Hazard Communication (The Right to Know)
Introduction: The Hazard Communication Standard (HCS) is based on a simple concept – that employees have a right to know about the hazards of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring. OSHA designed the HCS to provide employees with the information they need to know. The HCS addresses the issues of evaluating and communicating hazards to workers including issues such as chemical labeling, Safety Data Sheets (SDSs), a written program, and employee training requirements.
OSHA requires that all employers develop a written Hazard Communication Program and train their workers on the aspects the program covers. This is a difficult task for most companies since jobs and tasks change frequently. Each company is different and their program must be tailored to meet the company’s specific needs, by adding or deleting items based on the hazards or potential hazards of the job site. In addition, other employers at the job site affect employees’ chemical exposures and necessitate clear communication between employers to ensure employee protection. A copy of this written program must be available on each jobsite for review by any interested employee.
Frequently overlooked items usually covered by HCS requirements on a construction site include: adhesives, gasoline, paint thinner, grease, cleaners, solvents, and sealers.SDSs are usually very easy to obtain. Retail stores (including hardware and home improvement stores) selling hazardous chemicals to employers having a commercial account are required to provide SDSs upon request.
Containers and Labels: Your company must rely primarily on the use of the manufacturers’ container labels to meet the labeling requirement of the standard. All chemicals on site must be stored in their original container with manufacturers’ label attached. Workers may dispense chemicals from original containers in small quantities for immediate use by a single employee on a single shift. These secondary containers will be labeled with at least the generic name of the product dispensed (e.g., paint, thinner, etc.). Excess chemical will be returned to the original container at the end of the shift or given to a supervisor for proper handling and disposal. Supervisors shall ensure that all containers are labeled with the manufacturers’ label, or equivalent, containing the following information: chemical name, manufacturers’ name and address, and, appropriate hazard warnings such as “Flammable”, “Toxic”, etc. No unmarked containers of any size will be left in the work area unattended.
Hazardous Chemical List & Safety Data Sheets (SDS): A master list of all the hazardous chemicals and copies of SDSs for all hazardous chemicals to which employees may be exposed should be kept at each jobsite and available to all employees at the job site for review at any time.
Employee Information and Training: Each employer is responsible for providing required Hazard Communication training and hazard information to their affected employees and to confirm understanding of such training and instructions. Training must be documented. Prior to starting work, each new employee should attend a health and safety orientation and should receive information and training on the following:
An overview of the requirements contained in OSHA’s Hazard Communication Standard.
- Methods to reduce or prevent exposure to any hazardous chemicals including safe work practices and use of personal protective equipment.
- Location and availability of the written hazard communication program and the MSDSs for any hazardous chemicals present at the job site.
- Physical hazards and health effects of the hazardous chemicals.
- Methods used to determine the presence or release of hazardous chemicals in the work area.
- Steps the company has taken to reduce or prevent exposure to these chemicals.
- Safety emergency procedures to follow in the event of exposure to chemicals.
- How to read container labels and interpret MSDSs to obtain appropriate hazard information.
Summary: It is each company’s responsibility to inform and ensure all employers on the job site exchange the following information: hazardous chemicals list to which employees may be exposed while on the job site; procedures for obtaining SDSs from each employer; precautions employees should take to reduce the possibility of exposure; location of written Hazard Communication programs for each company; and, contact information for the safety coordinator for each company. In order for the Hazard Communication Standard’s to be effective, a commitment must be made by all involved persons to the prevention of incidents or happenings that result in injury and/or illness and to comply with all safety rules.