Page 18 - OHS, April 2022

HAZARD COMMUNICATION
Meeting both the intent and compliance with the HCS means that employees must know the hazards and precautions.
address the specifific chemical hazards of your workplace. Since this is performance oriented, you can use a lot of creative ways to accomplish this. Classroom training usually has limited retention and effectiveness. Training can be supplemented with short toolbox talks, posters or other visual information, or hazard information integrated into procedures. If it’s getting the message across to your workers, then it is meeting both the intent of and compliance with the standard.
To be able to communicate hazards and precautions to workers also means that we need some process to assess what our chemical hazards are, the health risks and determine what
precautions are needed.
As a Certifified Industrial Hygienist (CIH), I use an industrial
hygiene exposure assessment process. ThThe complexity of the assessment will depend on the nature or your operations and chemical exposures. For many operations that handle small amounts of chemicals, the exposure assessment may be not much more complicated than reviewing SDS or other information and doing a walkthrough to observe chemical use and exposure. More complicated operations or chemical exposures with the potential for significant health risk may need a detailed assessment and sampling.
Assessing exposures is also important for compliance with other OSHA standards like personal protective equipment and respiratory protection. These standards require an assessment of hazards to determine the appropriate protective equipment.
The Hazard Communication Standard, and your organization’s program, is not about the procedure and SDS binders on the shelf. It’s there to protect your workers from chemical hazards. Understand your hazards, be creative with communication, and, of course, always take care of the compliance paperwork.
Tom Burgess, MS, CSP, CIH, serves as Client Manager, Industrial Hygiene and Safety for T&M Associates, a leading national consulting, environmental, engineering, technical services and construction management company.
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