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T P PI NR R FR A A L L L LI N GO O T T: E E HC A TZ I I AO O R ND COMMUNICATIONS It’s common to associate hazardous chemicals with images of barrels of toxic liquids and large pools of waste. But in reality, even common substances like paints, cleaners, degreasers, or detergents in the workplace may be considered hazardous chemicals. creates through the mixing of difffferent substances. This can be a significant undertaking for larger facilities, but the program’s effectiveness will depend on the accuracy of your hazardous chemical inventory, and your facility must have this list present and accessible to employees and auditors. Before you begin the documenting process, consider reading 29 CFR 1910.1200(b)(5 & 6)1 so you’ll know what the exceptions are for certain chemicals. Another critical component of the plan is developing an equally thorough list of the positions and people who will handle these hazardous materials. Any employee who could be exposed during normal operations or in an emergency needs to be prop- erly documented. This process will tie directly into effective train- ing programs. 2. Label Materials OSHA has specific marking and labeling requirements for differ- ent types of containers. Employers should know these require- ments in detail and ensure that containers are marked appropri- ately in accordance with 1910.12001. Typical methods include stickers, signs, and placards. When it is impractical to use these, for example, when harsh conditions exist, or there’s a need to protect trade secrets, process sheets, batch tickets, operating procedures, or other written materials can be used to communicate chemical hazards to personnel. OSHA requires this information to be in English. You can add the information in other languages to the material, as long as the infor- mation is presented in English as well. 3. Obtain and Maintain Safety Data Sheets Any company producing or importing chemicals will be respon- sible for classifying hazards of the chemicals. Other employers that have potential exposure still need to maintain a safety data sheet for each hazardous chemical they use, with some exceptions referenced in step 1. If the chemical supplier did not provide a safety data sheet, it’s up to the employer to obtain or create one. Covering all 16 sec- tions in these documents is an intensive process. ThThe full list of 2. what needs to be covered can be read here 4. Implement Training Programs After identifying hazards and determining workers who could be exposed, you’ll need to train employees to be aware of the in- formation they need. This training should include topics such as location and use of safety data sheets, locations and operations where chemicals are present, the contents and functioning of the program, lists of chemicals, protective measures, and other infor- mation specified in the HazCom standard. Employees should be trained immediately after they are as- signed, and whenever a new chemical hazard is introduced into their work area. For example, training should be updated and de- livered when a new product or process is introduced that alters the hazardous chemical landscape of the company’s operation. That also means it’s time to update safety data sheets. Employers should also consider how often they want to conduct important refresher training. 5. Maintain Records for Audits In addition to an overarching concern for the health and safety of your employees, safety data sheets and training records should be continuously updated and readily available for OSHA inspectors. OSHA typically doesn’t conduct routine audits except for some specific industries. They will inspect targeted facilities, for example in the event of fatalities, severe injuries, or worker complaints. Penalties from these inspections differ based on the nature and severity of violations. The penalty for a single first-time seri- ous violation can exceed $15,000. If the violation is repeated or OSHA determines it is willful, the penalty can surpass $156,000. An effective HazCom program is critical to ensuring em- ployee safety, which should be the number one priority of any manufacturing company. By following these five key steps, you can implement a successful HazCom plan that keeps workers safe while improving efficiency by preventing costly and time-con- suming OSHA audits and shut-downs due to unnecessary chemi- cal contamination. Rick Gehrke serves as a Senior Environmental Safety and Health Consultant at Intertek Alchemy. He is a certified management sys- tems Lead Auditor with experience in ISO 14001, OHSAS 18001, ISO 45001, ISO 50001, LEED green building certification, busi- ness development, and certification program management. Gehrke earned his Associate of Applied Science in Intelligence Collection from the Community College of the Air Force and his Bachelor and Master of Science degrees in Environmental Science from the Uni- versity of Tennessee at Chattanooga. REFERENCES 1. www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200 2. www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/ subpart-Z/section-1910.1200 50 Occupational Health & Safety | JULY/AUGUST 2023 www.ohsonline.com