Who does the hazard communication standard apply to

What is Hazard Communication Standard (HazCom)?

The OSHA Hazard Communication Standard (29 CFR 1910.1200), or "HazCom," is a set of regulations that tell employers how they must inform employees about hazards of chemicals used in the workplace. HazCom requires us to have a HazCom Program which includes employee training, access to information about chemical products used in the workplace, access to personal protective equipment (PPE), and a written Hazard Communication Plan. Each of these is discussed in a bit more detail below.

Employee Training

General introductory HazCom training is provided by the Safety & Workers' Compensation Office during New Employee Training run by Human Resource Services. Job-specific HazCom training is provided by the employee's supervisor, with assistance from the Safety & WC Office as needed. HazCom training must be provided before you work where exposure to hazardous chemicals could occur. Annual refreshers are not required, but retraining is required any time the hazards change.

Access to Information about Chemical Products

There are three basic kinds of information that the HazCom standard requires:

1. Each shop or department must keep an up-to-date chemical inventory.
2. Each shop or department must maintain Material Safety Data Sheets, or MSDSs.
3. Each container must be labeled in such a way that employees can look up the MSDS for the product inside that container.

MSDSs are a kind of "fact sheet" about chemical products. They contain information about the safe use and handling of the product, including what kind of personal protective equipment to wear when handling the product and what to do in case of overexposure, a spill, or fire. OSHA requires virtually all chemical products used in the workplace to have an MSDS immediately available to employees.

Personal Protective Equipment (PPE)

Personal Protective Equipment, or PPE, is equipment worn by employees to protect themselves from chemical or other hazards. Common examples include safety glasses, goggles, gloves, steel-toed shoes, slip-resistant shoes (e.g. for food service workers and housekeepers), hardhats, and respirators. Read more about the North Carolina Office of State Personnel policies on PPE and the PPE policy specific to App State.

By law, employers must first try to find a way to actually remove the hazard before deciding to use PPE. For example, substitution with a less-hazardous chemical or adding extra ventilation must be tried before deciding that an employee should wear a respirator. The University Industrial Hygienist can provide valuable assistance in deciding when PPE is appropriate and if so, selecting the proper kind and training employees on its use. The wrong kind of PPE can give people a false sense of security and can actually increase their chances of getting hurt or sick from work.

Written HazCom Program

App State's written HazCom Program is contained in Policy 6 in the App State Resource Manual. This plan includes details on who is responsible for what with regards to chemical safety in non-laboratory workplaces.

Does HazCom Apply to Me?

The OSHA Hazard Communication Standard, or "HazCom," applies to all employees who use chemical products, unless the products meet all of the following four requirements:

1. General household or office product
2. Used for its intended purpose
3. Used in small quantities
4. Used in a manner that is incidental to your work (i.e. infrequently, for short periods of time, and not one of your job duties)

Working Safely with Chemicals

The Hazard Communication Standard, also known as the Right to Know Law, is mandated in US federal regulation 29 CFR 1910.1200 with enforcement by the Occupational Safety & Health Administration (OSHA); it is also mandated in State of Tennessee Regulations chapter 0800-1-9 with enforcement by the Tennessee Division of Occupational Safety & Health (TOSHA).  The OSHA web site provides extensive information about the standard.

The Hazard Communication Standard requires that employees receive safety training if they will be working with hazardous chemicals.   The Hazard Communication Standard requires that Safety Data Sheets (SDS) be provided by chemical manufacturers and distributors and that facilities where hazardous chemicals are located must train workers on how to safely handle hazardous chemicals.  Instruction on the use of SDS and proper chemical labeling must be included in this training.

Individuals who work with chemicals in laboratories are required to comply with the OSHA Lab Standard, which includes the requirements of the Hazard Communication standard but also incorporates additional requirements. Please note that the Lab Standard requires a written Chemical Hygiene Plan instead of a written Hazard Communication plan.

HCS Training Requirements

Training must include a description of the Standard, recognition of HCS pictograms, how to obtain, use & understand Safety Data Sheets (SDS), health effects (including reproductive risks), how to interpret information provided on chemical container labels, secondary container labeling requirements, personal protective equipment, safe work practices and emergency procedures.  

Due to the wide variety in chemical use at Vanderbilt, training is provided in two parts:  general information and department-specific information.  General training information is described below in Part One, while department-specific requirements are described in Part Two.

Important:  The OSHA Hazard Communication Standard was revised in 2012.  All individuals who work with chemicals at Vanderbilt must complete training that covers all requirements of this law. 

Frequency:   Initial with annual retraining

Contact the OCRS webmaster  if you have questions about HCS training requirements.  

Part One:  General Hazard Communication Training

Required for all employees.  Required annually for all employees who are exposed to and work directly with hazardous chemicals.  Also required annually for all VUMC employees, per VUMC Policy Hazardous Chemical Right-to-Know, Hazard Communication.

Part one training provides general information about requirements of the standard, such as a description of Safety Data Sheets (SDS), the need for chemical container labeling, proper personal protective equipment (PPE),  and other requirements of this standard.  This training is general and does not provide all of the information that is specific to different departments and units.  See Part two: Specific training, below.

The Hazard Communication Standard part one training may be provided to new staff online in the Learning Exchange as part of University or Medical Center online orientation or can be provided within their department.  The Hazard Communication Standard online training that is available in the Medical Center Learning Exchange and in VU Oracle Learn can be self-assigned.

Annual retraining for part one is also available online.

Part Two:  Specific Hazard Communication Training

Required annually for all employees who are exposed to and work directly with hazardous chemicals.

Supervisors are responsible for making sure that this training is provided at the departmental or unit level because it must provide specific information about the hazardous chemicals in use at each location.  For advice on how to provide specific Hazard Communication training, contact OCRS.

This specific training must include

• The Hazard Communication Written Program 
  • VUMC Policy SA 20-10.03: Hazardous Chemical Right to Know/Hazard Communication (Medical Center only)
  • The VU Hazard Communication Standard Written Program (University only)
• The list of hazardous chemicals used by your unit/department.
• Locations and situations that may occur within your unit or department where hazardous chemical exposure can occur.
• Appropriate PPE and engineering controls for chemicals used in your department/unit.
• Where to find and how to read Safety Data Sheets (SDS) for chemicals in use in your department or unit.
• Safe work practices and emergency procedures
• Instruction on proper labeling of secondary chemical containers.
• Recognition of hazard pictograms (symbols) used to represent specific hazards.

Class length varies and depends on the extent of chemical use within the department or unit.

Class Schedule/Location:  This training is provided within an individual department. 

Hazard Communication Standard Resources

Vanderbilt Hazard Communication Standard Written Programs

• VUMC Policy SA 20-10.03: Hazardous Chemical Right to Know/Hazard Communication
• VU Hazard Communication Standard Written Program (available from VU Workplace Safety)

Vanderbilt Chemical List and Safety Data Sheet Verification Log 

• Download as PDF file or WORD file.

Additional VUMC Resources

• More about VUMC requirements
• VUMC Top Safety Data Sheets - SDS for chemicals commonly used at VUMC

Recognize Chemical Hazards (NEW - 3/12/2018)

Pictograms

• OCRS Resources
  • What Pictograms Mean (NEW - 3/12/2018)
  • Pictogram Reference:  what each pictogram represents
• OSHA Resources
  • HCS Standard Pictogram - OSHA Quick Card (PDF version)
  • Downloadable Pictogram Graphics - to use for training purposes, when creating labels and writing Safety Data Sheets.

Labels

• OSHA Brief HCS Labels and Pictograms - OSHA Brief
• OSHA HCS Standard Labels - OSHA Quick Card - required format for labels
• OSHA Comparison of NFPA 704 and OSHA 2012 Labels

Safety Data Sheets (SDS)

• Safety Data Sheets - provides links to online resources for SDS
• Information provided on a SDS  (NEW - 3/12/2018)
• HCS Safety Data Sheets - OSHA Quick Card (PDF version) - required format for SDS
• HCS Safety Data Sheets - OSHA Brief

HCS Training

General References:

• OSHA Hazard Classification Guidance for Manufacturers, Importers, and Employers

Chemical Safety Resources

OCRS provides extensive chemical safety information through this web site:

• Safety Data Sheets
• Chemical & Laboratory Safety
• Chemical Waste
• Chemical Safety Links
• Chemical Safety Databases

Questions

If you have questions about the Hazard Communication Standard or Hazard Communication training, please contact one of the following:

• If you work in a VUMC hospital or clinic, please contact someone in the Hospital & Clinic Safety Section.
• If you work in any other VU or non-clinical VUMC area, please contact someone in the Chemical/Lab Safety Section.
• If you have questions about Hazard Communication Standard training, contact the webmaster.

Who does the hazard communication standard apply to quizlet?

What is the OSHA Hazard Communication Standard?

Who has hazard communication duty?

Where are written hazard communications not required?