Show Failure to have a written HazCom program consistently tops the list of OSHA general industry violations. Today we look at the essential elements of your written HazCom plan.The hazard communication standard (HazCom), also known as “worker right-to-know,” is one of OSHA’s most important standards. In summary, it requires chemical manufacturers, importers, and users to evaluate and communicate to workers the hazards of chemicals they make, import, or use. And HazCom violations have historically resulted in high numbers of citations. The twice-monthly OSHA Compliance Advisor newsletter describes HazCom as a performance-based standard, meaning that it is particular about the objectives employers must achieve, but flexible about the specific methods that are used to achieve them. HazCom covers some 7 million workplaces, more than 100 million employees, and 945,000 hazardous chemical products. OSHA says that a hazard communication program “helps employers design and implement appropriate controls for chemical exposures and gives employees the right to know the hazards and identities of the chemicals, as well as allowing them to participate actively in the successful control of exposures.” All the safety training you need in one program: 25 subjects, one low price. It’s BLR’s Safety Training Presentations. Try it at no cost. Click for details. The six core elements of HazCom are:
Under the standard, employers who manufacture, import, distribute, or use hazardous substances must communicate information about them to employees who work with them. This must be done through a written HazCom program, labels, MSDSs, and an employee information and training program. Failure to have a written HazCom program has consistently been the top violation in general industry in recent years. Last year there were more than 2,200 violations with initial penalties of more than $1 million. Failure to provide training on new chemical hazards and failure to have MSDSs available also ranked high on the list. Required Elements of a Written ProgramYour written HazCom program does not have to be long or spell out everything in detail, but it must be well-thought-out, clear, and comprehensive, and outline all the parts of the program you are implementing. It is likely to be the first thing a compliance officer or inspector will ask to see if your facility is ever inspected. Here are the essential elements:
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If an MSDS is missing, the employer must get it from the manufacturer, distributor, or other source. The list will eventually serve as an inventory of everything for which an MSDS is required. Your written program must also spell out your criteria for employee training. Tomorrow we’ll discuss what those criteria should include and what topics should be covered in HazCom training, and we’ll look at a product that can lift most of that burden from your shoulders. Does the HazCom program have to be written and available to employees?All workplaces where workers are exposed to hazardous chemicals must have a written hazard communication program that describes how the HazCom standard is implemented in that facility.
Is HazCom training required for all employees?All employees must be provided with information and training on hazardous chemicals in their work area at the time of their initial assignment (prior to being exposed to a chemical), and whenever a new chemical hazard they have not previously been trained about is introduced into their work area.
What must be provided to employees under the Hazard Communication Standard?The Hazard Communication Standard (HCS), 29 CFR 1910.1200 (h), requires all employers to provide information and training to their employees about the hazardous chemicals to which they may be exposed at the time of their initial assignment and whenever a new hazard is introduced into their work area.
Does OSHA require written hazard communication programs?Paragraph (e) of the standard requires employers to prepare and implement a written hazard communication program.
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