Administrative programs Hazard Communication Program

If a SNUR cross-references a subsection of 40 C.F.R. 721.72 then it will be a significant new use to manufacture, import, or process the SNUR substance unless the manufacturers, importers, processors, and users have a hazard communication program to warn about the risks that the substance poses. This group of significant new uses builds on a system of hazard communication established by the Occupational Health and Safety Administration (OSHA). OSHA has promulgated Hazard Communication Standards that require employers to assess hazards posed by the chemicals they make or import and provide hazard information on labels and in MSDSs. Employers and processors of chemicals that pose hazards must make the labels and MSDSs available in the work place and train their employees in safe handling procedures. 

Responsibilities should be delineated to cover the spectrum of levels within the school or school system depending on the scope of the program. This might include faculty, administrative staff, custodians, maintenance personnel, vice principal, principal, and superintendent. The delineation of responsibilities within a hazard communication program might read as follows ... 

The purpose of a hazard communication program is to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard 29 CFR 1910.1200 and to warn employees about hazardous chemicals and substances in the workplace. ... 

After almost 10 years of aggressive enforcement, Occupational Safety and Health Administration s (OSHA) Hazard Communication rule remains the agency s standard that results in the most numerous fines and penalties. From October 2001 to September 2002, OSHA wrote 2,073 citations for Hazard Communication (HAZCOM) violations that totaled 680,000. The citations occurred because most of the hazard communication programs and their site enforcement were very deficient. In 2010, Hazard Communication violations remained high on the list of the top 10 violated standards and unchanged at number three on the list (Thomas Galassi, 2010, MSDSonline Environmental, Health Safety Blog). 

There are many hazards that exist in a school environment that can result in harm to faculty, staff, and students. These hazards can include falls, cumulative trauma, and natural disasters. The Occupational Safety and Health Administration (OSHA) has created a regulation that is commonly referred to as its hazard communication standard (Occupational Safety and Health Administration, 1996), but it focuses only on the use of hazardous chemicals in the workplace. OSHA addresses the general need for employers to communicate to employees the hazards of various chemicals that are used at work. These chemicals can include products used by maintenance staff, janitorial staff, contractors, visitors, and teachers. Hazardous chemicals must be identified and included within the scope of a school hazard communication program. This chapter will explore the primary components of the hazard communication standard that apply to the use of hazardous chemicals in a school. The regulation will need to be read in its full text to identify all issues, details, and exemptions that might apply. 

U.S. Department of Transportation, Office of Hazardous Materials Initiatives and Training, Research and Special Programs Administration, Transport Canada, and Secretariate of Communications and Transportation of Mexico, 2004 Emergency Response Guidebook, Washington, D.C. (2004). 

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