When preparing your Job Safety Analysis or Job Hazard Analysis, it is imperative that the team know and understand U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.
According to OSHA, "Employers that have hazardous chemicals in their workplaces are required by OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a hazard communication program. The program must include labels on containers of hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and training for workers. Each employer must also describe in a written program how it will meet the requirements of the HCS in each of these areas.” OSHA
OSHA has outlined six steps for employers to help them implement a Hazard Communications Program that is compliant with the requirements of 29 CFR 1910.1200.
- Learn the Standard/Identify Responsible Staff
- Prepare and Implement a Written Hazard Communication Program
- Ensure Containers are Labeled
- Maintain Safety Data Sheets (SDSs)
- Inform and Train Employees
- Evaluate and Reassess Your Program
An effective written hazard communication program should include all of the elements outlined in the following figure:
Each chemical storage container must have the following:
- Product identifier
- Signal word
- Hazard statement(s)
- Precautionary statement(s)
- Name, address, and phone number of the responsible party
Pictograms are used to rapidly assess the hazards stored in a container. OSHA has implemented Globally Harmonized System of Classification and Labeling of Chemicals (GHS) to help employees understand the labels that are on chemical storage containers. The labels on chemical containers are now required to contain standardized pictograms. A review of these pictograms during the Job Safety Analysis or Job Hazard Analysis can be one way to encourage a discussion about the chemical hazards for a particular task or job. The following is a list of these standardized pictograms.
Flame Over Circle
Skull and Crossbones
In addition to pictograms on the chemical storage containers, there are also pictograms required during transport of the chemicals.
These transportation pictograms are generally regulated and required by the Department of Transportation (DOT).
OSHA's Hazard Communication standard also require and specify the information that needs to be included on Safety Data Sheets (SDSs). SDS are designed to provide salient information about the chemicals within a container. The SDS is intended to be used by a wide range of people, including employers, workers, safety and health professionals, emergency responders, government agencies, and consumers. The chemical manufacturers, importers, and distributors are required to produce the SDS and confirm that the information contained in the SDS is true and accurate.
The UN standard divides the SDS into sixteen sections, some of which are not mandatory. The sections are as follows with the non-mandatory sections indicated in italics:
- Hazard(s) identification
- Composition/information on ingredients
- First-aid measures
- Firefighting measures
- Accidental release measures
- Handling and storage
- Exposure control/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information
Additional information about the requirements for Safety Data Sheets are available from OSHA.
Making sure your employees are Informed and Trained is an integral component of the OSHA Hazard Communication Standard. The standard requires that employers train their employees on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. The training should include basic safety information about the chemicals and how to find information about the chemicals in the Safety Data Sheets. Employees need to understand the information contained on the chemical container labels and how to get additional information about the chemicals they work with if the need arises. When talking about chemical hazards during the Job Safety Analysis is a great time to make sure that workers have the proper hazard communication training and that all SDS are up to date.
It is not sufficient to either just read material to the workers, or simply hand them material to read. Employees must be trained such that they understand the information that is being presented. OSHA has published a "DRAFT MODEL TRAINING PROGRAM FOR HAZARD COMMUNICATION” which can be found on their website.
A Job Safety Analysis worksheet or Activity Hazard Analysis (AHA) form can be created to determine the safety procedures when working with chemical hazards. JSABuilder is a state-of-the-art online job safety analysis app to assist in preparing your Job Hazard Analysis or Job Safety Analysis. Set up a free trial account today and follow us on Twitter @JSABuilder, where we Tweet about Health and Safety, provide Safety tips, and updates on current Health and Safety topics.