OSHA’s Hazard Communication Standard€¦ · before 2012, considering Category 4 the most...

OSHA’s Hazard Communication Standard

W H I T E PA P E R

By Richard L. Best, Ph.D., CIHM, COSP Director of OSHA Compliance, Stericycle, Inc.

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OSHA’S HAZARD COMMUNICATION STANDARD2

Table of Contents

Introduction .....................................................................................................................................................3

Overview ..........................................................................................................................................................3

Classification of Chemicals ............................................................................................................................4

Labeling ...........................................................................................................................................................6

Safety Data Sheets ........................................................................................................................................10

Other Requirements of the Hazard Communication Standard ...............................................................13

Conclusion .....................................................................................................................................................14


IntroductionOSHA and Its Safety and Health StandardsIn 1970, the United States Congress passed the Occupational Safety and Health (OSH) Act that was subsequently signed into law by President Richard M. Nixon. The preamble to the OSH Act stated that its purpose was “To assure safe and healthful working conditions for working men and women; by authorizing enforcement of the Standards developed under the Act; by assisting and encouraging the States in their efforts to assure safe and healthful working conditions; by providing for research, information, education, and training in the field of occupational safety and health; and for other purposes.” The chief effect of the Act was to bring about the creation of the United States Occupational Safety and Health Administration (OSHA).

At its beginning, OSHA did not have any of its own Standards or regulations, and it had to make do by incorporating the consensus standards at the time that were already in existence among various industry groups and associations. In the years since its introduction, however, OSHA has developed and introduced many of its own Standards that lay down regulations that carry the force of law and must be followed by employers and employees on the job. One of the most important of OSHA’s Standards, and the topic of this paper, is what is known as the Hazard Communication (often referred to as HazCom) Standard or HCS. This paper presents an overview and reminder of the current HCS as it was updated in 2012 to align with the United Nations’ Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. By June 1, 2016, all manufacturers, importers, distributors and employers were required to be fully compliant. Training employees, new labeling and Safety Data Sheets (SDSs) had to be completed by December 1, 2013. The updated requirements of employers related to written Hazard Communication Programs, SDSs, proper product labeling and worker training are discussed.

OverviewHazard Communication StandardIn 1983, OSHA created the original HCS and based it upon a simple concept: employees have both the need and the right to know the hazards of chemicals to which they are exposed at work. They also need to know what protective measures they can use to safeguard themselves and others from exposure to those hazardous chemicals. OSHA’s HCS is the means of putting regulations into place that require employers to provide workers with the information they need. When OSHA first created the HCS, its scope was limited to manufacturing companies, but in 1987, OSHA expanded the scope of the Standard to apply to all covered employers whose workers had potential exposure to hazardous chemicals. The most recent update of the Standard, prior to the major revisions introduced in 2012, was in 1994. This paper discusses the Standard as it exists since 2012, as well as some related updates.

The HCS addresses over 7 million workplaces having some 100 million workers who are potentially exposed to hazardous chemicals on the job. There are hundreds of thousands of hazardous chemical products already on the market, and more are created every year. The HCS applies to certain hazardous chemicals that are known to be present in workplaces in such a manner that employees might be exposed under normal conditions of use or in a foreseeable emergency. The HCS also incorporates the requirement for a “downstream flow of information” that charges producers of chemicals with the primary responsibility for generating and disseminating information. Users of those chemicals must obtain the information generated by the chemical producers, typically in the form of SDSs, and transmit that information on to their employees.


The Globally Harmonized SystemIn 2012, Federal OSHA aligned the Hazard Communication Standard (HCS) with elements of the United Nations’ GHS of Classification and Labeling of Chemicals.

In addition to the right to know about hazardous chemicals in the workplace that was included in OSHA’s existing HCS, the incorporation of the GHS’s requirements added the right to understand, by requiring pictograms and other simplified communication elements such as the requirement to “train workers using a language and vocabulary they understand” to make hazard communication easier and most effective.

The GHS is a United Nations order of classification and labeling of chemicals that provides not only simplified communication elements, but also a single set of criteria for classification. GHS has been adopted in the U.S. and around the world in such places as Australia, China and countries of the European Union. The updated

HCS requires that the hazards of all chemicals produced or imported be classified and transmitted downstream to employers and employees in a manner that is consistent with the provisions of the United Nations’ GHS of Classification and Labeling of Chemicals. Although the GHS is not itself a regulation or Standard, OSHA’s incorporation of it into its own HCS effectively makes GHS’ requirements an enforceable part of the OSHA Standard.

Scope of the Standard The scope of the current HCS applies to all covered workplaces wherever hazardous chemicals are produced, imported, or might simply be present in a manner in which employees have actual or potential exposure. Some types of chemicals, however, are exempted from coverage by the Standard, as will be discussed further below.

Classification of ChemicalsClasses and CategoriesThe HCS establishes health and physical hazard classes with specific criteria for each classification, along with detailed instructions and determinations. The Standard has greater requirements for chemical manufacturers and importers who are required to classify the hazards of chemicals that they produce or import. Manufacturers, importers, and their distributors are required to transmit the required information to downstream employers who purchase and use the products.


Note:

The 2012 Standard revised categories of severity within hazard classes. Those categories of severity are listed, in descending order of hazard level, as Category 1,2,3, or 4. In other words, hazard Category 1 of any particular hazard class indicates the most hazardous category. This is noted because it is the reverse of the practice before 2012, considering Category 4 the most hazardous. OSHA’s criteria for classification of chemicals are presented in appendices to the Standard and are also discussed below.

OSHA defines a hazardous chemical as one that is a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas or a hazard not otherwise classified. A simple asphyxiant is a substance or mixture that displaces oxygen in the ambient atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to unconsciousness and death. Combustible dust refers to fine particles that present an explosion hazard when suspended in air in certain conditions. A pyrophoric gas means a chemical in a gaseous state that will ignite spontaneously in air at a temperature of 130 degrees Fahrenheit or below.

Health Hazards “Health hazards” refer to any of the following hazardous effects that a chemical might exhibit:

• Acute toxicity, through any route of exposure

• Skin corrosion or irritation

• Serious eye damage or irritation

• Respiratory or skin sensitization

• Germ cell mutagenicity

• Carcinogenicity

• Reproductive toxicity

• Specific target organ toxicity through either single or repeated exposure

• Aspiration

Criteria for determining whether or not a chemical should be classified as a health hazard are presented in detail in Appendix A of the HCS titled Health Hazard Criteria.1

Physical Hazards “Physical hazards” refer to any of the following:

• Explosives

• Flammables (gases, aerosols, liquids or solids)

• Oxidizers (liquid, solid or gas)

• Gases under pressure

— Compressed, liquefied, refrigerated liquefied, dissolved

• Self-reactives

• Pyrophorics (liquid, solid or gas)

• Self-heating chemicals

• Organic peroxides

• Corrosive to metal

• Chemicals which, when in contact with water, emit a flammable gas

Physical hazard criteria are presented in detail in Appendix B of the Standard.2

https://www.osha.gov/dsg/hazcom/hazcom-appendix-a.html

https://www.osha.gov/dsg/hazcom/hazcom-appendix-b.html


LabelingManufacturer Product LabelsChemical manufacturers and importers are required to have labels on the chemicals they sell that include all of the following elements:

• A product identifier or name

• A signal word such as “danger” or “warning” used to emphasize hazards

• A hazard statement using standard phrases for particular hazard classes and categories

• Pictograms, or symbols, that convey health and physical information assigned to a GHS hazard class and category

• Precautionary statements that provide measures to minimize or prevent adverse effects

• Supplier information including the name, address, and telephone number of the manufacturer or supplier

PictogramsIn addition to the other label requirements, OSHA adopted 8 of the 9 GHS pictograms shown below. Pictograms are simple graphics used on labels and SDSs to communicate specific hazards.

Health Hazard

Gas Cylinder

Flame Over Circle

Flame

Corrosion

Environment(Non-Mandatory)

Exclamation Mark

Exploding Bomb

Skull and Crossbones


Two of the pictograms are explored below. OSHA provides full descriptions of all pictograms in Appendix C.3

Health Hazard Pictogram

The health hazard pictogram shows a black silhouette of a human form with a white area in the chest region. This pictogram is used to indicate hazardous chemicals that are one or more of the following:

• Carcinogens

• Respiratory sensitizers

• Toxic to the reproductive system

• Toxic to a target organ

• Cause mutations in sperm or egg cells

• Present a hazard of being aspirated through the oral or nasal cavities

Chemicals that are toxic to specific organ systems might be toxic as the result of a single exposure or through repeated or prolonged exposure.

Flame Pictogram

The flame pictogram might be used with flammable gases or aerosols, flammable liquids, and/or flammable solids. Flammable, of course, refers to things that can burn, but OSHA has very technical definitions for such terms. Appendix B2 of the Standard provides more precise and expanded definitions. The following is a summary.

Flammable Gases and Aerosols

• A flammable gas is one having a flammable range in air at 68°F and a standard pressure of 14.7 psi

• An aerosol is a gas that is compressed, liquefied, or dissolved under pressure in a container with a release valve that ejects it in the form of gas, foam, paste, powder, or liquid particles

• Aerosols are considered flammable if they have any component that is a flammable gas, a flammable liquid, or a flammable solid

Flammable Liquids

• A flammable liquid has a flash point under 200°F

• There are 4 categories of flammable liquids

Flammable Solids

• A flammable solid is a readily combustible solid, or a solid that can cause or contribute to fire through friction

• Readily combustible solids are powdered, granular, or pasty chemicals that are dangerous if they can be easily ignited by brief contact with an ignition source such as a burning match and if the flame spreads rapidly

— Liquids with a flash point below 73.4°F and an initial boiling point equal to or less than 95°F are Category 1, or most flammable and, therefore, most hazardous

— Liquids with a flash point below 73.4°F and an initial boiling point above 95°F are Category 2

— Liquids with a flash point equal to or greater than 73.4°F and equal to or less than 140°F are Category 3

— Liquids with a flash point greater than 140°F and less than or equal to 199.4°F are Category 4

https://www.osha.gov/dsg/hazcom/hazcom-appendix-c.html



Updated TerminologyBy now, the changes made in 2012 to technical terminology in the Standard may be familiar to you:

• Previously, a liquid with a flashpoint less than 100°F was called a flammable, and a liquid with a flashpoint between 100 and ~200°F was called a combustible, but the current Standard considers anything with a flashpoint of less than or equal to 200°F a flammable

• Compressed gases are now called gases under pressure

• Self-reactive substances are thermally unstable liquids or solids liable to undergo a strong decomposition even without oxygen (air) being present

• Pyrophoric liquids or solids refer to those that are liable to ignite spontaneously within 5 minutes of coming into contact with air

Workplace LabelsWhen a hazardous chemical is purchased, the manufacturer’s information is required to be present on the original product label. If some of the chemical from the original container is transferred to a secondary container, however, then a workplace label must be attached to that secondary container. Secondary containers must be labeled with workplace labels in English. Workplace labels are required to contain either much of the same information that a manufacturer’s original product label contains (product identifier, signal word, hazard statement, pictogram, and precautionary statement), or, alternatively, they are considered acceptable to OSHA if they contain at least the following 2 items of information:

• Product identifier

• Words, pictures, symbols, or combination thereof that provide at least general information about the hazards of the chemical

Exceptions to Workplace LabelingThere are some exceptions to when workplace labeling is required, even when a worker pours a hazardous chemical from its original container into an unmarked workplace or secondary container. For example, an employee is not required to label secondary containers into which a hazardous chemical has been transferred (from its labeled container), if the chemical is intended only for the immediate use of the employee who performed the transfer.

Another exception permits drugs that are dispensed by a pharmacy to a healthcare provider, for direct administration to a patient, to be exempted from labeling required by the HCS.

Alternatives to Workplace LabelingAnd finally, the Standard also permits using alternatives to labels, such as signs, placards, process sheets, batch tickets, operating procedures, or other such written materials, for individual stationary process containers, as long as any alternative method identifies the containers to which it is applicable and conveys the information that is required for workplace labels. Such alternatives should, however, be discussed in the written Hazard Communication Program, and training about the alternatives must be provided to employees.


Examples of Workplace Poster and Label

Recognize Hazardous Chemicals.Understand the Dangers. Protect Yourself.


HAZARD COMMUNICATION STANDARD PICTOGRAMHCS Pictograms and Hazards

HEALTH HAZARD FLAME EXCLAMATION MARK

Examples:• Carcinogen• Mutagenicity• Reproductive Toxicity• Respiratory Sensitizer• Target Organ Toxicity• Aspiration Toxicity

Examples:• Flammables• Pyrophorics• Self·Heating• Emits Flammable Gas• Self Reactives• Organic Peroxides

Examples:• Irritant (skin and eye)• Skin Sensitizer• Acute Toxicity• Narcotic Effects• Respiratory Tract lrritant• Hazardous to Ozone

Layer (Non·Mandatory)

GAS CYLINDER CORROSION EXPLODING BOMB

Examples:• Gases Under Pressure

Examples:• Skin Corrosion/Burns• Eye Damage• Corrosive to Metals

Examples:• Explosives• Self Reactives• Organic Peroxides

FLAME OVER CIRCLE ENVIRONMENT (NON-MANDATORY) SKULL AND CROSSBONES

Examples:• Oxidizers

Example:• Aquatic Toxicity

Example:• Acute Toxicity

(Fatal or Toxic)

Go to MyStericycle.com to print workplace labels and order infection control, safety and waste containment products.

Need Help? Have Questions?Contact us at 866-783-7422 or [email protected]

In an emergency, call:__________________________________________ Fire, Police & Medical

__________________________________________Gas Leak

__________________________________________Building Issues

© 2018 Stericycle, Inc. All rights reserved. STC_SAFEPSTR_0518

Hazard Communication Poster

Workplace Labels

The requirement for workplace labeling under 29CFR 1910.1200 (f)(6) states: Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers; or, Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

For additional labels order online at MyStericycle.com or call Stericycle at 866-783-7422.

© 2018 Stericycle, Inc.Steri•SafeSM

HEALTH HAZARD

PRODUCT IDENTIFIEROR CHEMICAL NAME

SDS#(if assigned by employer)

Please refer to matching Safety Poster for further information concerning each category.

FLAMMABLES IRRITANTS; SENSITIZERS

H A Z A R D C L A S S

GASES UNDER PRESSURE CORROSIVES

ENVIRONMENT

EXPLOSIVES

OXIDIZERS

REQUIRES PPE - SEE SUPERVISOR OR REFER TO SDS FOR GUIDANCE

ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY


HEALTH HAZARD







ENVIRONMENT

EXPLOSIVES

OXIDIZERS


ACUTE TOXICITY

Using a permanent marker, write the name of the hazardous chemical, record the corresponding SDS# (if one is assigned by the employer), check the appropriate hazard, and, if appropriate, PPE; then affix the label to the container.

© 2018 Stericycle, Inc. All rights reserved. STC_SDSLAB_0418

2019

http://store.stericycle.com/hazard-communication-poster-and-workplace-labels/

http://store.stericycle.com/hazard-communication-poster-and-workplace-labels/

10 OSHA’S HAZARD COMMUNICATION STANDARD

Safety Data SheetsEmployers Who Do Not Produce ChemicalsEmployers who do not actually produce or import chemicals, but who simply use chemicals in their workplace, are not charged with classifying the chemicals. They are only charged with the need to obtain and maintain the classification information developed by the producers/importers and then to communicate that information to their workers via a comprehensive, written Hazard Communication Program. This includes proper container labeling, employee training, SDSs, and other forms of warnings as discussed below.

Safety Data SheetsSDSs are the documents that OSHA requires manufacturers, producers, or importers of hazardous chemicals to prepare for the purpose of transmitting information about hazardous chemicals downstream to employers and users. SDSs are similar to what were formerly referred to as Material Safety Data Sheets (MSDSs), but there have been significant revisions to what they must contain and how that information must be presented.

SDSs are required to be written in English. Additional languages are permitted, but they do not take the place of an English version. A completely different OSHA Standard, the Access to Medical Records Standard, 1910.1020, requires that “some record” of hazardous chemicals be maintained in the workplace for a period of 30 years, and keeping SDSs for that period of time, therefore, is one means of compliance with that requirement.

16-Section Format for Safety Data SheetsSince 2015, the HCS has required new SDSs to follow a uniform format and to include the section numbers, the headings, and the associated information summarized below:

Section 1: Identification includes product identifier, manufacturer or distributor name, address, phone number, emergency phone number, recommended use, restrictions on use

Section 2 — Hazard(s) identification includes all hazards regarding the chemical and required label elements

Section 3 — Composition/information on ingredients includes information on chemical ingredients and any trade secret claims

Section 4 — First-aid measures includes important symptoms/effects, whether acute or delayed, and any required treatment

Section 5 — Fire-fighting measures lists suitable extinguishing techniques, equipment, and any chemical hazards from fire

Section 6 — Accidental release measures lists emergency procedures, protective equipment, and proper methods of containment and cleanup

Section 7 — Handling and storage lists precautions for safe handling and storage, including any incompatibilities

Section 8 — Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs), Threshold Limit Values (TLVs), appropriate engineering controls, and Personal Protective Equipment (PPE)


Section 9 — Physical and chemical properties lists, as the section name indicates, the chemical’s physical and chemical characteristics

Section 10 — Stability and reactivity lists chemical stability and possibility of hazardous reactions

Section 11 — Toxicological information includes routes of exposure, related symptoms, acute and chronic effects; and any numerical measures of toxicity

Section 12 — Ecological information*

Section 13 — Disposal considerations*

Section 14 — Transport information*

Section 15 — Regulatory information*

Section 16 — Other information includes the date of preparation or last revision

Note:

OSHA has stated, "The SDS must also contain Sections 12 through 15, to be consistent with the UN GHS of Classification and Labeling of Chemicals, but OSHA will not enforce the content of these sections because they concern matters handled by other agencies."4

Employees Who Work Off-SiteBusinesses that have employees who travel for work at off-site locations are required to keep SDSs at a primary workplace facility, and they must also ensure that employees can immediately obtain the required information in an emergency.

Multi-Employer WorkplacesIf employees of other employers might visit your workplace (example: employees of a cleaning company that might visit your facility every evening, etc.) and could be exposed to hazardous chemicals in your workplace, then the Hazard Communication Program for your facility must include the methods that will be used to provide the other employer with:

• On-site access to SDSs

• Precautionary measures to be taken for the visiting employees to protect themselves in normal conditions and foreseeable emergencies

• Methods that will be used to inform the other employers of the chemical labeling system used in your workplace

Consumer Products ExemptionThere are some exemptions to the requirements of the HCS for certain types of products. One such exemption is for “consumer products”. Consumer products are products that can be purchased by general consumers. Employers are not required to provide SDSs when employees use a consumer product that contains hazardous chemicals if the product is used for the same purpose and in a similar frequency and duration of time as general consumers use the product.

However, if employees are required to use a consumer product containing a hazardous chemical at a rate exceeding the common level of consumer use, an SDS is required to be readily available to employees.

https://www.osha.gov/Publications/OSHA3514.html


If, for example, an employee used a cleaning product (that contains a hazardous chemical) on a daily basis that a general consumer would normally use monthly, the employer must provide SDSs. This regulation is not based upon the chemical manufacturer’s intended use of its product, but upon how it is actually used in the workplace.

Sometimes, though, it is easier to obtain and keep an SDS for exempted products, rather than debate whether or not the SDS is actually required or whether the product is being used in the same way that a general consumer would use it. Keep in mind that OSHA’s requirements represent only the minimum that is required by regulation, and an employer is permitted to do more than OSHA requires. It is not an OSHA violation to have an SDS on hand for a consumer product, even if the HCS does not technically require such an SDS.

Other Items Not Covered by the Hazard Communication StandardIn addition to consumer products, other types of products, which are exempt from the requirement to have SDSs, include:

• Pesticides regulated by FIFRA, the Federal Insecticide, Fungicide, and Rodenticide Act

• Toxic substances regulated by the Environmental Protection Agency through the Toxic Substances Control Act

• Tobacco

• Natural wood products for retail sale

• Articles that do not result in employee exposure via inhalation, ingestion, or skin absorption

• Food or alcoholic beverages

• Ionizing and non-ionizing radiation

• Biological hazards

• Food, non-hazardous drugs and cosmetics

Hazardous DrugsAlthough most drugs are exempt from the HCS, hazardous drugs (HDs) are not exempted from the requirement to have SDSs and other requirements of the Standard. OSHA treats HDs exactly like any other hazardous chemicals. OSHA first published guidelines for the management of cytotoxic/antineoplastic drugs (which are part of a growing list of HDs) in the work place, in 1986. Concern over worker exposure to hazardous drugs, particularly health care workers (HCWs), has grown ever since then, partly due to the rise in cancer patients whose treatments may include HDs. The National Institute for Occupational Safety and Health (NIOSH) has estimated that around 8 million HCWs are at risk of exposure to HDs.

In 2016, OSHA issued an update on HDs that serves as an effective resource in identifying and handling of HDs but as they pointed out in the Hazard Communication section of the update, the 2012 HCS description of HDs is still in effect to stay compliant with OSHA Standards.5,6 That is, if the drug is in liquid or aerosol form at the time it is taken by the patient and if the drug can:

• Affect a cell’s genetic material

• Cause cancer (known or presumed)

• Cause developmental malformations to an embryo or fetus

• Target specific organ systems (such as kidneys, nervous system, blood forming system, etc.)

Note:

OSHA has stated that the above linked 2016 update replaces Section VI: Chapter 2 of the Technical Manual originally referred to in the 2012 HCS for among other issues, referring to how a hazardous classification can be made for drugs based upon either the characteristics or the pharmacology/toxicology of the drug in question.

https://www.osha.gov/SLTC/hazardousdrugs/controlling_occex_hazardousdrugs.html

https://www.osha.gov/SLTC/hazardousdrugs/controlling_occex_hazardousdrugs.html#hazcom


NIOSH's most recent list of hazardous drugs may be a resource for required Written Hazard Communication Programs, discussed below.7 Be advised that NIOSH periodically prepares an updated list of antineoplastic and other hazardous drugs. The latest version can be downloaded from the NIOSH website.

Other Requirements of the HCSWritten Hazard Communication ProgramOne of the primary requirements of the HCS is the requirement for employers to develop a written Hazard Communication Program for that employer’s particular workplace that describes how requirements for the following items will be met:

• Labels and other forms of warning

• SDSs (formerly called MSDSs)

• Master list of hazardous chemicals

• Employee information and training

• Hazards of any non-routine tasks that might be present in a particular workplace

Multi-Employer workplaces must also include the methods they will use to inform other employers about:

• Providing SDSs for other employers’ workers

• Precautionary measures

• Any labeling system in use in the facility

If an employer has non-routine tasks that are performed at the workplace and that present the potential for employee exposure to hazardous chemicals, then the written Hazard Communication Program must also include:

• Identification of the non-routine tasks

• Methods the employer will use to inform employees about the non-routine task hazards and about how to protect themselves

Training RequirementsOSHA requires Hazard Communication training whenever a worker is initially assigned to a position where there is a potential for exposure to hazardous chemicals. Retraining is required whenever a new chemical hazard, for which employees have not previously been trained, is introduced into the work area. Some states also have workers' compensation or right to know regulations that require similar annual training on hazardous chemicals. It is therefore recommended that annual Hazard Communication training be provided in all states just to ensure that an employer has covered all the bases.

Hazard Communication training is required to cover the following areas of information:

• Hazards of chemicals in the work area, including:

— Physical hazards

— Health hazards

— Simple asphyxiation

— Combustible dust

— Pyrophoric gas

— Hazards not otherwise classified

https://www.cdc.gov/niosh/docs/2016-161/pdfs/2016-161.pdf?id=10.26616/NIOSHPUB2016161


• Methods and specific procedures workers can use to protect themselves, including:

— Work practices

— Emergency procedures

— PPE to be used

• Operations where hazardous chemicals are present

• Details, location, and availability of:

— The employer’s written Hazard Communication Program

— Master list of hazardous chemicals

— Explanation of labels received on containers

— Workplace labeling system used by the employer

— SDSs, including:

PFollowing proper order of information

PHow employees can obtain and use correct hazard information, and the

— Methods used to detect the presence or release of hazardous chemicals

Incorporation of the GHS has also created some specific training requirements about changes to the Standard. OSHA requires training on the Hazard Communication Standard, including the following elements:

• Revised label elements, including pictograms

• Revised SDSs

ConclusionHazardous Chemicals On-the-JobAs far back as the fourth century BCE, Hippocrates recorded work-related diseases that occurred in miners as the result of being exposed to lead. Over the centuries others wrote about concerns of workers being exposed to zinc, sulfur, silver, and other materials in the mining, smelting, and refining industries. The Mad Hatter in Lewis Carroll’s Alice in Wonderland was described as being “mad,” because hatters in that era frequently showed signs of poisoning from mercury that was commonly used in the processing of animal hides in the hat industry. In the 1900s, a physician named Alice Hamilton was one of the early pioneers in the field of occupational medicine in the United States. All of this is mentioned here to simply make the point that, regretfully, there is nothing new about workers being exposed to hazardous chemicals on the job.

Hazardous chemicals have pretty much always been around, and whether we happen to be at work, or even at home, hazardous chemicals are a fact of life for most of us. But that fact does not mean we cannot take steps to protect our associates, our loved ones, and ourselves. Safety precautions such as those required by OSHA’s HCS, as updated by incorporation of the GHS, represent a further step in the right direction. Ultimately, however, our safety on the job is in our own hands and can only be truly realized by conscious dedication to learning about the hazardous chemicals to which we are exposed and then following the guidelines, recommendations, rules, and requirements for protecting ourselves.


OSHA and other regulatory bodies periodically conduct formal review processes of current regulations. These reviews may result in updates as a new Final Rule published in the Federal Register but these documents are, for the better, always subject to change. For example, the GHS has conducted several updates since OSHA aligned with the global harmonized system in 2012.

The GHS is updated as necessary to reflect new requirements, and OSHA may make further changes to the HCS as needed. Some changes may not effect you but it's best to stay on top of compliance efforts so you can efficiently adopt any regulatory updates that effect you. Are you confident your facility is in full HCS compliance and ready for any potential regulatory changes?

For more information on how Stericycle can help you stay compliant with OSHA's Hazard Communication Standard, visit us at Stericycle.com/OSHA.

https://www.stericycle.com/services/compliance/osha

16 OSHA’S HAZARD COMMUNICATION STANDARD© 2020 Stericycle, Inc. All rights reserved. STC_HCSHAZCOMWP_0319


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Sources:

1. Occupational Safety and Health Administration (OSHA), Appendix A to 1910.1200, https://www.osha.gov/dsg/hazcom/hazcom-appendix-a.html, accessed 2/15/19.

2. OSHA, Appendix B to 1910.1200, https://www.osha.gov/dsg/hazcom/hazcom-appendix-b.html, accessed 2/15/19.

3. OSHA, Appendix C to 1910.1200, https://www.osha.gov/dsg/hazcom/hazcom-appendix-c.html, accessed 2/15/19.

4. OSHA, Publications/Safety Data Sheets, https://www.osha.gov/Publications/OSHA3514.html, accessed 2/15/19.

5. OSHA, Safety and Health Topics/Hazardous Drugs, https://www.osha.gov/SLTC/hazardousdrugs/controlling_occex_hazardousdrugs.html, accessed 2/15/19.

6. OSHA, Safety and Health Topics/Hazardous Drugs, https://www.osha.gov/SLTC/hazardousdrugs/controlling_occex_hazardousdrugs.html#hazcom, accessed 2/15/19.

7. Centers for Disease Control and Prevention (CDC), NIOSH/Docs, https://www.cdc.gov/niosh/docs/2016-161/pdfs/2016-161.pdf?id=10.26616/NIOSHPUB2016161, accessed 2/15/19.

8. Stericycle data, RMW Missed Stops Report, YTD August 2018.

http://www.stericycle.com

https://www.osha.gov/dsg/hazcom/hazcom-appendix-a.html


https://www.osha.gov/dsg/hazcom/hazcom-appendix-c.html

https://www.osha.gov/Publications/OSHA3514.html

https://www.osha.gov/SLTC/hazardousdrugs/controlling_occex_hazardousdrugs.html

https://www.osha.gov/SLTC/hazardousdrugs/controlling_occex_hazardousdrugs.html#hazcom

https://www.cdc.gov/niosh/docs/2016-161/pdfs/2016-161.pdf?id=10.26616/NIOSHPUB2016161

OSHA’s Hazard Communication Standard€¦ · before 2012, considering Category 4 the most...

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