The Hazard Communication Program

Because the chemical processing industry manufactures chemicals and employs technicians, the CPI is responsible for both sections of the OSHA standard that addresses chemical manufacturers employer requirements and user responsibilities. 

Employers are responsible for the development of a written hazard communication program, a hazardous chemical inventory list, and associated material safety data sheets. This written program should be designed so that it is given to the new employee upon initial assignment. The materials should be site specific, readily accessible by plant personnel, and include an evergreen feature that will keep it up to date. Employers are also required to provide training to employees 

Plant Chemical Inventory List Provided to All Employees Toxicology 

Chemical Hazards Physical Hazards Product Identification PPE 

6 Safe Handling, Storage, and Transportation of Hazardous Chemicals 

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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... 

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. 

Describe the six critical items required in the Hazard Communication program. 

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). 

An explanation of the hazard communication program, including information on labeling and MSDSs... 

Every company which uses hazardous chemicals must have a written hazard communication program that must be available to employees and be provided to OSHA upon request. The Hazard Communication Program must include ... 

AU persons being considered for positions covered by the hazard communication program should receive a brief written statement concerning the program so that they may ask appropriate questions at the time of their job interview. If they are selected, a more extensive docirment should be provided so that they wUl be aware of the exphcit requirements of the standard. 

The HCF hazardous material protection program complies with the applicable parts of SNL/NM Industrial Hygiene Program and Chapter 6, Industrial Hygiene, of the SNL ES H Manual (SNL 1998). Isotope production activities apply the Hazard Communication Program defined in Chapter 6, Section D, Hazard Communication Standard, of the SNL ES H Manual. Other activities, such as standard laboratory operations, apply the Laboratory Standard defined in Chapter 6, Section E, Laboratory Standard, of the SNL ES H Manual. 

The hazard communication programs applied to SNL/NM facilities are defined in Section D, Hazard Communication Standard, and Section E, Laboratory Standard of Chapter 6 of the SNL ES H Manual (SNL 1998). These standards address the 10CFR1910 criteria, training of employees, the availability of Material Safety Data Sheets (MSDSs), and the use of the CIS described in the previous section. HCF activities will follow these two standards appropriate to the... 

Do you know where to access the hazard communication program ... 

Details of the hazard communication program including an explanation of labeling system and MSDSs and how employees can obtain and use hazard information. 

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. 

Workers have the right to information regarding the hazards to which they are, or will be, exposed. They have the right to review plans such as the Hazard Communication Program. They have a right to see a copy of a Material Safety Data Sheet (MSDS) during their shift and receive a copy of an MSDS when requested. Also, information on hazards that may be brought to the workplace by another employer should be available to workers. Other forms of information, such as exposure records, medical records, etc., are to be made available to workers upon request. 

The requirements of the hazard communication program including the location and availability of the written program, required lists of hazardous chemicals, and... 

The Hazard Communication Program defines various terms as follows ... 

Right to know" station binder—Located in the "Right to Know" work station, it contains the company s Hazard Communication Program, the Hazardous Chemicals Inventory List and corresponding MSDSs, and the Hazard Communication Program Review and Signature Forms. 

For the industrial hygiene survey you should, at a minimum, want to inventory all chemicals and hazardous materials at the site, review the hazard communication program, and conduct air sampling in various areas to analyze the air for hazardous contaminants. For specific applications, a noise level survey and a review of the respirator program could be required [2],... 

This information from the regulation indicates that the primary responsibility for conducting the evaluation rests with the chemical manufacturer or importer. The responsibility of the school is to review the information provided and ensure that all chemicals that are used in the workplace that are considered to be hazardous are included within the scope of the hazard communication program. 

For employers using hazardous chemicals, the most important aspect of the hazard communication program in terms of SDSs is to ensure that someone is responsible for obtaining and maintaining the SDSs for every hazardous chemical in the workplace. The list of hazardous chemicals required to be maintained as part of the written program will serve as an inventory. As new chemicals are purchased, the list should be updated. Many companies have found it convenient to include on their purchase orders the name and address of the person designated in their company to receive SDSs. 

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