OSHA’s hazard communication standard (HCS) provides the requirements for communicating the hazards posed by workplace chemicals. Its purpose is to ensure that the hazards of all chemicals are evaluated, and that information concerning these hazards is conveyed to both employers and employees.
The five main components of the HCS are hazard evaluation, a written hazard communication program, safety data sheets (SDS), labeling and other hazard warnings, and employee information and training.
Chemical manufacturers or importers are required to evaluate the chemicals they produce or import to determine if they are hazardous and, if so, what the chemical hazards are. The manufacturers or importers must use the best scientific evidence available in making this evaluation and develop an SDS for each hazardous chemical. Employers who don’t produce or import chemicals are not required to perform this chemical evaluation, but may rely on the manufacturer’s or importer’s evaluation and SDS for their hazardous chemicals.
Written Hazard Communication Program
If you have employees who use hazardous chemicals, you must establish and maintain a written hazard communication program. It must include:
- A listing of all hazardous chemicals used.
- A complete SDS for each hazardous chemical listed/used.
- Provisions for employee awareness and training.
- Labeling and hazard warning information.
Safety Data Sheet (SDS)
You must have an SDS for each hazardous chemical used in your workplace. The SDS must be readily accessible to the employees who use the chemical. The SDS must include the following:
- The name or identity of the chemical as used on the container label.
- A listing of the hazardous ingredients.
- Physical and chemical characteristics of the chemical (vapor pressure, flash point, boiling point, etc.)
- The physical hazards of the chemical such as fire, explosion, or reactivity.
- The chemical’s health hazards, including signs and symptoms of exposure.
- The primary routes of entry into the body.
- OSHA or ACGIH exposure limits, or manufacturer’s recommended limits.
- Whether the chemical is a carcinogen (cancer-causing agent).
- Precautions for safe handling and use.
- Applicable exposure control measures, and emergency and first aid procedures.
- The date of preparation or revision of the SDS.
- The name, address, and telephone numbers of the manufacturer or importer.
Labeling and Other Hazard Warnings
The chemical manufacturer or importer is responsible for ensuring that each chemical container leaving its facility is appropriately labeled with the identity of the hazardous chemical, appropriate hazard warnings, and the name and address of the manufacturer or importer. Employers are responsible for ensuring that each container of hazardous chemical in the workplace is labeled or marked with the identity of the chemical and appropriate hazard warnings. Portable containers into which hazardous chemicals are transferred for immediate use, are the only exceptions.
Employee Information and Training
Employers must provide employees with information and training on hazardous work area chemicals upon initial assignment. Employers are also required to train employees whenever a chemical presenting a new hazard is introduced into the work area. Training should include:
- Location of the written HCS program, SDS, and hazardous chemical listing.
- Operations where hazardous chemicals are present.
- Physical and health hazards of the chemicals that employees use.
- OSHA Hazard Communication Standard (29 CFR 1910.1200).
- Details of your written HCS program, including an explanation of the labeling system and SDS.
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (monitoring, odor, appearance, etc.).
- Measures employees can take to protect themselves from the chemicals in their workplace (appropriate safe work procedures, protective equipment, etc.)
Certain items do not fall under the scope and application of the OSHA HCS because they are usually covered by other federal regulations. A partial list of some of these generally exempt items includes:
- Hazardous wastes as defined by the SWDA and RCRA
- Tobacco or tobacco products
- Food or alcoholic beverages intended for personal consumption by employees while in the workplace or for retail sale
- Personal medications as defined by the Federal Food, Drug and Cosmetic Act
- Cosmetics for sale in a retail establishment or for personal use by employees
- Biological hazards
- Ionizing and non-ionizing radiation
Consumer products as defined by the Consumer Product Safety Act.
OSHA 29 CFR 1910.1200
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NOTICE: This guide may make reference to the Occupational Safety and Health Administration (OSHA) regulations; however the guide is not legal advice as to compliance with OSHA or other safety laws, codes, or regulations. Compliance with OSHA and other safety laws codes or regulations, and maintaining a safe work environment for your employees remains your responsibility. WCF Insurance does not undertake to perform the duty of any person to provide for the health or safety of your employees. WCF Insurance does not warrant that your workplace is safe or healthful, or that it complies with any laws, regulations, codes, or standards.