Each year, HAZCOM is OSHA’s most often cited standard, and many of us would agree that a HAZCOM program is like the “A” of the ABCs of safety. However, we often see programs that are not up to 100% compliant. Here are the OSHA requirements for our written program. Does your program meet these?
In general, the written program should consider the following elements, where applicable:
(1) Labels and Other Forms of Warning.
Designation of person(s) responsible for ensuring labeling of in-plant containers.
Designation of person(s) responsible for ensuring labeling on shipped containers.
Description of labeling system(s) used.
Description of written alternatives to labeling of in-plant containers, where applicable.
Procedures to review and update label information when necessary.
(2) Material Safety Data Sheets.
Designation of person(s) responsible for obtaining/maintaining the MSDSs.
How the data sheets are to be maintained (e.g., in notebooks in the work area(s), in a pick-up truck at the jobsite, via telefax), procedures on how to retrieve MSDSs electronically, including back-up systems to be used in the event of failure of the electronic equipment, and how employees obtain access to the MSDSs.
Procedures to follow when the MSDS is not received at the time of the first shipment.
For chemical manufacturers or importers, procedures for updating the MSDS when new and significant health information is found.
(3) Training.
Designation of person(s) responsible for conducting training.
Format of the program to be used (audiovisuals, classroom instruction, etc.).
Elements of the training program–check to see if the written program addresses how the duties outlined in (h)(2) and (h)(3) will be met.
Procedures to train new employees at the time of their initial assignment and to train employees when a new hazard is introduced into the workplace.
Procedures to train employees regarding new hazards to which they may be exposed when working on or near another employer’s worksite (i.e., hazards introduced by other employers).
(4) Additional Topics To Be Reviewed.
Is a list of the hazardous chemicals part of the written program?
Are methods the employer will use to inform employees of the hazards of non-routine tasks outlined? Do those methods include procedures regarding how employees will be informed of potential hazards at other worksites they may visit and at multi-employer worksites?
Are employees informed of the hazards associated with chemicals contained in unlabeled pipes in their work areas?
Does the written plan include the methods the employer will use on multi-employer worksites to provide other employers with on-site access to MSDSs?
Does the plan include the methods the employer will use at multi-employer worksites to inform other employers of any precautionary measures that need to be taken to protect employees?
For multi-employer workplaces, are the methods the employer will use to inform the other employer(s) of the labeling system used clearly described?
Is the written program made available to employees and their designated representatives upon request?