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Hazard Communication Program for Construction

F Marie Athey OHST

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F Marie Athey OHST | September 30, 2013 | Comments Off on Hazard Communication Program for Construction

Hazard Communication Program for Construction

The third learning  module of OSHA 10 training found on OSHAcampus.com focuses on the importance of a written hazard communication program in the workplace and safely handing chemicals. According to OSHA’s Hazard Communication Standard, all workplaces where employees use and handle hazardous chemicals are required to have a written HAZCOM program. This program should detail how the facility will implement training.

We understand that drafting and implementing a HAZCOM program could be confusing to both employers and employees. Essentially though, employers should bear in mind the program needs to be written and specific to an employer’s site with focus on labeling, SDS, and training. Think of the written plan as a  guide to implementing OSHA’s HAZCOM standard, and stick to the requirements stated by the standard to avoid going off target. The target – protecting employees from chemical exposures.

Here are some things to keep in mind, based on OSHA’s HAZCOM FAQs and related resources:

Where can we look for inspiration when writing our company’s HAZCOM plan?

OSHA suggests examining the sample programs of trade organizations and similar companies in your industry for writing your HAZCOM program. See how each organization has adapted the standard to their workplace. However, make sure that that these samples are meant to provide you guidance. Your HAZCOM plan should be specific to your industry, facility, and type of operations.

Do temporary agencies have to train workers on HAZCOM?

Temporary agencies are expected to provide hazard training to workers for the recognition of chemical hazards. From there, the host company will pick up the responsibility of training employees on-site, in accordance to 1010.1200(h)(1) and 1926.59.

What constitutes proper HAZCOM training?

Generally speaking, the training should be in pursuance of the provision (1910.1200(h)). The standard requires employers to provide employees comprehensive information about the effects of chemical exposure and the components of the company’s hazard communication program before the start of work. The training should be facilitated with audio visuals, videos, and slides as well as onsite hazard training where employees can gain practical knowledge and skills and have the opportunity to ask questions.

What should we know about refresher training or training new hires?

OSHA’s HAZCOM standard requires employers to train workers for any new physical or health hazards. Refresher training is required for the use of new chemicals, but if their hazards are similar to those of previously used chemicals (for which training has already been done) make sure employees know this. Employees who have received HAZCOM training before do not need retraining, but the problem is how do you verify they have received HAZCOM training at their previous job?

When should we expect to receive SDS from manufacturers?

Manufacturers or suppliers must provide the safety data sheets the upon delivery of chemicals used. OSHA’s HAZCOM also requires manufacturers to update the SDSs within three months of discovering a new hazard associated with a chemical. With the new GHS standard manufactures have until 2015 to be in full compliance with the new SDS and labels.

Do we need to include insecticides and cleaning products on the MSDSs?

Household consumer products need not be included in the company’s MSDS so long as they are used in the same way consumers use them. Otherwise, employees may have to be informed of their hazardous properties.

How about pharmaceutical drugs?

The HCS applies only to pharmaceutical drugs that are recognized as workplace hazards, and subject employees to occupational exposure. In this event, the manufacturer and importer are responsible for evaluating the hazards presented by the pharmaceutical drug. The employer can rely upon the results of this evaluation for safety.

Can we save SDSs on a computer and still be in compliance of HAZCOM requirements?

Yes, as long as the file is accessible immediately to workers at their work spaces. Otherwise, the company would be violating paragraphs (g)(8) or (g)(9) of OSHA’s HAZCOM standard.

What labeling requirements should we take note of to remain in compliance of the HAZCOM?

Manufacturers, importers and distributors are required to label each chemical container, regardless of whether a chemical type is clustered together or not. In the workplace, if chemicals are to be transferred to a new container for storage, the containers still have to be labeled according to the standard. Labeling should not be necessary if the transferred chemicals will be used immediately.

For more information on OSHA’s HAZCOM standard, check out the following links:

Hazard Communication Solutions

https://www.osha.gov/dsg/hazcom/solutions.html

Copy of OSHA’s HAZCOM Standard

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099

Hazard Communication Guidelines for Compliance

https://www.osha.gov/Publications/osha3111.html

Frequently Asked Questions: Hazard Communication (HAZCOM)

https://www.osha.gov/html/faq-hazcom.html#faq11

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