Hazard
Communication Standard
Exposure to certain chemicals can
cause or contribute to many serious health effects, including
heart ailments, cancer,
central nervous system disorders, kidney and lung damage,
sterility, burns, and severe skin rashes. Some chemicals
may also be safety hazards and have the potential to cause
fires and explosions and other serious accidents.
Because of the seriousness of these safety and health problems,
and because many employers and employees know little or nothing
about them, OSHA has developed a framework called the Hazard
Communication Standard (HCS). The basic goal of
the standard is to ensure that employers and employees know
about work hazards, and know how to protect themselves.
In addition to the Hazard Communication
Standard, OSHA has developed a detailed set of rules dealing
with specialized
topics such as storage of flammable materials, compressed
gases (including oxygen), and other materials which are often
stored in healthcare facilities. A list of titles,
together with link to the text the rules, may be found at
the OSHA
website
What is covered under the Hazard Communication Standard
(HCS)?
The HCS covers all chemicals imported
into, produced, or used in U.S. workplaces. It establishes
uniform requirements to make sure that the hazards of each
of these chemicals
are evaluated, and that this hazard information
is transmitted to employers who deal with the
chemicals and to employees who might be exposed to them.
Note first that this applies to all hazardous
chemicals. The HCS covers both physical hazards (such
as flammability) and health hazards (such as irritation,
lung damage, and cancer). Most chemicals used in the
workplace have some hazard potential, and thus will be covered
by the rule.
How does the HCS work?
The standard's design is simple. Chemical manufacturers
and importers are responsible for evaluating the hazards
of the chemicals they produce or import. Using that
information, they must then prepare labels for containers,
and more detailed technical bulletins called material safety
data sheets (MSDSs).
Employers that "use" hazardous chemicals must have a program
to ensure that this information is provided to exposed employees. "Use" means
to package, handle, react, or transfer. This is an
intentionally broad scope, and includes any situation where
a chemical is present in such a way that employees may be
exposed under normal conditions of use or in a foreseeable
emergency.
In other words, your chemical supplier is responsible for
ensuring that the appropriate evaluation has been performed
and that the material is available to you, but you (as a
healthcare facility) are responsible for making sure you
have obtained the information and have communicated it to
anyone in your workplace who may be affected by it.
One difference between this rule and many others adopted
by OSHA is that this one is performance-oriented. That
means you have the flexibility to adapt the rule to the needs
of your workplace, rather than having to follow specific
rigid requirements. It also means that you have to
exercise more judgment to implement an appropriate and effective
program.
Are you located in a "State Plan" State?
If you are operating in a state with
an OSHA-approved State Plan, you must comply with your
State's requirements, which
may be different from those of the Federal rule. Many
of the "State Plan" States had hazard communication
or "right-to-know" laws prior to promulgation of the federal
rule. Employers in State Plan States should contact
their State OSHA Offices for more information regarding applicable
requirements. Use the HERC
state OSHA locator to determine if you are located in
a state with an approved OSHA program.
The remainder of this section describes
how to prepare a written hazard communications program,
which is a key requirement
of the Hazard Communication Standard. Other sections
in Managing Hazardous Materials cover important elements
such as purchasing materials, inventory control, labeling,
storage, and materials segregation. These practices
will help you comply with the rules in a cost effective manner. Also,
there is a list of additional resources that may further
improve your understanding of these rules and assist with
compliance.
Written hazard communication program
Employers must develop, implement, and maintain at the workplace
a written, comprehensive hazard communication program. The
written plan should include:
- who is responsible for the various aspects of the program
in your facility,
- a list of hazardous chemicals in the workplace (hazard
inventory),
- how the requirements for labels and other forms of warning,
materials safety data sheets, and employee information
and training, are going to be met in your facility.
The written program does not have
to be lengthy or complicated. Some
healthcare facilities may be able to start with an existing
written program from another facility and adapt it to their
own facility. Several example programs can be found
under More Resources
Although these examples may be helpful,
you must remember that the written program has to reflect
what you are actually
doing in your workplace. You can use the example as a basis
to get you started, but expect to do some rewriting. You
will need to adapt it to address the specific circumstances
in your facility. It is not a good idea simply to write up
the plan, and then to file it away and forget it. The
regulations specify that your written program must be available
to
- employees and their designated representatives
- the Assistant Secretary of Labor for Occupational Safety
and Health (i.e. to the OSHA inspector, if he or she requests
it)
- the Director of the National Institute for Occupational
Safety and Health (NIOSH)
In addition, in states with state
plans, you may also be asked to make your program available
to the appropriate state
authorities. It is worth the effort to review the plan
periodically to make sure it covers any changes that may
have occurred in your facility or your range of operations. At
a minimum, that will make it more likely that your staff
will know where to find the written plan if someone asks
to see it.
The rest of this section deals with several specific topics
that your written hazard communications program must address,
including:
Each of these items is covered in more detail in the following
paragraphs.
Identifying responsible staff
Compliance with HCS is not a "one shot deal". Hazard
communication will be a continuing program in your facility. In
order to have a successful program that will both protect
your employees and pass inspections, you must assign responsibility to
specific individuals. This applies both to
the initial activities (plan writing and getting the facility
into compliance in the first place) and to ongoing activities.
In some cases, these activities may
be part of current job assignments. For example, Site Supervisors
are frequently
responsible for on-the-job training sessions. If you identify
which employees will be responsible for implementing the
plan and get them involved early in the program design process,
your plan will be carried out more effectively. You
will also get feedback that will help you evaluate the program.
For any safety and health program, success depends on commitment
at every level of the organization. This is particularly
true for hazard communication, where success requires a change
in behavior. This will occur only if employers understand
the program and are committed to its success, and if the
people presenting the information motivate employees.
You can refer to the written program examples listed below for
ideas on establishing roles and responsibilities.
Hazard inventory
As part of your written hazard communication
program, the standard requires you to prepare a list of
all of the hazardous
chemicals in the workplace. The list will eventually
serve as an inventory of everything for which you must maintain
an MSDS. But even from the outset, preparing the list
will help you complete the rest of the program, since it
will give you some idea of the scope of the program required
for compliance in your facility.
The best way to prepare a comprehensive list is to survey
the workplace. Purchasing records are also
useful for establishing what chemicals have entered the
facility "officially". You should of
course review them, create a list, and determine the
fate of all purchased chemicals once they have been received. But
materials also have a way of flying into facilities under
the radar (as vendor samples, for example). There
is no substitute for actually walking through the facility,
clipboard in hand, looking in all the nooks and crannies,
and taking copious notes.
The broadest possible perspective
should be taken when doing the survey. Sometimes people think of 'chemicals' as
being only liquids in containers. The HCS covers chemicals
in all physical forms" liquids, solids, gases, vapors, fumes,
and mists whether they are 'contained' or not.
During the survey, try to take a comprehensive look around:
- Identify the chemicals in containers, not forgetting
to include chemicals contained in pipes.
- Think also about chemicals that
may be generated during facility operations. For
example, welding fumes, dusts, and exhaust fumes are
all sources of chemical exposures.
- Read labels provided by the suppliers on hazard information.
- Make a list of all chemicals in the workplace that are
potentially hazardous.
For your own information and planning,
you also may want to note on the list the location(s) of
the products within
the workplace, and an indication of the hazards as found
on the label. This will help you as you prepare the
rest of your program. To determine whether a particular chemical
is covered by the rule, you should consider two factors:
- Can the chemical pose a hazard under any plausible circumstances?
- What is the potential that someone in the workplace might
be exposed to the chemical?
If the chemical is inherently non-hazardous,
it is not covered (water, mild solutions of innocuous substances,
etc.). If
there is no potential for exposure, (for example, if the
chemical is
MSDS collection and availability
Once you have compiled as complete a list as possible of
the potentially hazardous chemicals in the workplace, the
next step is to determine if you have received material
safety data sheets for all of them. Check your
files against the inventory you have just compiled. If
any are missing, contact your supplier and request one. It
is a good idea to document these requests, either by copy
of a letter or a note regarding telephone conversations.
If you have MSDSs in your files for
chemicals that are not on your list, figure out why. Maybe you don't use the
chemical any more. Or maybe you missed it in your survey. Some
suppliers do provide MSDSs for products that are not hazardous. These
do not have to be maintained by you. If you have questions
regarding the hazard status of a chemical, contact the manufacturer,
distributor, or importer.
You should not allow employees to use any chemicals
for which you have not received an MSDS. The
MSDS provides information you need to ensure you have
implemented proper protective measures for exposure.
Having gone through this exercise
once, you will not want to have to repeat it too often. You
will find it advantageous to have procedures in place to
confirm that the appropriate
MSDS has been received and is on file in the right location
before any material your facility receives is released for
use in the workplace.
The MSDS is a detailed information bulletin prepared by
the manufacturer or importer of a chemical that describes
the physical and chemical properties, physical and health
hazards, routes of exposure, precautions for safe handling
and use, emergency and first-aid procedures, and control
measures. Chemical manufacturers and importers must develop
an MSDS for each hazardous chemical they produce or import,
and must provide the MSDS automatically at the time of the
initial shipment of a hazardous chemical to a downstream
distributor or user. Distributors also must ensure that downstream
employers are similarly provided an MSDS.
Each MSDS must be in English and include information regarding
the specific chemical identity of the hazardous chemical(s)
involved and the common names. In addition, information must
be provided on the physical and chemical characteristics
of the hazardous chemical; known acute and chronic health
effects and related health information; exposure limits;
whether the chemical is considered to be a carcinogen by
NTP, IARC, or OSHA; precautionary measures; emergency and
first-aid procedures; and the identification (name, address,
and telephone number) of the organization responsible for
preparing the sheet. Copies of the MSDS for hazardous chemicals
in a given worksite are to be readily accessible to employees
in that area. As a source of detailed information on hazards,
they must be readily available to workers during each workshift.
Employers must prepare a list of all hazardous chemicals
in the workplace. When the list is complete, it should be
checked against the collected MSDSs that the employer has
been sent. If there are hazardous chemicals used for which
no MSDS has been received, the employer must contact the
supplier, manufacturer, or importer to obtain the missing
MSDS. A record of the contact must be maintained.
Labels and other forms of warning
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,
and distributors must ensure that every container of hazardous
chemicals 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.
The primary information to be obtained
from an OSHA-required label is the identity for the material
and appropriate hazard
warnings. The identity is any term which appears on
the label, the MSDS, and the list of chemicals, and thus
links these three sources of information. The identity
used by the supplier may be a common or trade name ("Black
Magic Floor Cleaner"), or a chemical name (1, 1, 1 -
trichloroethane). The hazard warning is a brief statement
of the hazardous effects of the chemical ("flammable," "causes
lung damage"). Labels frequently contain other
information, such as precautionary measures ("do not
use near open flame") but this information is provided
voluntarily and is not required by the rule. Labels
must be legible and prominently displayed. There are
no specific requirements for size or color or any specified
test.
With these requirements in mind, if you are inspected, the
compliance officer will be looking for the following types
of information to ensure that labeling is properly implemented
in your facility:
- Designation of person(s) responsible for ensuring labeling
of in-plant containers;
- Designation of person(s) responsible for ensuring labeling
of any shipped container;
- Description of labeling system(s) used;
- Description of written alternatives to labeling of in-plant
containers (if used); and,
- Procedures to review and update label information when
necessary.
Training
Employers must establish a training
and information program for employees who are exposed to
hazardous chemicals in their
work area at the time of initial assignment and whenever
a new hazard is introduced into their work area. At
a minimum, the discussion topics must include the following:
- The hazard communication standard and its requirements.
- The components of the hazard communication
program in the employees' workplaces.
- Operations in work areas where hazardous chemicals are
present.
- Where the employer will keep the written hazard evaluation
procedures, communications program, lists of hazardous
chemicals, and the required MSDS forms.
The employee training plan must consist of the following
elements:
- How the hazard communication program is implemented in
that workplace, how to read and interpret information on
labels and the MSDS, and how employees can obtain and use
the available hazard information.
- The hazards of the chemicals in
the work area. (The
hazards may be discussed by individual chemical or by hazard
categories such as flammability.) Measures employees can
take to protect themselves from the hazards.
- Specific procedures put into effect
by the employer to provide protection such as engineering
controls, work practices,
and the use of personal protective equipment (PPE).
- Methods and observations, such as visual appearance or
smell, workers can use to detect the presence of a hazardous
chemical to which they may be exposed.
- Trainig to protect workers in the event of a spill or
leak of a hazardous chemical from a sealed container.
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