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Haz Comm: Are You Still Out of Compliance?

By Jim Rogers, Special to AZBEX

One of the OSHA standards that has been significantly updated in the last few years is commonly known as the Haz Comm standard, or the Right to Know requirements. These regulations can be found in 29 CFR 1910.1200 and they apply to varying degrees to all types of workplaces that use, store or produce hazardous products.

A recent conversation with officials at the Arizona Department of Occupational Safety and Health revealed that a majority of construction inspections here are still resulting in the issuance of citations for violations of these standards, indicating that employers continue to be misinformed on what they need to do to comply.

First, the premise of this set of rules is simple: All employees have a right to know about the hazards posed by the products they are working with. This includes the more obvious hazards, such as working with a product that produces toxic fumes, and the not as obvious hazards such as recognizing that lumber produces a hazard in the form of flammable saw dust when it is cut.

Simply put, it is the company’s responsibility to identify these workplace hazards and establish a program for communicating the dangers to all potentially exposed employees so that steps can be taken to keep them safe. This is accomplished through the development of a written plan, inventorying all of the hazardous materials that are used, obtaining hazard information for these products from the manufacturer or importer, and ensuring that information is communicated to all potentially affected employees through facilitated access to the product information, proper labeling of products and containers, and training on how to stay safe.

Understanding what information you need to collect and include in your Haz Comm program is an important first step for any employer. It is also important to understand the employee training that is required under the standard.

Additional considerations include:

  • Companies must maintain a list of the chemicals being used in the workplace
  • Safety Data Sheets (SDS’s) must be obtained for each product on the chemical list
  • The chemical list and the SDS’s must be available for access by all employees
  • Employees must be taught how to read the SDS’s – this is where you find requirements for everything from handling and storage to the PPE required to be worn
  • Employees must be made aware of hazards before they handle chemicals
  • Product containers must be labeled using the new GHS pictograms and hazard statements
  • In most instances, when you put a product into a secondary container it must have the same label as the original

Having a better understanding of the intent of the Haz Comm standard, understanding how the rules apply, and understanding who is actually required to do what, can lead to better compliance, easier maintenance and a safer and more productive workplace.

For more information on Haz Comm compliance, including discussions on electronic Safety Data Sheets, the changes brought about by GHS (Global Harmonization System), and new requirements for labeling secondary containers, visit my blog posts. For even more information, check out ABA’s half day seminar coming up later this month.

NOTE: Jim Rogers is an experienced construction industry trainer and educator that stresses the importance of integrating safety, quality and productivity into all operations. Find Jim at LinkedIn.

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