Hazardous Materials – Hazard Communication Standards

In the workplace, there are certain types of hazards that are quite clear.  For example, the idea that injuries could result due to a fall down a long, slippery metal stairwell, or through accidental contact with a rapidly-spinning steel blade do not need to be explained to anyone.  However, there are scenarios where the dangers are not so immediately obvious, making it difficult for workers to know exactly which precautions they need to take and what type of personal protective equipment they need to wear.

The use of industrial chemicals in the workplace represents one such gray area, and the Occupational Safety and Health Administration has published a series of comprehensive guidelines and regulations aimed at providing a clear system of communicating these types of hazards to the employees who might encounter them.  It is important to note that risk managers are not responsible for actually determining which chemicals are dangerous and to what degree – OSHA’s Hazard Communication Standard already places that burden on chemical manufacturers.  What is required is that managers ensure that their workers are fully informed as to the nature of the chemicals they are either working with or near as they go about their daily tasks.

Once risk managers have surveyed a jobsite and identified which chemicals are present that could pose a threat to employee health, the next step is to communicate this information to workers.  This needs to be accomplished in a number of ways.  A written plan must be produced which inventories the chemicals in question, and it must be accompanied by the material safety data sheets for each.  It has to further elaborate on the types of labeling and warnings that are used in the facility, and how employees have been made aware of all of this information.  Data sheets should be available to workers at specifically designated areas throughout the facility, so that they might inform themselves further of the hazards that have been already presented to them in training.

OSHA requires that a written plan be accompanied by an extensive labeling process that identifies all dangerous chemicals not only as potentially hazardous, but also including their chemical or trade name (depending upon which is a better identifier) and a hazard warning describing the potential dangers posed by the chemical.  These dangers must be specific – for example, if the chemical is combustible in the presence of a spark, this must be noted, and if it causes burns upon exposure to the skin, this must also be included.  These labels must be affixed to containers, pipes, and other systems where hazardous chemicals can found, and the labels must be visible to workers.  This means that when moving chemical storage units from point A to point B, the labels must constantly face outward no matter where the containers are deposited.

A chemical labeling policy is a process that must be continually evaluated and updated in order to measure its effectiveness and also to keep it up to date with any changes that are made to a facility or jobsite.  Risk managers must remain vigilant to ensure that they fully comply with OSHA regulations concerning hazard communication.