicals and because many employers and employees know little or nothing about the chemicals they work with, OSHA promulgated the hazard communication standard to provide not only protection from potential hazards. The standard form of communication of the required information is comprehensive training that includes specifics regarding container labeling and warnings, safety data sheets (SDS), and more.

When evaluating a hazard communication program to ensure that it complies with OSHA standards, several common problems occur throughout many industries:

1. Management Commitment – A hazard communication program, like other safety and loss prevention programs, needs management commitment to be successful. Without commitment at the leadership level of an organization, most safety programs have a higher chance of failing. The most common problems encountered in maintaining this program are lack of management support, inadequate funding, and the lack of other resources necessary to develop and maintain the required elements of a hazard communication program. One method that safety and loss prevention professionals have been successful in using has been to communicate potential OSHA penalties for noncompliance as well as the mandatory nature of the standard. Another method is to explain the potential harm that may occur if an employee is injured because of improper labeling or inadequate training.

2. Assessing Hazards – The purpose of a hazard assessment element of the hazard communication program is to determine the identity and location of hazardous chemicals at a facility or workplace. The results of the hazard assessment are used to prepare an inventory of harmful substances and their SDS as well as to define the types of hazards that need to be covered during employee training. A significant problem that can occur with this standard is omitting potential chemicals located on-site during the assessment. To mitigate this potential problem, conduct a comprehensive hazard assessment that includes defining and identifying all potentially hazardous chemicals and determine whether employees have the potential for exposure to harmful chemicals.

In general, the chemicals outlined in 29 CFR Section 1910 subpart Z, Toxic and Hazardous Substances are considered “hazardous chemicals.” You may also want to consider the Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment by the American Conference of Governmental Industrial Hygienists (ACGIH). Chemicals established as being or having the possibility of being a carcinogen in the following sources must be reported as such:

• National Toxicology Program (NTP), Annual Report on Carcinogens
• International Agency for Research on Cancer (IARC) Monographs (latest edition)
• 29 CFR section 1910, subpart Z, Toxic and Hazardous Substances

3. Developing a Written Program – An additional common problem in complying with the hazard communication standard can be the development of the written hazard communication program. A communication program contains three primary components:

• Labeling per the Globally Harmonized Systems (GHS)
• Safety Data Sheets (SDS)
• Employee Information and Training

4. Safety Data Sheets – A Safety Data Sheet, or SDS, is a document that described the physical and chemical properties of products, their physical and health hazards, and precautions for their safe handling and use. The major problem regarding SDSs as an element of the hazard communication program is the acquisition and maintenance of the SDS for every chemical at the worksite. Many organizations have instituted online, or digital SDS libraries in conjunction with management controls to ensure the current SDSs are available for each chemical on site. For many organizations, the maintenance of accurate SDSs for each chemical at the site has proven to be a more difficult undertaking. Some of the sources of these problems occur when purchasing agents obtain new or different chemicals and do not inform the safety and health professional, when the receiving department fails to notice unlabeled products as they enter the facility, and when updated SDSs are not incorporated into the existing SDS booklet or binders. OSHA frequently cites this type of violation during compliance inspections.

5. Employee Training – the hazard communication standard requires employers to provide training programs for their employees. The rule requires that employees receive training and information on the following topics:

• All provisions of the hazard communication standard
• The types of operations in their work areas where hazardous chemicals are present
• The location and availability of the written program, a list of hazardous chemicals, and SDSs.
• Employee training sessions that describe methods which employees can use to detect the presence or release of toxic chemicals in the workplace. Employees should also be informed about any existing medical monitoring programs.
• The physical and health hazards associated with the chemicals in their work areas.
• Specific measures of protection from hazards in their work areas to include engineering or administrative methods, and personal protective equipment.
• Specific components of the hazard communication program, including explanations of the facility’s labeling system and the methods employees, can use to obtain hazardous chemical information.

To address and maintain compliance after your hazard communication program has bee instituted, employers should audit their program to track performance and identify deficiencies for immediate correction. Continuous feedback and refresher training are other keys to a successful hazard communication program.