Hazard Communication

What is OSHA’s Hazard Communication Standard?

The HCS established uniform requirements to make sure that the hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated and that this hazard information is transmitted to affected employers and exposed employees.

Chemical manufacturers and importers must convey the hazard information they learn from their evaluations to downstream employers by means of labels on containers and safety data sheets (SDS’s). In addition, all covered employers must have a hazard communication program to get this information to their employees through labels on containers, SDS’s, and training.

Prepare and Implement a Hazard Communication Program

All workplaces where employees are exposed to hazardous chemicals must have a written plan describing the implementation of the standard.

The written plan must:

  1. List the chemicals present at the site,
  2. Indicate who is to be responsible for the various aspects of the program in your facility, and
  3. Indicate where written materials will be made available to employees.

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. The written program must describe how the requirements for labels and other forms of warning, safety data sheets, and employee information and training, have been met at your facility.

Labeling

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 are required to 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.

If the material is subsequently transferred by the employer from a labeled container to another container, the employer will have to label that container unless it is subject to the portable container exemption. The primary information to ensure that labeling will be properly implemented at your company you must show:

  1. Designation of person(s) responsible for ensuring labeling of company containers;
  2. Designation of person(s) responsible for ensuring labeling of any shipped containers;
  3. Description of labeling system(s) used;
  4. Description of written alternatives to labeling of company containers (if used); and,
  5. Procedures to review and update label information when necessary.

Employers purchasing and using hazardous chemicals will primarily be concerned with ensuring that every purchased container is labeled. If materials are transferred into other containers, ensure that these are labeled as well, unless they fall under the portable container exemption.

Reading GHS Labels

OSHA’s HazCom standard uses the GHS system of chemical labels. This system is designed as a universal easy to understand system.

A GHS label consist of:

Product Name – A product identifier is used on a GHS label and matches the product identifier used on the SDS. For mixtures/alloys, the label includes the chemical identities of all ingredients that contribute to acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, skin or respiratory sensitization, or Target Organ Systemic Toxicity (TOST), when these hazards appear on the label. Where a product is supplied exclusively for workplace use, the Competent Authority may give suppliers discretion to include chemical identities on the SDS, in lieu of including them on labels.

Symbol – The GHS label for a substance includes the chemical identity of the substance. The Competent Authority rules for confidential business information (CBI) take priority over the rules for product identification.

Signal Word – The signal word indicates the relative degree of severity a hazard. The signal words used in the GHS are “Danger” for the more severe hazards, and “Warning” for the less severe hazards. Signal words are standardized and assigned to the hazard categories within endpoints. Some lower level hazard categories do not use signal words. Only one signal word corresponding to the class of the most severe hazard should be used on a label.

Hazard Statement – Hazard statements are standardized and assigned phrases that describe the hazard(s) as determined by hazard classification. An appropriate statement for each GHS hazard should be included on the label for products possessing more than one hazard.

Supplemental Information – Supplemental label information is non-harmonized information on the container of a hazardous product that is not required or specified under the GHS. In some cases this information may be required by a Competent Authority or it may be additional information provided at the discretion of the manufacturer/distributor. Supplemental information is used to provide further detail that does not contradict or cast doubt on the validity of the standardized hazard information. It also may be used to provide information about hazards not yet incorporated into the GHS.

Pictograms/Symbols – The GHS symbols are incorporated into pictograms for use on the GHS label. Pictograms include the harmonized hazard symbols plus other graphic elements, such as borders, background patterns or colors which are intended to convey specific information. For transport, pictograms have the background, symbol and colors currently used in the UN Recommendations on the Transport of Dangerous Goods, Model Regulations. For other sectors, pictograms have a black symbol on a white background with a red diamond frame. Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear.

First Aid Statements – First aid for contact with the chemical.

Name and Address of Company – The contact information for the chemical producer.

Telephone number – The phone number for the supplier.

Safety Data Sheets

OSHA requires that companies make SDS’s readily available to employees. Different companies have distinct methods of meeting this requirement.

  • Some companies keep the MSDSs in a binder in a central location (e.g., in the pick-up truck on a construction site).
  • Others, particularly in workplaces with large numbers of chemicals, computerize the information and provide access through terminals.
  • As long as you can get the information when you need it, any approach may be used.

In order to ensure that you have a current SDS for each chemical as required, and that access is provided, this must be in your written program:

  1. Designation of person(s) responsible for obtaining and maintaining the MSDSs;
  2. How such sheets are to be maintained in the workplace (e.g., in notebooks in the work area(s) or in a computer with terminal access), and how employees can obtain access to them when they are in their work area during the work shift;
  3. Procedures to follow when the SDS is not received at the time of the first shipment;
  4. For producers, procedures to update the SDS when new and significant health information is found; and,
  5. Description of alternatives to actual data sheets in the workplace, if used.

Spills

In the event of a chemical spill, the individual(s) who caused the spill is responsible for prompt and proper clean-up. It is also their responsibility to have clean-up materials and equipment appropriate for the chemicals being handled readily available. For these, and other safety reasons it is very important to know the properties (e.g. hazards, volatility, reactions, etc.) of the chemicals you work with or handle. Use the SDS sheets on each chemical to learn the appropriate level of protection required, proper handling and cleanup of chemicals used.

A hazmat incident is an incident in which a hazardous material, including motor oil, paint, thinner or other hazardous material is unintentionally released into the environment. A spill should be effectively and quickly contained and cleaned up. A spill needs to be promptly reported. Employees should clean up the spill only if properly trained and protected. Employees who are not trained in the proper cleanup procedures, in addition to reporting the incident should warn others of any hazard and leave the hazardous area. If there is a fire or medical attention is needed, contact emergency services 911 immediately.

Spill responsibilities

The designated person has primary responsibility for coordinating the response to emergencies, including spills. All employees should follow these procedures in the event of a spill.

Employees at the scene of the spill will immediately notify their supervisor or designee of the incident, giving the exact location of the spill, type of product released, and the approximate amount released. If at a site other than a plant location, employee will also indicate how they can be contacted (telephone number, company radio, pager number, etc.)

Personal protective equipment will include chemical resistant gloves, aprons, footwear, and splash proof eye/face protection. Employees at the scene will make every attempt to contain the spill to the smallest possible area, unless there is an eminent danger to life.

The employee should secure the source as much as possible with absorbent pads, socks, etc. keeping unauthorized individuals away from the scene. The designated person will determine the severity of the release and will request assistance from a designated cleanup organization (DCO), if necessary. The DCO will respond to the release location to begin containment and remediable operations.

Spill Prevention Measures

The following measures are intended to minimize the potential for a spill/release of a hazardous material into the environment: Properly label all containers so that the contents are easily identifiable. If possible, move material handling indoors, under cover, or away from storm drains or sensitive water bodies. Cover outside storage areas either with a permanent structure or with a seasonal one such as a tarp so that rain cannot come into contact with the hazardous material and the run off move the hazardous material into the environment.

Check containers often for leaks and spills. Replace containers that are leaking, corroded, or otherwise deteriorating with containers in good condition. Collect all spilled liquids and properly dispose of them. Store, contain, and transfer liquid materials in such a manner that if the container is ruptured or the contents spilled, they will not discharge flow or be washed into the storm drainage system, surface waters, or groundwater. Place drip pans or absorbent materials beneath all mounted taps and at all potential drip and spill locations during the filling and unloading of containers. Any collected liquids or soiled absorbent materials should be re-used/recycled or sent for proper disposal.

If paved, sweep and clean storage areas monthly, do not use water to hose down the area unless all of the water will be collected and disposed of properly. Install a spill control device (such as a tee section) in any catch basin pans that collect runoff from any storage areas if the materials stored are oil, gas, or other materials that separate from and float on water. This will allow for easier cleanup if a spill occurs. When feasible, protect catch basins while conducting field activities so that if a spill occurs, the material will be contained.

Spill Classifications

Small spills – This includes any spill where the major dimension is less than 18 inches in diameter.

Medium spills – These are spills where the major dimension exceeds 18 inches, but is less than 6 feet.

Large spills – Large spills include:

  1. any spill involving flammable liquid where the major dimension exceeds 6 feet in diameter; and
  2. any “running” spill, where the source of the spill has not been contained or flow has not been stopped.

Cleanup Procedures

Small spills may be handled by employees with spill kits. Medium and large spills will normally be cleaned up by the DCO.

Small Spill Clean Up

Wear the proper protective equipment. (Safety glasses or goggles, face shield, respirator, gloves, aprons, footwear, etc.) Quickly contain the spill by stopping or securing the spill source. This might be as simple as closing a valve, uprighting a container, or placing absorbent pads around the spilled material.

Do not endanger yourself. Following this initial response immediately report the incident to the supervisor. Remember that both the spilled material and the absorbent may be considered hazardous waste and must be disposed of in compliance with state and federal environmental regulations. Evaluate the area outside the spill. If the spill is flammable, engines and electrical equipment near the spill area must be turned off.