Preparing and Implementing a Hazard Communication Program

All workplaces where employees are exposed to hazardous chemicals must have a written plan that describes how the standard will be implemented in that facility. Preparation of a plan is not just 

The plan does not have to be lengthy or complicated. It is intended to be a blneprint for implementation of your program—an assurance that all aspects of the requirements have been addressed. Many trade associations and other professional groups have provided sample programs and other assistance materials to affected employers. These have been very helpful to many employers since they tend to be tailored to the particular industry involved. You may wish to investigate whether your industry trade groups have developed such materials. 

If OSHA inspects your workplace for compliance with the HCS, the OSHA compliance officer will ask to see your written plan at the outset of the inspection. In general, the following items will be considered in evaluating your program. 

The written program must describe how the requirements for labels and other forms of warning, MSDSs, and employee information and training, are going to be met in your facility. The following discussion provides the type of information compliance officers will be looking for to decide whether these elements of the hazard communication program have been properly addressed. 

In-plant containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings. Chemical manufacturers, importers, aud distributors are required to ensure that every container of hazardons chanicals they ship is appropriately labeled with such information and with the name and address of the producer or other responsible party. Employers purchasing chemicals can rely on the labels provided by their suppliers. If the material is subsequently transferred by the employer from a labeled container to another container, the employer will have to label that container nnless it is snbject to the portable container exemption. See paragraph (f) for specific labeling reqnirements. 

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