Hazards communication programs

The most common required program is the Hazard Communication Program (CFR 1910.1200). Nearly every company has hazardous materials on their premises and, therefore, needs a HAZCOM program. The question arises as to what is a hazardous material. If you can t safely wash your eyes with it, consider it hazardous. The standard is obviously more technical, giving the employer exceptions. The most common exception is that if the material used is only maintained in household quantities, it does not have to meet all the requirements of the standard. For most hazardous materials, which usually come in the form of chemicals, a few basic requirements exist. The Hazard Communication program is more thoroughly discussed in chapter 15 dealing with hazardous materials. 

---

A written hazard-communication program must describe the employer s efforts to tell employees about the standard and how it is being implemented at the worksite. 

The HCS was promulgated to provide workers with access to information about the hazards and identities of the chemicals they are exposed to while working, as well as the measures they can take to protect themselves. OSHA s HCS requires employers to establish hazard communication programs to transmit information on the hazards of chemicals to their employees by means of labels on containers, material safety data sheets, and training programs. 

All employers are required to develop, implement, and maintain at the workplace a written hazard communication program. The program must include the following components (1) a list of hazardous chemicals in the workplace, (2) the methods the employer will use to inform employees of the hazards associated with these chemicals, and (3) a description of how the labeling, material safety data sheet (MSDS), and employee training requirements will be met. 

The term "hazardous" refers to any chemical which can affect an employee s health. Effects can range from mildly irritating to potentially highly carcinogenic. If employees may be potentially exposed to hazardous chemicals, the employer is required to develop a written hazard communication program that includes the following ... 

Employers are required to make the written hazard communication program available upon request to employees or their designated representatives... 

Location and availabihty of the written hazard communication program and MSDS. 

OSHA Hazard Communication Standard (29 CFR 1910.1200) The US OSHA s Hazard Communication Standard (HCS) ensures that information about chemical hazards and associated protective measures is provided to workers and employers. This is accomplished by requiring chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and to provide information through labels on shipped containers and MSDSs. Employers with hazardous chemicals in their workplaces must prepare and implement a written hazard communication program, and must ensure that containers are labeled, employees are provided access to MSDSs, and an effective training program is conducted for all potentially exposed employees. The HCS provides workers the right-to-know the... 

Hazard evaluations, warning labels, MSDSs, work area specific training, and written hazard communication program leader s training guide included. 

Kit for medium and small businesses MSDSs, leader s guide, ten student reference guides, two posters, guide book for MSDS data, and fill-in-the-blank written hazard communication program. Industrial Training Systems Corporation, 1992. 

Volume 1 background and legal requirements, employer responsibilities, SARA Title III, sample forms, compliance checklists, label suppliers, and training program index. Volume 2 model hazard communication program. 

Workplace situations followed by self-test multiple choice and true/ false questions, MSDSs, labels, and written hazard communication program. 

Hazard communication programs, commonly referred to as HazCom programs, help create a safer working environment and are required by law. These programs disseminate information about the hazards of all chemicals stored in the warehouse to employers and employees. 29 CFR 1910.1200, Hazard Communication Standard, requires employers to develop and implement written HazCom programs. 

The initial step in pre-incident planning is a risk assessment, based on an inventory of all material stored at the warehouse. This information should be readily available as part of the Hazard Communication program outlined in Chapter 4. The properties and hazards of stored materials should be determined using the material safety data sheets and... 

More than one year after withdrawal of the Hazard Identification proposed standard, the new proposed standard (standard) entitled Hazard Communication, was published in the Federal Register, Volume 47, No. 5, Friday, March 19,1982. It proposes that chemical manufacturers assess the hazards of chemicals which they produce and that all employers in SIC Codes 20 through 39 (Division D, Standard Industrial Classification Manual) provide information to their employees about the hazardous chemicals which they use by meems of a hazard communication program, labels, placards, material safety data sheets, and information and training. 

The National Paint and Coating Association (NPCA) Label Guide and the Hazardous Materials Identification System (HMIS) are then presented. HMIS is the most comprehensive in-plant hazard communication program developed as a single total integrated system. 

Chemical manufacturers, importers, or employers evaluating chemicals shall describe in writing the procedures they use to determine the hazards of the chemical they evaluate. The written procedures are to be made available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director. The written description may be incorporated into the written hazard communication program required under paragraph (e) of this section. 

Employers shall develop and implement a written hazard communication program for their workplaces which at least describes how the criteria specified in paragraphs (f>, (g), and (h) of this section for labels and other forms of warning, material safety data sheets, and employee information and training will be met, and which also includes the following ... 

The employer may rely on an existing hazard communication program to comply with these requirements, provided that it meets the criteria established in this paragraph (e). 

The quality of a hazard communication program is largely dependent upon the adequacy and accuracy of the hazard determination. The hazard determination requirement of this standard is performance-oriented. Chemical manufacturers, importers, and employers evaluating chemicals are not required to follow any specific methods for determining hazards, but they must be able to demonstrate that they have adequately ascertained the hazards of the chemicals produced or imported in accordance with the criteria set forth in this Appendix. 

The ES H Division maintains a web site where MSDSs are available for review for HazCom (Hazard Communication Program) and chemical hygiene plans. MSDS data are collected to satisfy EPCRA reporting requirements and to complete waste disposal forms. All chemical disposals are performed in accordance with General Waste Management Requirements (LIR 404-00-02.2). The Facility and Waste Operations Division is responsible for pickup of waste and deposition to treatment facilities. 

CFR1910.1200(h)(2)(iii) 4.1.3.3 The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and material safety data sheets required by this section. 

CFR1910.1200(h)(3)(iv) 4.1.4.4 The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees ean obtain and use the appropriate hazard information. 

Section 4.1 consolidates the requirements for general employee information and training on hazardous chemicals in the workplace such as the location, availability and content of material safety data sheets (MSDSs) for the chemicals and chemical products being used or stored, methods to detect the presence of hazardous chemicals, personal protective measures, the details of the workplace hazard communications program, etc. 

B. Significant New Use if Used Without a 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. 

---