Page 16 - OHS, April 2022

HAZARD COMMUNICATION
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standard is the measure of compliance.
BY TOM BURGESS
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OSHA’s Hazard Communication Standard (HCS) de- mands attention to details, including making sure Safety Data Sheets (SDS) are available, providing training and addressing chemical container labeling.
While attention to these details is vital, what I often see lacking is attention to the purpose of the Hazard Communication Standard itself. The intent of the OSHA standard is to ensure that the millions of employees who are exposed to hazardous chemicals in their jobs understand the hazards and how to protect themselves.
Ultimately, meeting both the intent and compliance with the HCS means that employees must know the hazards and precautions. Hazard evaluation, SDS, labeling, written programs, information and training are all key elements intended to achieve this goal.
The HCS is performance-oriented, meaning achieving the standard, including employee knowledge, is the measure of compliance. This is intended to give employers more flexibility in how they achieve compliance, but can also make it more challenging to manage, since having a written program, labeling, SDS and training does not guarantee compliance.
If I am auditing or if OSHA is inspecting your facility for compliance, worker interviews will be an important part of the assessment. Do workers know what chemicals they are or may be exposed to? Do they understand the potential health risks? Do they know, and are they using, controls or personal protective
equipment? Do they know what to do if there is a spill or they are accidentally overexposed? If your workers can’t answer the questions, you are not in compliance, even if you have training and other documentation.
I remember an OSHA inspection at a chemical plant where I worked in New Jersey. We had a dusty operation where workers were required to use coveralls and respirators. The inspector approached a worker to ask questions. Somehow, it seems, an inspector or auditor always finds the last person on the floor that you want them talking to. Our compliance was based in part on whether or not this specific worker understood what he was working with and the precautions.
It didn’t matter what language he spoke, his education level or experience, it was our responsibility to make sure he was knowledgeable. In this case I was very happy when the worker gave simple, clear explanation of what he was doing, what he was working with, the ventilation controls and protective equipment. This wasn’t just about compliance. It was clear that he was protecting his health rather than just following a rule.
Training is the most common area where I see programs miss- ing the intent of the standard. This especially occurs when online or off-the-shelf training programs are used. Many training sessions spend a lot of time reviewing the elements of the standard, the ele- ments of a label, and maybe even details on each of the 16 sections of SDS. However, this is not hazard communication training.
Hazard communication information and training must
12 Occupational Health & Safety | APRIL 2022
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