Got All Your Bases Covered? Assessing Your HazCom Program

Rachel Krubsack, EHS Editor

November 21, 2022

 Cleaning up a spill

Developing and implementing a successful hazard communication program isn’t a one-shot deal. Employers required under the HazCom standard to implement a program should periodically review it to make sure it’s up to date and all the requirements are being met.

A look at what's required

With some exceptions, if you have employees who are exposed to hazardous chemicals, you must:

  • Identify and list hazardous chemicals in the workplace, e.g., create and maintain a chemical inventory.

  • Obtain safety data sheets (SDSs) and labels for each hazardous chemical, if not provided by the manufacturer, importer, or distributor.

  • Implement a written HazCom program, including provisions for proper container labeling, SDSs, and employee training.

  • Communicate hazard information to employees through proper labels, SDSs, and formal training programs.

Manufacturers and distributors of hazardous chemicals have additional responsibilities, including evaluating and classifying chemicals as to their hazards, creating SDSs, and labeling shipped containers with detailed information as described at 1910.1200(f)(1).

Assessing your program

Review and revise your HazCom program as appropriate to address changing conditions in the workplace, such as:

  • The addition of new chemicals,

  • Updated hazards from chemicals currently used,

  • Changes in processes that affect exposures, and

  • Changes to personal protective equipment (PPE) or training.

To ensure you're in compliance:

  • Obtain a copy of the HazCom standard (1910.1200);
  • Read and understand its requirements;
  • Prepare and implement a written HazCom program, which includes the chemical inventory;
  • Identify who has primary responsibility for the written program, and for:
    • Obtaining and maintaining SDSs.
    • Making sure containers in the facility are properly labeled.
    • Labeling shipped containers leaving your facility.
    • Conducting HazCom training.
  • Ensure containers are labeled;
  • Obtain an SDS for each hazardous chemical;
  • Make SDSs available to employees;
  • Inform and train employees;
  • Establish procedures to maintain the program; and
  • Establish procedures to evaluate program effectiveness.

Learn more about how J. J. Keller can help with Chemical Management or call 888.473.4638 for more information.

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OSHA's Hazard Communication (HazCom) Standard is based on the concept that employees have both a need and a right to know the chemical hazards they may be exposed to in their work areas, and how they can protect themselves from those chemical hazards.

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