Hazard Communications

Every day, chemicals are used in the workplace to “get the job done.” Housekeepers use cleaning products to clean and beautify work areas; maintenance personnel use a variety of chemicals and lubricants to keep machinery running; groundskeepers use pesticides and fertilizer to keep the landscape looking beautiful; and office staff use toner and ink to get paperwork done. These employees have one thing in common – exposure to chemicals. Are these employees aware of the hidden dangers of their jobs? Has management implemented appropriate policies and procedures to keep employees safe? 

In 1983, the Occupational Safety and Health Administration (OSHA) passed a regulation (29 CFR 1910.1200) requiring employers to provide information to employees about the chemicals they use in the workplace. Additional revisions were made in 1994, requiring employers to establish a hazard communication program that includes labeling, material safety data sheets, and training programs. In Virginia, state agencies are required to comply with this standard. The main purpose of the Hazard Communication Standard (HCS) is to inform employees of the hazards and properties of the chemicals to which they are exposed while working, as well as the measures they should take to protect themselves.

Agencies have the responsibility of providing this information to employees in a written format. A good written program has the following elements:

• An index listing all hazardous chemicals located on the property
• An up-to-date material safety data sheet for each hazardous chemical listed
• Identification or samples of labels and warning signs/labels that will be used
• Instructions for communicating non-routine tasks to employees
• Requirements for training and retraining
• Agency instructions for sharing and communicating the hazard communication plan with outside contractors

The task of listing all the hazardous chemicals on the agency’s property might seem overwhelming and impossible, but really is manageable. All manufacturers of hazardous chemicals are required to supply a material safety data sheet (MSDS) for the products they sell. The agency procurement department should require a MSDS for all hazardous chemicals delivered to the property. In addition, the receiving department should ensure that the appropriate MSDS is available once a product has arrived. If not, a system should be developed to either retrieve a current MSDS or deny the shipment. 

Once a system is in place for ordering and receiving chemicals, it is necessary to inventory the chemicals already on-site. Enlist the help of the work groups that use the chemicals to list the quantity and types of chemicals they have on hand. Ask these work groups for any associated MSDSs. Many times, manufacturers enclose MSDSs either in or on the product-shipping container. Discourage stockpiling and stress the importance of keeping only the quantity or amount needed on hand.

Many times, chemicals or products that are not normal stock items are found on the premises. These items may have been purchased at a local home improvement center and brought on the property for use. Discourage this practice, if possible, or remind employees to ask for an MSDS at the time of purchase. If a product is found and no MSDS is available, contact the manufacturer to obtain a copy. If unable to retrieve an MSDS from the manufacturer, here are a couple of resources that may help:

SIRI MSDS Database- http://hazard.com/msds/index.php

Once the MSDS list is compiled and chemicals inventoried, it is necessary to organize the information. There are a variety of ways to arrange this information. A good example is listing the chemicals in alphabetical order and creating a paper-indexed book. MSDS books should be easy to access at all times. Good locations to store master copies of the MSDS books are in the shipping/receiving area, security office, safety representative office, or the agency library.

Another option is to create an electronic database with all the corresponding MSDSs. Electronic versions of MSDSs are acceptable; however, agencies must ensure that:

• “MSDSs are readily accessible with no barriers to employee access. This means reliable devices accessible at all times without the employee needing to ask anyone for permission.
• “Workers must be trained in the use of these devices, including specific software.
• “There must be an adequate back-up system and written plan for rapid access to hazard information in the event of an emergency including power-outages, equipment failure, on-line access delays, etc.
• “The system of electronic access is part of the overall hazard communication program.
• “Employees and emergency response personnel must be able to immediately obtain hard copies of the MSDSs, if needed or desired.”¹

Whether the agency chooses to maintain hard copies or use electronic versions, maintenance and updating is an ongoing process. For more information on electronic databases, review the official OSHA interpretation:

• 2/30/1997 – Manufacturer and employer responsibilities when providing MSDSs electronically
• 01/30/1997 – Material Safety Data Sheets

Labeling of containers is just as important as having the proper MSDS on hand. An unlabeled container can lead to disaster. All containers arriving at the agency should have, minimally, the following information on the label:

• Identity of the hazardous chemical
• Appropriate hazard warnings
• Name and address of the chemical manufacturer, importer, or other responsible party

This information can be communicated in a variety of ways using words, pictures, symbols, or a combination. Labels on containers should not be removed or defaced. OSHA does not require employers to label a portable container intended for immediate use by the employee who transfers the product from a labeled container. However, it is strongly recommended and encouraged that all secondary containers be labeled. There is no standard way to label secondary containers. Some agencies use permanent marker, fill-in-the-blank labels, copied labels from the original container, or tags. Develop and implement a standard labeling method for the agency.

As part of the written hazard communication program, OSHA requires that employees receive training before working with hazardous chemicals. Giving the employee the MSDS to read is not adequate training according to OSHA. The training must be in a form that employees can understand and comprehend. Training topics include:

• Requirements of the Hazard Communication Standard
• Agency specific labeling system
• MSDS review and location
• Job-specific work chemicals
• Physical and health effects of chemicals
• Work practices
• Personal protective equipment requirements
• Agency-specific emergency procedures to follow in the event of an exposure or release

Additional training may be required when a new product or procedure is introduced to a group of employees. Retraining may be required if an employee is observed not following the hazard communication program. 

When an agency uses contractors to perform work at the facility, chemical hazards must be communicated between the contractor and the agency. The agency should develop a procedure for contractors to submit the MSDSs for the hazardous chemicals they will be using. Additionally, the agency should communicate the type of hazardous chemicals located on-site and where to obtain agency-specific MSDSs to the contractors.

It is the agency’s responsibility to provide its employees with a safe and healthy work environment. The hazard communication program is just once piece of the puzzle. Increasing employee knowledge about the chemicals they work with can help reduce and eliminate exposures to hazardous chemicals and the potential illnesses and injuries that might result.

¹ Interactive Learning Paradigms Incorporated. The MSDS FAQ: Frequently Asked Questions about Material Safety Data Sheets. Retrieved November 22, 2004, from http://www.ilpi.com/msds/faq/partd.html#paperless.

Resources

Virginia Department of Labor and Industry, Safety and Health Templates (2002). Hazard Communication Program Guide. Retrieved from: http://www.dhrm.virginia.gov/workerscomp/forms/hazardcommunication.doc

The following training videos are available through the lending library: (http://www.dhrm.virginia.gov)

• Hazard Communication: A Health Responsibility
• Hazard Communication: The Road to Safety
• Hazard Communication: Training for Employees
• MSDS: Read It Before You Need It
• Recognizing & Identifying Hazardous Materials

References

U.S. Department of Labor, Occupational Safety and Health Administration. “Frequently Asked Questions: Hazard Communication (Hazard Communications)”- Viewed November 22, 2004, at http://www.osha.gov/html/faq-hazcom.html.

U.S. Department of Labor, Occupational Safety and Health Administration. “Hazard Communication: Foundation of Workplace Safety Programs.” – Viewed November 22, 2004, at http://www.osha.gov.