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Since Houston is a major center for companies that deal with hazardous materials, Hazard Communication Programs are serious business here. The Hazard Communication Standard, or "HazCom,” is usually in the top five most cited violations by OSHA. Insufficient implementation of the HazCom requirements often stems from a company's impression that providing workers with Material Safety Data Sheets (MSDS) and providing employee with a basic safety manual fulfill compliance with the standards.

• A company documented/written Hazard Communication Program
• Regular, documented employee training
• Labels on any hazardous chemicals and warning signage of danger areas
• Material Safety Data Sheets (MSDS)

Normally, an OSHA inspector will ask to see the written Hazard Communication Program during an inspection. The written program needs to be specific to the workplace and must describe the methods the employer will use to inform employees of the hazards involved in routine and non-routine tasks performed. Also, the written program must outline the procedures the employer will use to meet the other requirements: Regular, documented employee training, Labels on any hazardous chemicals and warning signage of danger areas, and Material Safety Data Sheets (MSDS).

Training

Training in the methods, practices, and observations which employees are to use in the recognition of actual and (or) potential health hazards, and measures they should take to protect themselves and others should include complete coverage of the written Hazard Communication Program, Labels, and Material Safety Data Sheets (MSDS). Make sure each employee has received a complete copy of the written Hazard Communication Program and has read and clearly understands it. Ongoing and updated training sessions provided by the employer must also provide to the employee a clear understanding of the overall "HazCom" program and their role in it.

The requirements regarding training are as follows:

• Hazardous chemicals/ situations in their work area[s] at the time of their initial assignment, and whenever a new hazard is introduced into their work area.
• The hazard communication standard requirements must be addressed as part of employee training.
• The location and availability - of the written "HazCom" program, including the required list of hazardous chemicals, and MSDS applicable to their work area(s) or job sites.
• MSDS - proper usage, understanding, and availability must be covered as part of their training.
• The methods and observations that may be used to detect the presence or release of a hazardous chemical, including the physical and health hazards of those chemicals in their work area.
• Labeling Practices for hazardous chemicals and substances in the work place, including any other form of warnings (such as signage for hazardous areas or conditions).
• Company Inventory List of Chemicals used in the workplace and jobsites, identified as they are referenced on the appropriate material safety data sheet.
• The method the company uses In Multi-Employer Worksites to provide the other employer(s) all precautionary information or measures that need to be taken to protect those employees (if exposed) from.
• Measures employees should take to protect themselves, including procedures the employer has implemented to protect employees from such hazard exposure, to include personal protective equipment to be used.
• An explanation of material safety data sheets and how employees can find and use the appropriate information.

The trainer may discuss the particular hazards of chemical, where there are few, or where there are large numbers of chemicals, the training may be done in categories such as flammable liquids, carcinogens, etc. In either case, the training must refer to information on product labels and MSDS.

Employees must be trained on potential new hazards of a new chemical when introduced to their work area[s], if the chemical has a hazard for which they have not been trained, but re-training may be limited to that hazard.

Training sessions must be documented to include a list of employee name(s), date, time, place, subject or topic covered etc., and have each employee in attendance sign-off on an attendance sheet. Training documentation should be filed and maintained.

Labels and Signage

All containers hazardous chemicals need to be marked, labeled, or tagged with the identity of the chemical(s) within, and, must show the hazard warnings necessary for employee protection. The hazard warnings may be in the form of message, words, pictures, symbols, or combination to indicate general information about the hazard of the chemical(s). Labeling and warning requirement guidelines are as follows:

• The chemical manufacturer, importer, or distributor must label, tag or mark with information regarding the identity of the hazardous chemicals of each container with appropriate hazard warnings, and the name and address of the chemical manufacturer, importer, or other responsible party.
• The employer must label, tag or mark with information regarding the identity of the hazardous chemicals of each container with appropriate hazard warnings.
• The employer may use signs/ placards, process sheets, batch tickets, operating procedures, or other written materials in lieu of affixing labels to individual stationary (bulk) process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required as outlined earlier.
• An employer is not required to label a portable container into which hazardous chemicals are transferred from a labeled container for the immediate use by the employee who performs the transfer.
• Employers and employees shall not remove or deface any existing labels or other forms of warnings on incoming containers of hazardous products, unless the container is immediately marked otherwise with the required information.
• Labels or other forms of warning must be legible - printed in English - displayed clearly on the container, and readily available in the work area throughout each work shift. If an employer has an employee who speaks other languages, the information may be added to the material in their language, but must also be presented in English.
• Any significant changes regarding hazards of a chemical, the labels for those chemicals must be revised with the new information prior to being distributed or introduced into the workplace again. Hazardous chemicals shipped to the employer after that time must contain the new information.

The employer must also develop a program in which hazardous chemicals or products that are incoming, stored, transferred into or broken down into smaller containers, or distributed to employees and in workplaces for the labeling and warning sign practices as outlined in this section.

Other forms of warning practices include implementation of proper posting of warning signage for any hazardous area, situation, or condition, that should be conveyed to employees in each workplace, such as "Flammable", "Hard Hat Area", "Safety Glasses Required In This Area", "High Voltage" etc.

MSDS

When an employee uses a hazardous chemical, a material safety data sheets (MSDS’s) must be obtained and filled out. Each sheet must contain at least the following information:

• Label identity of the chemical used.
• The chemical & common name(s) of a single substance, or the chemical & common name(s) of all ingredients which have been determined to be health hazards of a mixture of substances.
• The physical and chemical hazards of the product, such as fire, explosion, vapor pressure, etc.
• The signs and symptoms - of exposure to the hazardous chemical.
• The OSHA permissible exposure limit - ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the manufacture, importer, and/or employer preparing the material safety data sheet.
• Any listing in the National Toxicology Program (NTP) Annual Report on Carcinogens, or whether the product has been found to be a potential carcinogen in the Internal Agency for Research on Cancer (IRAC), or by OSHA.
• Any applicable precautions or instructions for safe handling and use, including appropriate hygienic practices.
• Any Applicable control measures (work practices, personal protective equipment, etc.)
• Emergency and first aid procedures.
• The date of preparation of the MSDS - or the last change to it.
• The name, address, and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the MSDS who can provide any additional information.

The Company must maintain copies of the required MSDS for each hazardous chemical in the workplace, and ensure they are accessible during each work shift to employees when they are in their work area[s].

Each jobsite should to keep a copy of all MSDS’s of the materials on that jobsite, along with the written "HazCom" program and a List of Chemicals, updated when a new hazardous substance is introduced. This will insure that your overall "HazCom" program is addressed, available, implemented, and updated at each worksite.