Hazard communication, in five short modules
5 modulesWhat the standard is for
Describe the purpose of the hazard communication standard and the work it covers.
Every chemical produced or imported has to be evaluated for its hazards, and what that evaluation finds has to reach the people who work with it. That is the hazard communication standard in one sentence. It applies to any chemical known to be present in the workplace in a way that could expose an employee under normal conditions of use, or in a foreseeable emergency. Notice how wide that is. It is not only the drums in the store. It is the cleaning product under the sink and the solvent someone brought in for a single job. The standard does not ask you to remove every hazard from the building. It asks that nobody works beside one without knowing it is there and what it does.
Check: Does the standard cover a chemical that is only used during an emergency?
Who classifies, and who passes it on
Distinguish the duties of a chemical manufacturer from the duties of an employer.
Two different jobs sit behind the same label. Chemical manufacturers and importers classify the hazards of what they make. They evaluate it, they decide which hazard classes it falls into, and they put that on the label and the data sheet that travel with the container. Employers are not required to classify anything. What employers must do is pass on the classification they receive, keep it available, and make sure the people downstream can act on it. If you buy a solvent, you rely on the classification that came with it. If you make one, the evaluation is yours. Getting that split right matters, because a container that arrives unlabelled is not a paperwork problem you can quietly fix at the receiving dock.
Check: Your site buys a cleaning chemical. Who is responsible for classifying its hazards?
The written program
Identify what a workplace hazard communication program has to contain.
Each workplace needs a written hazard communication program, and it is a short document with a specific job. It describes how labels will be handled, how safety data sheets will be kept and reached, and how training will be delivered. It also lists the hazardous chemicals present in the workplace. That list is the part that tends to go stale, because chemicals arrive faster than documents get revised. The program has to be available to employees who ask for it. Treat it as the map of your own system rather than a file that exists to be produced during an inspection. If someone new asks where the data sheets are and the program cannot answer that, the program is not finished.
Check: Name the three areas a written hazard communication program has to describe.
Reading a label
Identify the six required elements on a shipped container label.
A shipped container carries six things, and once you know them a label stops being decoration. There is the product identifier, so you know what it is. A signal word, which is either danger or warning. Hazard statements, saying what it can do to you. Pictograms, the red bordered diamonds that carry the same message at a glance. Precautionary statements, saying what to do and not do. And the name, address and telephone number of the manufacturer, importer or other responsible party. Workplace containers can be labelled differently, as long as the employee still gets the identifier and the hazard information. What is never acceptable is a container someone has filled and left with nothing on it.
Check: Which two signal words can appear on a shipped container label?
Data sheets and training
Explain when training is required and how data sheets have to be made available.
Safety data sheets follow a fixed sixteen section order, so the same information is always in the same place no matter who wrote the sheet. Section four is first aid. Section eight is exposure controls. You learn the order once and it works forever. Those sheets have to be readily accessible to employees in their work area during each work shift, which rules out a locked office and a promise to fetch it tomorrow. Training runs alongside them. Employees are trained on the hazardous chemicals in their work area at the time of their initial assignment, and again whenever a new chemical hazard is introduced. Training covers detection, the physical and health hazards, protective measures, and how to read the labels and the sheets.
Check: When does an employee have to be trained on a chemical hazard in their area?