When OSHA revised the hazard communication standard in 2012, a lot of emphasis was placed on container labeling, standardized formatting of safety data sheets (SDS) and training. As a result, many employers needed to update their written hazard communication programs.  

Although hazard communication programs are required, OSHA did not set a mandatory interval for plans to be reviewed or updated. However, they must be kept current and accurate so that they continue to provide relevant information to safeguard employees and communicate information about hazardous chemicals that are used in their workplace. 

Periodic reviews are the best way to make sure that chemical inventories are still accurate, the people responsible for coordinating elements of the hazard communication program are still performing needed duties and training continues to addresses chemical hazards appropriately. 

Reviewing the written program

The intent of a written hazard communication program is to identify hazardous chemicals in the workplace and outline the methods that will be used to protect employees from those hazards. It does not need to be complicated or long. In fact, it should clear and easy to read.

When someone reads the program, they should have a clear picture of the types of hazardous chemicals that are stored and used onsite, their locations and how labeling will be used to identify them. They should also be able to find and use SDS and follow the outlined procedures to protect themselves from those hazards.

Reviewing plans will likely identify staff changes, new chemicals that need to be added, obsolete chemicals that need to be removed and revisions in training that go along with the addition or deletion of chemicals. Even in facilities that maintain fairly consistent operations, small changes are likely to occur over time. Program reviews are a good way to identify them. Consider the following during each program review.

Updating chemical inventories

An accurate chemical inventory is the keystone of the program. It may be arranged alphabetically, by location or by another means, but it must contain all of the hazardous chemicals that are present at the facility. The plan should identify who is responsible for maintaining the chemical inventory and the process that they use to keep it up-to-date.

Even if procedures are in place to identify new chemicals that are received at the loading dock and purchasing records are reviewed regularly to look for new chemicals that have been ordered, the best way to make sure that inventories are accurate is to regularly walk through the entire workplace to see if everything on the list matches up with what is being used and stored onsite.

Container labeling

Container labeling provides employees with an immediate reminder of a chemical’s hazards. Chemical manufacturers and distributors are required to provide proper labeling on all containers, but if those chemicals are transferred to other containers for use in a workplace, the employer is responsible for properly labeling the container.

Labeling can be verified during chemical inventory walk arounds. In addition to containers, consider tanks and pipelines that may contain hazardous chemicals and need to be labeled.

Managing safety data sheets

Each item on the chemical inventory must have a SDS. Like managing chemical inventories, keeping track of SDS can be a seemingly endless task.

Revisit the process for obtaining SDS for new chemicals and for reviewing those SDS to determine if new procedures need to be put in place to handle those chemicals or if employee training is needed to address new hazards that are found.

OSHA allows hard copies of SDS to be stored in central locations. They may also be accessed electronically. The key is that employees must be able to access the information at any time with no barriers. So, if SDS are stored electronically, back-up plans must be in place in the event of power outages or if the database goes offline. 

Hazard communication programs must describe how SDS are maintained and how employees can access them.

Procedures for non-routine tasks

Principles of hazard communication are often incorporated into standard operating procedures that are used daily to help keep workers safe. These procedures reflect the way chemicals are regularly used and should be designed in a way that, when followed, prevents employee injuries or illnesses.

From time to time, employees may also perform tasks that are outside of their daily routines. For example, cleaning out tanks or performing other forms preventative maintenance.  When hazardous chemicals are involved in these non-routine tasks, employees may have different exposures than under normal operations.

Like standard operating procedures, hazard communication plans need to identify any special hazards that may be encountered when performing non-routine tasks and the procedures that are to be followed to prevent exposures, injuries and illnesses.

Multi-employer provisions

Contractors, vendors and other outside product or service suppliers who perform work within the facility need to be made aware of the hazardous chemicals that they could be exposed to. They must also supply information (such as SDS) for chemicals that they bring onto the worksite.

Hazard communication programs must establish how SDS will be shared between these entities.  Details on how chemicals are labeled and how outside entities will be protected from hazards should also be provided.

Employee training

Maintaining SDS and properly labeling containers provide employees with daily reminders and resources to work safety with hazardous chemicals. Training provides the foundation for them to understand how these tools prevent injuries and illness.

Training also establishes how controls, procedures and personal protective equipment must be used to provide protection. As chemicals are added or removed, and when new processes are introduced, employees may need additional training.

Plans must document how employees will be trained about chemical hazards as well as the procedures and tools needed to ensure their safety. Details on how to determine if training has been effective should also be part of the plan and should be reviewed periodically, not just following an incident.

Even though OSHA has not established a mandatory schedule for reviewing and revising plans, employers must ensure that their hazard communication plans are accurate and truly reflect the hazards that are present at their facility. It is easy for small changes to go unnoticed, which can leave employees vulnerable to chemical hazards. Establishing a regular schedule to review and update plans will help to prevent chemical exposures and associated injuries and illness.