Hazardous Materials Communications and Guidelines for Employers

OSHA Standards and Requirements

Hazard Communication

In 1994 the top two most frequently cited OSHA citations involved the HazCom Standard, and
often resulted in fines of more than $1,000 per violation.

What is a Hazardous Chemical?

The HazCom Standard applies to all businesses where hazardous chemicals are used in the
workplace. OSHA defines a hazardous chemical as any liquid, solid, or gas that could present a
physical or health hazard to an employee. Examples of hazardous chemicals include cleaning agents,
degreasers, flammables, greases, paints, pesticides, aerosols and compressed gases.

Which Consumer Products are Hazardous Chemicals?

Many employers do not realize that many of the same products they use at home are considered by
OSHA to be hazardous chemicals. Exemptions are made for consumer products, and two criteria
must be met in order to qualify. First, the product must be used in the same quantity and
concentration as it would be at home. Second, it must not be used with greater frequency or for
longer durations than it would be at home. For example, the average American does not buy a
five-gallon bucket of degreaser, nor does the average American clean their bathroom twice a day. If
you use hazardous chemicals in the workplace and do not meet the criteria for exemption, then the
HazCom Standard applies to your business.

Steps Necessary For Compliance

Now that you know whether the Hazard Communication Standard applies to you, you’re probably
wondering "What do I have to do?" The key to successful compliance is to be proactive. Don’t wait
for an accident to happen or for an OSHA inspection to begin thinking about Hazard
Communication. The key is understanding what you must do in order to comply. First, you must
develop a written HazCom plan. Second, you should be sure that your hazardous chemical inventory
list is up to date and complete. Third, make sure that all hazardous chemicals are properly labeled.
Fourth, you must have accessible Material Safety Data Sheets (MSDS) for every chemical that is
covered by the standard. And finally, you must properly train your employees. It’s important to
understand that most HazCom citations involve the absence of compliance — for example, NOT
having a written hazard communication program or NOT properly training your employees.

Again, the key to compliance is proactivity. The first step is to understand what is required of you,
and the second is to take action. Develop your written plan. Train your employees. Do these things
now. True workplace safety is implemented long before accidents happen or OSHA pays a visit.

Why Does OSHA Enforce the Hazard Communication Standard?

The actual OSHA standard, 1910.1200(a)(1) says,

The purpose of this section is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard commun-ication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training.

Elements of the Written Hazard Communication Program

According to the U.S. Department of Labor General Industry Digest, 1994 (Revised):

Employers shall develop, implement, and maintain at the workplace a written hazard communication program for their workplaces. Employers must inform their employees of the availability of the program, including the required list(s) of hazardous chemicals and material safety data sheets.

The actual OSHA standards; 1910.1200(e)(1)(i) & (ii) say,

Employers shall develop, implement, and maintain at each workplace, a written hazard commun-hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.

Hazardous Chemical Inventory

All hazardous chemicals used by the employees in your facility are to be documented in the
Hazardous Chemical Inventory. This listing must be available for inspection by any employee.

The Hazardous Chemical Inventory lists the chemicals in use at that location. Any new hazardous
chemicals received are to be documented in the Hazardous Chemical Inventory before use by any
employee. The Material Safety Data Sheet for any chemical should also be available.


The information on all labels should correspond to the information on the appropriate Material Safety
Data Sheet. All containers must be labeled. Also, piping that carries hazardous chemicals must be
labeled (example — hot water, compressed gases, high pressure water, or high pressure air).
Transfer containers are temporary containers that are used by one person for one shift only. They
are not required to be labeled. According to the U.S. Department of Labor General Industry Digest,
1994 (Revised):

The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked with the identity of the hazardous chemical(s) contained therein and must show hazard warnings appropriate for employee protection.

The actual OSHA standard, 1910.1200(f)(5) says,

(5) Except as provided in paragraphs (f)(6) and (f)(7) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information:

(i) Identity of the hazardous chemical(s) contained therein; and,

(ii) Appropriate hazard warnings, or alternatively, words, pictures,
symbols, or combination thereof, which provide at least general
information regarding the hazards of the chemicals, and which, in
conjunction with the other information immediately available to
employees under the hazard communication program, will provide
employees with the specific information regarding the physical and
health hazards of the hazardous chemical.

The manufacturer’s name, address and emergency phone number should also be on the label. In the
event of an emergency, having the emergency phone number on the label can save valuable time.

Material Safety Data Sheets

As an employer you should have a Material Safety Data Sheet (MSDS) for every chemical that your
employees use or are potentially exposed to. The actual OSHA standard, 1910.1200(g)(8) says,

The employer shall maintain in the workplace copies of the required material safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and other alternatives to maintaining paper copies of the material safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)

How to Read a Material Safety Data Sheet (MSDS)

At first glance, most material safety data sheets are confusing. However, by knowing what’s in each
section you can find the information that you are looking for quickly. Some sections such as
Hazardous Ingredients, Transportation Information and Regulatory Information will be used mainly
by the Safety Director.

OSHA requires all employees to be familiar with the hazards and precautions of the chemicals that
they are working with. As an employee, it is your responsibility to remain familiar with the hazards
and precautions of the chemicals that you are working with. Monthly safety meetings will help you to
review and reinforce this information.

You should not use a chemical that you don’t have an MSDS for. All chemicals in use should be on
the Hazardous Chemical inventory for your area.

Each Material Safety Data Sheet is broken up into approximately eight sections. Those sections
include follows:

PRODUCT IDENTIFICATION — Gives the name of the chemical which is
the same as the name on the corresponding label.

HAZARDOUS INGREDIENTS — Lists names of chemicals that make up this
particular hazardous material.

PHYSICAL CHARACTERISTICS — Lists information such as odor and

FIRE AND EXPLOSION HAZARDS — Gives the flash point (which
determines if it is a flammable, combustible, or neither) and fire fighting

REACTIVITY — Lists types of chemicals that shouldn’t be stored with this
particular chemical.

HEALTH HAZARDS — Look in this section for symptoms of overexposure
and first aid procedures.

PPE that should be used when handling or using this chemical.

SPILL OR LEAK PROCEDURES — What should be done to control a spill or

SPECIAL PRECAUTIONS — Special handling or use instructions are
documented in this section.

TRANSPORTATION DATA — Used for DOT classifications.

REGULATORY INFORMATION — Is this chemical covered by the SARA
Title III or RCRA Hazardous Waste Acts.

Minimum Hazard Communication Training Requirements

Hazard communication training is fairly simple for most employers. The training can be broken down
into two phases.

Conceptual training should include:

- what do you expect your employees to know about the hazards of the
chemicals that they are exposed to

- OSHA Hazard Communication standard

- basic hazards that employees encounter when they work with
hazardous chemicals (fire, health, etc.)

- acute vs. chronic hazards

- what is a Hazardous Chemical Inventory and where is it located in your

- how to read a MSDS and where to find them

- labeling of containers

Practical training should include:

- health and physical hazards of each chemical

- signs of exposure/overexposure

- how to detect the release of a chemical

- PPE to use with each chemical

- special precautions you should take when using or handling

- how to respond in an emergency involving that chemical

- how to handle a spill or leak

A good approach is to do your conceptual training annually and upon hiring or job change. The
practical training is best handled during your monthly safety meetings. A good approach is to cover
the information on the MSDS for one to two chemicals during the monthly safety meeting. Putting
your employees in a room for eight hours and covering a stack of MSDS will probably only result in
a very low retention of the material. By covering small chucks of the MSDS information during
monthly meetings, you will get better retention. During an OSHA Inspection, the compliance officer
will interview employees to test their knowledge of the hazard communication standard. If your
employees are properly trained (i.e. able to answer basic questions about the Hazard
Communication program, MSDS, labeling, hazardous chemical inventory and basic chemical
hazards) you can receive a citation even though your employee spent days in ineffective training. The
actual OSHA standards; 1910.1200(h)(3)(i) through (iv) say,

Employee training shall include at least:

{i} Methods and observations that may be used to detect the
presence or release of a hazardous chemical in the work area (such
as monitoring conducted by the employer, continuous monitoring
devices, visual appearance or odor of hazardous chemicals when
being released, etc.);

{ii} The physical and health hazards of the chemicals in the work

{iii} 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, such as appropriate work practices, emergency
procedures, and personal protective equipment to be used; and,

{iv} The details of the hazard communication program developed
by the employer, including an explanation of the labeling system and
the material safety data sheet, and how employees can obtain and
use the appropriate hazard information.

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