HazCom: Breaking Down the Requirements

Rachel Krubsack, EHS Editor

Aug 23, 2022

The HazCom Standard affects over five million workplaces and remains one of the most confusing OSHA regulations. Following are its basic requirements.

Written hazcom program

Employers who have hazardous chemicals in the workplace must develop, implement, and maintain a written hazcom program.* This is basically a written record of what your company has done and will do to comply with the HazCom Standard. The program must include a chemical inventory, which is a list of all hazardous chemicals present in the workplace, including those that are stored or are not in use. It’s important to remember that HazCom covers chemicals in all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered by HazCom.

*Note: The written program requirement does not apply to laboratories or workplaces where employees only handle sealed containers of hazardous chemicals, such as warehouses and retail sales.

Safety data sheets (SDSs)

Employers must maintain a safety data sheet (SDS) for each hazardous chemical in the workplace, and it must be specific to the product and manufacturer. If, under normal conditions of use, employees do not open sealed containers of hazardous chemicals, such as in warehousing or retail sales, you need only maintain the SDSs that are sent with incoming shipments.

Labels

Employers are not required under Hazcom to re-label already labeled containers, however, there are several situations in which you may need to do so:

1. If the received quantity of a chemical is broken down into smaller containers, you must label additional containers;

2. Labels that fall off or become unreadable must be replaced;

3. Relabeling incoming containers for a company-wide uniform labeling system.

Training

Training for workers exposed to hazardous chemicals must cover:

• The details of the written hazcom program, including information about shipped container labels and any workplace labeling system you use;
• How to obtain and use the hazard information on an SDS;
• What operations have hazardous chemicals, including by-products;
• Location and availability of the written program, chemical inventory, and SDSs;
• How you monitor for hazardous chemicals;
• Hazards of chemicals in the work area; and
• Measures they can take to protect themselves like work practices, emergency procedures, and personal protective equipment (PPE).

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