Did you know that violations related to the OSHA Hazard Communication standard ranked #2 in the OSHA top 10 list for most frequently cited violations in 2018? Common citations included not having a written program or safety data sheets (SDS) for all chemicals, lack of employee training, and deficiencies related to secondary container labels.
What can you do to protect your company from HazCom violations? Employers are responsible for ensuring that the labels and SDSs are readily available to all employees. They are also responsible for training employees on how to properly recognize the hazards associated with chemicals and how to properly handle the chemicals based on the hazards conveyed. For laboratories that use chemicals this specifically means that employers must ensure that:
- Labels on incoming containers of hazardous chemicals are not removed or defaced. Incoming container labels must include the identity of the hazardous chemical(s), appropriate pictograms and signal word, and hazard and precautionary statements.
- Labels on secondary containers made in-house must include the elements required for incoming chemical labels, or the identity of the hazardous chemical(s) and pictures or symbols that convey the same information. Alternative means of labeling, such as wall posters or reference charts that relay the necessary hazard information to employees are also allowed.
- A current chemical inventory is maintained and current SDS are on file for all inventoried chemicals and that they are readily accessible to employees. Depending on the town, electronic SDS may be allowed in place of paper copies. (Note that SDS may not always be received with incoming shipments of hazardous chemicals and in some cases they will need to be downloaded from manufacturer websites.)
- Training is provided that includes the physical and health hazards of chemicals in the work area and the measures employees can take to protect themselves from these hazards; the location of the written plan, inventory, and SDS; and an explanation of the SDS and labeling systems.
Don’t forget that laboratories that ship hazardous chemicals, including those made in-house, are considered to be either a chemical manufacturer or a distributor under the Hazard Communication Standard and have additional requirements including that they ensure that containers of hazardous chemicals leaving the laboratory meet manufacturer labeling requirements, and that an SDS is included with the chemical shipment.
For additional information on compliance with the Hazard Communication Standard and avoiding regulatory violations related to it, please email firstname.lastname@example.org.