Disclaimer: The 2020 SSG emphasis program is designed for owners and managers to ensure they are adhering to, and maintaining the technical elements of their OSHA compliance and safety program. It is not designed for employee training. Check out the PREMIUM version of this site t0 gain access to our employee-based, OSHA-compliant trainings on numerous topics.


This week and every week here in the 2020 emphasis program is brought to you by Safety Consulting NOW, which is a project I’ve worked hard on for the past few years. It’s a full Learning Management System filled with OSHA-required training, video ToolBox Talks and several other consulting resources. And on that note, I wanna direct you to the Core video training on Hazardous Communication and the Global Harmonized System that we have on our NOW platform. It does a great job of laying out everything you and your employers are required to know and practice within your operations. That said, let’s jump into this week’s emphasis on Hazard Communication or Hazcomm for short. This term literally means, how your employer communicates the hazards of chemicals and substances to you and your teammates, as OSHA requires. It’s an extremely important topic because everyone within a workplace will likely have exposure to some sort of chemical. Whether that’s windex, bleach, or W-D40…you need to have several things organized and lined out to make this an OSHA complaint program within your operations. So this first week, we are gonna cover the implementation of a Written Hazard Communication Program and ensure you have taken an inventory on all hazardous chemicals in the workplace. So let’s break this down. 

Paragraph (e), of this standard requires employers to prepare and implement a written hazard communication program. This does not need to be lengthy or complicated. The main intent of the requirement is to help ensure that compliance with the standard is done in a systematic way and that all elements are coordinated. Thus, the program must describe how the employer will address the requirements of Labels and Other Forms of Warning; Safety Data Sheets; and Employee Information and Training. In addition, the written program must include A list of the hazardous chemicals known to be present in the workplace. This list may be kept using any product identifier from the SDS. Thus, the list may be kept by product name, common name, or chemical name. The important aspect of this requirement is that the term used on the list must also be available on both the SDS and the label so that these documents can be cross-referenced. The list can be compiled in whatever way the employer finds most useful and applicable to the workplace. A list of all hazardous chemicals in the entire workplace may be most suitable for very small facilities, where there are few work areas and all workers are potentially exposed to essentially the same products. For larger workplaces, it may be more convenient to compile lists of hazardous chemicals by work area and have them assembled together as the overall list for the workplace. Regarding “The list”, this is an inventory of chemicals for which the employer must ensure that there is an SDS available. Compiling the list also helps employers keep track of the chemicals present, and to identify chemicals that are no longer being used, and therefore could be removed from the workplace. Removing such chemicals may also reduce potential adverse effects that could occur in the workplace. The best way to prepare a comprehensive list is to survey the workplace. Working with your purchasing department may also help. That said though, employers should establish procedures to ensure that purchasing procedures result in receiving SDSs before a material is used in the workplace. Prior to purchasing chemicals, review the hazards of the chemicals and evaluate if less hazardous chemicals can be used instead. When the standard notes “Product identifier” this means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used should permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. Now, when you’re conducting the chemical survey, the broadest possible perspective should be taken. Sometimes people think of “chemicals” as being only liquids in containers. The HCS covers chemicals in all forms—liquids, solids, gases, vapors, fumes, and mists—whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If the chemical is not hazardous, it is not covered by the standard. If there is no potential for exposure (e.g., the chemical is inextricably bound and cannot be released), the chemical is not covered by the standard. Look around. Identify chemicals in containers, including chemicals running through pipes, but also think about chemicals that are generated during work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Read the labels provided by suppliers for hazard information. Make a list of all chemicals in the workplace that are potentially hazardous. For your own information and planning, you may also want to note on the list the location(s) of the products within the workplace, and an indication of the hazards as found on the label. This will help as you prepare the rest of your program. Paragraph (b) of the standard, scope and application, includes exemptions for various chemicals or workplace situations. After compiling the complete list of chemicals, you should review paragraph (b) to determine if any of the items can be eliminated from the list because they are exempted materials. For example, food, drugs, and cosmetics brought into the workplace for personal consumption by workers are exempt. Once you have compiled a complete list of the potentially hazardous chemicals in the workplace, the next step is to determine if you have received SDSs for all of them. Check your files against the inventory you have just compiled. Employers are required to have SDSs for all hazardous chemicals that they use. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by keeping a copy of a letter or e-mail, or a note regarding telephone conversations. If you cannot show a good faith effort to receive the SDS, you can be cited for not having the SDS for a hazardous chemical. If you have SDSs for chemicals that are not on your list, figure out why. Maybe you do not use the chemical anymore. Or maybe you missed it in your survey. Some suppliers provide SDSs for products that are not hazardous. These SDSs do not have to be maintained. Do not allow workers to use any hazardous chemicals for which you have not received an SDS. As a helpful reminder, the SDS provides information you need to ensure that proper protective measures are implemented prior to worker exposure. 

Paragraph (e)(1)(ii) states that: There must be methods to inform employees of the hazards of non-routine tasks. The written program needs to include how an employer will inform workers of hazards that are outside of their normal work routine. While workers’ initial training will address the types of exposures they will encounter in their usual work routines, there may be other tasks to be performed on occasion that will expose these workers to different hazards, as well as require novel control measures. For example, in a manufacturing facility, it may be necessary periodically to drain and clean out reactor vessels. For this task, workers may be exposed to cleaning chemicals that are not normally in the workplace, and the usual controls for the process may not protect them, so personal protective equipment may have to be worn. The written program needs to address how the employer will handle such situations and make sure that workers involved have the necessary information to stay protected. Regarding Multi-Employer Workplaces. This is a topic that gets brought up to us often. Here’s what you need to know: Where there is more than one employer operating on a site, and employees may be exposed to the chemicals used by each employer, the employer’s written hazard communication program must address: 

1. How on-site access to SDSs will be provided to the other employer(s). 

2. How such employers will be informed of needed precautionary measures. 

3. How such employers will be informed of the on-site labeling system if it is different from the labels specified for shipped containers under the standard. 

In summary, this emphasis we’re doing at SSG provides a focused opportunity to review your written program to ensure that it is consistent with the HazCom 2012 requirements. It may need to be updated; for example, you may have to add or delete chemicals from the list in the program, or change your description of the approach to workplace labeling. Also, one more quick answer to a question we get asked often: If your workers’ job assignment requires travel between various geographical locations, you may keep the written program at the primary work location. So it’s not needed to be taken everywhere. Just ensure it has been trained on and the employee knows what they’re working with at whatever location they’re visiting. 

Alright, that wraps up this week. Next week we will be diving into the proper labeling of containers. It’s a commonly cited violation and we wanna make sure we’re pointing you in the right direction. For Summit Safety Group and Safety Consulting NOW, I’m Jake Woolfenden and I’ll see you next week. Please check out training.safetyconsultingnow.com to subscribe to our full training library. I’ll see you in the next one.