How to comply with OSHA Hazardous Material standard
Know the standard. The Occupational Safety and Health Administration (OSHA) hazard communication standard (HCS), also known as the “employee-right-to know” standard is found at 29 CFR 1910.1200 of the general industry standards and incorporated into the construction standard at 29 CFR 1926.59. HCS and chemicals.
Develop a chemical inventory list. An employer should walk around the business grounds and surrounding areas, recording the product names of all chemicals, along with the manufacturers’ names, addresses and telephone numbers. Something as simple as a tube of caulking compound is a product that contains chemicals for which an employer must maintain an MSDS and list the product on the chemical inventory. Each chemical’s location also should be noted. (This is a good time to properly dispose of half-empty and unneeded cans of paint, adhesive and other materials.) The completed chemical inventory list should be kept with the written program because it may need to be amended as new chemicals are purchased.
Sample Chemical Inventory List (The following information should be gathered for each product used)
- MSDS on file? Y/N
- ID Number
- Product Name
- Manufacturers’ Name and Address
- Manufacturers’ Telephone Number and Emergency Telephone Number
Label all containers. All containers should be labeled with at least the following information:
- Identity of the chemical
- All potential hazards associated with the chemical
- Manufacturer’s name, address and telephone number
One common problem facing companies is the use and labeling of portable containers. Portable containers should be dedicated for one specific use and labeled with the identity of the hazardous chemical inside and appropriate hazard warnings so employees will have general information as to the hazards relating to the chemical. The employer is not required to label portable containers into which hazardous chemicals are transferred from properly labeled containers when the material transferred is for the immediate use of the person performing the transfer. For example, if paint thinner is poured from a labeled original container into a bucket for the purpose of cleaning some parts, the bucket does not need a label if the person transferring the thinner is one who will use it immediately.
OSHA states containers of this type do not need to be labeled if the entire contents are used in one shift by only one person, with the contents being used completely or returned to their original containers. The containers cannot be passed from one employee to another, and employees cannot leave unlabeled, partially filled containers overnight.
Labels are available from any safety supply company. For maximum employee comprehension, labels should be as simple as possible. One style of labeling should be used consistently. Color-coded labels accompanied with numbers and pictures or icons are helpful when there are crew members who do not read English.
Obtain MSDSs. An MSDS (Material Safety Data Sheet) is needed for each chemical at the workplace. If an MSDS is not received with a shipment, the manufacturer should be contacted to request one for inclusion in the MSDS file. A MSDS request letter should be sent and retained as evidence of due diligence to obtain the required MSDS.
- Sample MSDS Request Letter
- Material Safety Data Sheet (MSDS)
- MSDS DEFICIENCIES CHECKLIST
- Contractors Notification
Develop a written program. Each written program must contain the following information:
- Container-labeling information
- Material safety data sheets (MSDS)
- Methods of training
- Chemical inventory lists
- Hazards of non-routine tasks
Provide training. The goal behind HCS training is to provide employees with information and training about hazardous chemicals they may encounter in the workplace. Training may address broad categories of hazards (e.g., explosives, flammable liquids, carcinogens) or each specific hazardous chemical (by label and MSDS) that the employee may encounter in the workplace. Employers are responsible for administering additional training when the hazards for particular employees change or new employees are hired. All training should be documented with the date of training, topics covered during the training session and the trainer’s name.
The minimum OSHA training requirements include:
- Methods and observations that may be used to detect the presence or release of hazardous chemicals in the work area (such as monitoring conducted by the employer, visual appearance or odor of hazardous chemicals when being released, and so on). The MSDS describes these characteristics.
- The physical and health hazards of all chemicals in the work area
- The measures employees can take to protect themselves from these hazards; including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals. These may include work practices, emergency procedures and personal protective equipment (PPE) to be used.
- The details of the hazard communication program developed by the employer, including an explanation of the labeling system and MSDSs, and how employees can obtain and use the appropriate hazard information.
- An explanation of hazard communication, including a description of company operations where chemicals are present, explanation of the company’s written hazard communication program and its contents, location of the written program, and means by which employees can obtain a list of hazardous chemicals and MSDSs from the employer.