Of all of OSHA’s many standards (and trust us, there are more than a few) one of the most frequently violated standards is Standard 1910.1200, the Hazardous Communication Standard, and not having a sufficient Hazardous Communication Plan. In fact, from October 2017 to September 2018 it was the second-most cited standard behind only the Fall Protection Standard.
Commonly known as the “Right to Know Law”, this standard is a requirement of employers to inform, educate and train employees of potentially hazardous chemicals and materials located on site of their work environment.
However, more than just the right to know, former firefighter and current Pearl Engineering safety consultant Scott Burkart describes this standard more so as a “Right to Understand.”
“Telling an employee just isn’t enough,” Scott said. “More than just knowing, it falls on the employer to sufficiently meet the standard, have a Hazardous Communication Plan in place and getting their employees to truly understand the hazards in their environment.
So how can a business avoid a citation for violating the Hazardous Communication Standard? You must meet the required 6 categories that make up the standard:
- Written inventory of all hazardous chemicals
- Properly labeling chemicals
- Provide Safety Data Sheets (SDS)
- Procedure for non-routine tasks
- Information and Training for employees
- Creating a Hazardous Communication Plan
Chemical Inventory
Every workspace needs to keep a list of all hazardous chemicals present. This list needs to include additional information including:
- the common name of the chemical
- any trade names the chemical could be known as
- the name of the chemical’s manufacturer
- when it was stored
- how much is present
- the chemical’s daily use location
- how to store it
- and where to store it
When building an inventory, much of this information can be obtained from both the chemical’s labeling and the SDS. A chemical inventory needs to be accessible to all employees.
Labeling
The Hazardous Communication Standard recently underwent a slight update when the Global Harmonization System (GHS) was introduced. The GHS introduced a world-wide system for labeling and identifying chemicals.
GHS labeling displays important information about the chemical and its properties using several elements, most distinctly the use of small graphics (called hazard pictograms) displaying the chemical’s attributes and qualities.
A GHS compliant label must include:
- the name of the chemical
- a signal word
- hazard pictograms
- the name of the manufacturer and contact information
- a precautionary statement/first aid instruction
- and a hazard statement
In addition to these components, a GHS label is often accompanied by an additional, diamond-shaped graphic broken into different colors, each with their own indication and a number between 0 and 4 indicating its danger level. 0 being no hazard and 4 being the highest hazard.
- Blue: health hazard
- Red: fire hazard
- Yellow: reactive hazard
- White: special hazards, such as water reactivity or radioactivity
Consider this example of GHS labeling for Thiourea dioxide: (image)
The name (Thiourea dioxide), signal word (DANGER), hazard pictograms (indicating the substance is flammable and an irritant), the manufacturer (Wago Chemical Group Inc.) and contact information, hazard statement and precautionary statements are all present, as well as the diamond indication that it is both a fire hazard and contains a special hazard.
Sufficient labeling must be present in all primary Containers (provided by the chemical manufacturer or shipper) and secondary container (a container the chemical is transferred into at your facility). The only exception is if the chemical is transferred to a secondary container and immediately used up and is always under control by the worker that transferred it.
Safety Data Sheets
Now completely standardized after the introduction of GHS, Safety Data Sheets and mandatory 16 sectioned documents containing essential information about the chemical. SDS need to be present and easily accessible to everyone on site.
The 16 sections of an SDS are:
- Identification
- Hazard(s) Identification
- Composition/Information of Ingredients
- First-Aid Measures
- Fire-Fighting Measures
- Accidental Release Measures
- Handling and Storage
- Exposure Controls
- Physical and Chemical Properties
- Stability and Reactivity
- Toxicology Information
- Ecological Information
- Disposal Considerations
- Transport Information
- Regulatory Information
- Other Information
For a more in-depth breakdown of each section, see OSHA’s breakdown here.
Non-Routine Tasks
Procedures for completing non-daily tasks needs to be established, recorded and taught to all employees that will be required to take part in them.
What constitutes a non-routine task? While an employee may be handling a certain chemical every day, the tank it is housed in may need to cleaned monthly, quarterly or yearly. When it does, they need to know how to do so safely.
Other non-routine tasks can include dealing with spills, dealing with leaks or dealing with exposures.
This list is both industry and site-specific and must include every possible example. For this reason, Scott encourages creating this list become group work.
“A list like this with so many possible examples and variations cannot be created in a vacuum,” he said. “Talk to all levels of the organization, from workers to managers – even the cleaning crew – to help identify all possible risks and responses that need to be trained. Outside help from consultants are another useful resource.”
Information and Training
When it comes to training, every level of the organization needs to be involved. Anyone that will or may come in contact with chemicals needs to be trained. Full-time, part-time as well as volunteer workers need to all receive the same level of training.
The kind of training these employees must receive differs from instance to instance but needs to be thorough and site-specific. Employees must be trained for all current workspace chemicals as well for any chemicals that are brought in in the future. This kind of training should include dealing with:
- exposure
- clean up
- detecting leaks or spills
- the health hazards associated with each chemical
- how and where to access SDS and the Hazardous Communication Plan
- and any protective materials they may be using, such as alarms or protective clothing
With training for all employees mandatory by OSHA, the burden of proof again falls on the employer. Employers need to verify that all employees are knowledgeable and proficient in these skills and can do so through written, verbal or proficiency tests.
“This is where the concept of ‘right to understand’ comes into play,” Scott said.
Your Hazardous Communication Plan
So, what needs to be in your Hazardous Communication Plan? Everything that was just covered!
Your plan needs to be a written catalog and documentation that all of these areas have been covered, accounted for and executed. While templates exist on how to display all this information, Scott warns that many are not industry-specific and may not be entirely helpful, encouraging organizations to create their plan in house.
“The Hazardous Communication Standard covers 43 million different workers and over 1 million different chemicals,” Scott explained. “Something that broad that covers everything is non-existent and needs to be written on your own.”
Scott is proficient in training and evaluating employees and workspaces that work with hazardous chemicals. He can help your organization train employees, create your own Hazardous Communication Plan, understand each element and avoid any unnecessary citations from OSHA.
For questions or inquiries, contact Scott at sjb@pearlengineering.com.
