Risky Business: Conquering the Hazard Communication Standard
Risky Business: Conquering the Hazard Communication Standard
OSHA’s Hazard Communication Standard (HCS) is long, and some parts of it are technical, but the basic concepts are simple. In fact, you have most likely been meeting most or all of the requirements for years. In other words, you have:
- A written hazard communication plan
- Chemical inventory list
- MSDSs
- Products labeled
- Training on chemical hygiene in place
If that’s the case, then you may find that you simply need to tweak your HazCom program here or there. If you are operating in an OSHA-approved state plan, for example in Minnesota, California or Washington, you must comply with the state's requirements, which may be different than those of the federal rule. Many of the state plans had hazard communication or right-to-know laws in place before the federal rule was put in effect. According to what we’ve observed at SafeLink over the past year, this standard is being more closely applied during OSHA visits of dental laboratories.
The HCS covers both physical hazards (such as flammables, corrosives, and harmful dusts), and health hazards (such as irritation, lung damage, and cancer). Most chemicals used in the workplace have some hazard potential, so the HCS will probably apply to every product you use. One difference between this standard and other OSHA standards is that this one is performance oriented. That means that you have the flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific, rigid requirements. It also means that you have to exercise more judgment to implement an appropriate and effective program. This is where things get tricky. A good example of exercising judgment is how you choose to communicate hazards of chemicals to your employees and how you determine the hazard rating of a particular chemical product.
Identify Hazardous Chemicals in the Workplace
The standard requires an inventory list of hazardous chemicals in the workplace as part of the written hazard communication program. The list will eventually serve as an inventory of everything for which an MSDS must be maintained. In the beginning, however, preparing the list will help you complete the rest of the program since it will give you some idea of the scope of the program required for compliance in your facility.
The best way to prepare a comprehensive list is to dig in and survey the workplace. The broadest possible perspective should be taken when doing the survey. Sometimes people think of chemicals as being only liquids in containers. The HCS covers chemicals in all physical forms - liquids, solids, gases, vapors, fumes, and mists - whether they are contained or not.
Look around, identify chemicals in containers, including pipes, but also think about chemicals generated in the work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Read 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 your inventory list the location(s) of the products within the workplace, and an indication of the hazards as found on the label. Even though this information does not have to be listed, it will save you time and help you with your overall health and safety program.
Employee Information and Training
Information and training is a critical part of the hazard communication program. This is the part that OSHA is taking a close look at in dental labs. Employees must be able to identify verbally the hazards of the chemicals that they’re working with. Having MSDSs and labeling containers is not enough. Worker training must include learning how to read and understand this information, determine how it can be obtained and used in their own workplaces, and understand the risks of exposure to the chemicals in their workplaces as well as the ways to protect themselves.
Each employee who may be exposed to hazardous chemicals when working must be provided information and trained prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes. A method that is recommended is to prepare a Job Safety Analysis (JSA) that includes working with the hazardous chemicals. JSA's are synonymous with many companies' Standard Operating Procedures (SOP) and apply primarily to hazardous operations or potentially hazardous operations. JSA is a procedure used to review work methods and uncover hazards that might result in incidents/accidents. The JSA will provide a framework for incident/accident analysis. Next month, Risky Business will provide details on the preparation of a Job Safety Analysis.
