OccuSafe Industrial Hygiene Consulting

OCCUSAFE UPDATE
Monthly Round Up of Important Ideas and Standards in
Industrial Hygiene and Safety

February 2017

IN THIS ISSUE: Hazard Communication Is Among The Most Cited Serious Violations

In 2016, OSHA continued to include the Hazard Communication Standard (HCS) as one of the ten most cited serious violations. HCS was created to ensure that manufacturers and importers of chemicals evaluate and provide information about these materials. The standard requires that employers create a written hazard communication program, ensure that all containers are labeled and safety data sheets are readily available, and train employees who may come in contact with these chemicals.

To avoid penalties and protect workers, every manufacturer, importer, and user of chemicals must follow the provisions of this standard:

• Identification: Create a complete inventory of your chemicals. Take the broadest view of what is a chemical. The HCS covers chemicals in all physical forms: liquids, solids, gases, vapors, fumes, and mists whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If it is not hazardous, it is not covered. Identify the chemicals in containers, including pipes, and chemicals that are bi-products of work operations. Make a list of all chemicals in the workplace that are potentially hazardous.
• Labeling: In-plant containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings. Employers purchasing chemicals can rely on the labels provided by their suppliers. If the employer subsequently transfers the material from a labeled container to another container, the employer must label that container. The Global Harmonization System (GHS) should be used for most containers.
• Safety Data Sheets (SDS): Chemical manufacturers and importers are required to obtain or develop an SDS – formerly known as material safety data sheets (MSDS) – for each hazardous chemical they produce or import. Employers must have an SDS for each hazardous chemical used and, they must be readily accessible to employees when they are in their work areas during shifts. Under the GHS, the format and information found in an SDS has been standardized. Employers should use an SDS as a basic source of information. For operations that use especially hazardous chemicals, there are no substitute for company and industry standards and procedures.
• Training: Provide training and information to each employee who may work in an area with a hazardous chemical(s) prior to initial assignment or when there is a change in the chemicals or process. Each employee should be able to identify the hazardous chemicals in the area, know the signs and symptoms of exposure, how to protect themselves from exposure, emergency procedures, and the location of the SDSs and other information about the chemicals they work with.

The following checklist will help to ensure compliance with the Hazard Communication Standard:

• Obtain a copy of the rule.
• Read and understand the requirements.
• Assign responsibility for tasks.
• Prepare an inventory of chemicals
• Ensure containers are labeled.
• Obtain a SDS for each chemical.
• Prepare a written program.
• Make SDSs available to workers.
• Conduct training of workers.
• Establish procedures to maintain current program and evaluate its effectiveness.For more information on this topic and to discuss your company’s safety and industrial hygiene needs call OccuSafe at (214) 662-6005 or visit us at www.occusafeinc.com.Industrial Hygiene & Safety, Inc. provides skills and expertise to recognize, evaluate and control hazards and injuries in the areas of industrial hygiene, occupational safety and health. OccuSafe services companies of all sizes in a range of industries.newsletter is published monthly by OccuSafe Industrial Hygiene & Safety Services, Inc. Feel free to forward it to friends and colleagues.