The goal of OSHA’s Hazard Communication Standard (HCS) is to “ensure that the hazards of all chemicals produced or imported are evaluated and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, [material] safety data sheets (SDS), and employee training.” Information and training are the core elements of a hazard communication program with the purpose of preventing illness or injury due to chemical exposure.

Training should include education on the HCS, hazardous properties of all chemicals in the workplace and methods of protection to ensure a safe work environment. It is important for each employee to comprehend and understand the risks associated with any potential exposure. The Hazard Communication Program is the written plan describing how the employer will implement and comply with the Hazard Communication Standard. It will be the initial focus of an investigation should an OSHA compliance officer conduct an inspection. The plan should include a complete list of all potentially hazardous chemicals in the workplace and corresponding SDS sheets, how the SDS will be maintained and accessed, and documentation of training and education on usage of labeling and SDS sheets. Each employer must have a designated OSHA compliance officer who is responsible for maintaining an up to date list of all hazardous chemicals in the workplace and current safety data sheets (SDSs) on each of these chemicals in the office.

In addition, the compliance officer should determine if the chemical containers are properly labeled and appropriately updated. Employees should know where to access SDSs in the workplace. Detailed procedures for purchasing, receiving, storage and handling of chemicals should also be readily available. In the event of a new chemical being introduced to the workplace, procedures should exist to educate the employees prior to usage. This training can be performed on individual chemicals if there are only a few chemicals used in the workplace or the training can be done by hazard categories should many chemicals exist in the workplace. In March 2012, OSHA revised the HCS to align with the vast majority of the international community regarding labeling and classification of hazardous chemicals. Employee training on the United Nations Globally Harmonized System for labeling and classification was to be completed by December 1, 2013, and have included education on the label elements and requirements as well as training on the new 16-section SDS format. Transition to the new system will occur in stages and be fully operational by December 1, 2016. 

OSHA Checklist for Compliance

Following this checklist will help ensure your compliance with the rule:

• Obtained a copy of the rule.
• Read and understood the requirements.
• Assigned responsibility for tasks.
• Prepared an inventory of chemicals.
• Ensured containers are labeled.
• Obtained MSDS (Material Safety Data Sheet) for each chemical.
• Prepared written program.
• Made MSDSs available to workers.
• Conducted training of workers.
• Established procedures to maintain current program.
• Established procedures to evaluate effectiveness.

For Hazard Communication, OSHA has recently published a Small Entity Compliance Guide for Employers that Use Hazardous Chemicals, available at https://www.osha.gov/Publications/OSHA3695.pdf.