Hazard Communication Standard
OSHA's Hazard Communication Standard (HazCom) is based on a simple concept -- that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. When employees have information about the chemicals being used, they can take steps to reduce exposures, substitute less hazardous materials, and establish proper work practices. These efforts will help prevent the occurrence of work-related illnesses and injuries caused by chemicals.
The HazCom standard's design is straightforward. Chemical manufacturers and importers must evaluate 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 (MSDS’s), which must be provided to all purchasers to whom these chemicals/products are shipped. Employers must establish a written workplace program to communicate these types of information regarding any potentially hazardous chemicals to their employees.
Basically, UNM’s principal investigators (or others that possess chemicals) are responsible for developing an inventory of all chemicals in their area, keeping labels on containers as they are received, maintaining material safety data sheets in a “readily accessible to employees” format, and providing information and training for employees.
SRS has developed a written program for general use at UNM in compliance with the OSHA HazCom standard, which is found in Section 4.05 of the SRS Manual. Compliance may be achieved by fully implementing this program. Please print a copy of this written program, and place it in a ring binder along with copies of the other documentation (chemical inventory, MSDS’s, Chemical Hygiene Program, training records etc.) that may be required by the HazCom standard.
Every container of hazardous chemicals must be labeled, tagged, or marked with the required information by the chemical manufacturer or importer. It is not necessary to supplement the manufacturer’s labels, but all missing labels must be replaced as soon as possible.
OSHA’s HazCom standard requires that all end-use containers be labeled. For example, where a solvent may be drawn from a 55-gallon drum into a small safety can, both the drum and the safety can, shall be properly labeled. The secondary label must, at a minimum, include the name of the chemical/material and an appropriate hazard warning (flammable, cancer-causing agent, irritant, corrosive, combustible, etc.).
The HazCom standard requires that a list of hazardous chemicals in the workplace be compiled and maintained. The best way to prepare a comprehensive list, if one has not already been compiled, is to survey the workplace.
The list will eventually serve as an inventory of every chemical/material for which an MSDS must be received and maintained on file. A printed copy of this inventory should be placed in the HazCom ring binder with the corresponding MSDS's.
Material Safety Data Sheets
Chemical manufacturers, importers, and distributors of hazardous chemicals are all required to develop/obtain and provide the appropriate material safety data sheets to the purchasers to whom they ship chemicals. It is the responsibility of each principal investigator or other person responsible for any specific workplace to obtain and maintain a MSDS for every chemical/material onsite or newly purchased chemical. MSDS’s for all hazardous chemicals must be readily accessible to all employees at all times. SRS recommends that a hard copy of all MSDS’s be kept in a ring binder with all the other HazCom documentation.
Once a complete list/inventory has been compiled, of the potentially hazardous chemicals in your work area, check your files against the inventory you have just compiled. If any are missing a MSDS, contact the manufacturer or your supplier, and request one. OSHA requires manufacturers to send MSDS’s within 30 days of a written or telephoned request. Most manufacturers have web sites, which allow customers to retrieve or print a MSDS.
Under the OSHA HazCom standard, the role of MSDS’s is to provide detailed information on each hazardous chemical, including its potential hazardous effects, its physical and chemical characteristics, and recommendations for appropriate protective measures. This information should be useful to supervisors responsible for designing protective programs, as well as to the workers. As new chemicals are purchased, the inventory and MSDS’s should be updated on a monthly basis.
Employee Information and Training
Each employee who may be exposed to hazardous chemicals when working must be provided information and be trained prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes. "Exposure" or "exposed" under the OSHA HazCom standard means that an employee is subjected to a hazardous chemical in the course of employment through any potential route of entry (inhalation, ingestion, skin contact, or puncture) and includes potential (e.g., accidental or possible) exposure.
Annual training must be provided by qualified personnel (Chemical Safety Officers or supervisors) by incorporation into the on-going employee safety training program. This training must warn of any potential health or physical hazard, recommend appropriate safety precautions, and permit access to the applicable MSDS’s. Review key information in the applicable standard operating procedures, and provide the appropriate personal protective equipment (PPE), before the employee begins the job. Assure that these PPE are properly worn and maintained.
Although employees obtain information regarding hazards and protective measures through written labels and material safety data sheets, it is through effective information and training that workers will learn to read and understand such information, determine how to acquire and use it in their own workplace, and understand the risks of exposure to the chemical in their workplaces as well as the ways to protect themselves. A properly conducted training program will provide reasonable assurance of comprehension and understanding.