Introduction
The Hazard Communication Standard, also known as the “Right-to-Know Law,” ensures that chemical hazards in the workplace are identified and evaluated and information concerning these hazards is communicated to employers and employees. This standard has been modified to align with the provisions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS establishes the criteria for the standardization of hazard classifications and hazard communication creating one system for workers, consumers, transportation workers and emergency responders. This provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.
Written Program
Employers must develop, implement and maintain at each workplace, a written hazard communication program which at least describes how requirements for labels and other forms of warning, Safety Data Sheets (SDS), employee information and training will be met.
The written program must include:
- A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate SDS (the list may be compiled for the workplace as a whole or for individual work areas); and
- The methods the employer will use to inform employees of the hazards of non-routine tasks and the hazards associated with chemicals contained in unlabeled pipes in their work areas.
The employer must make the written hazard communication program available upon request. Where employees must travel between workplaces during a work shift, the written hazard communication program may be kept at the primary facility.
Labels and Other Forms of Warning
The employer must ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following:
- Product identifier;
- Signal word;
- Hazard statement(s);
- Pictogram(s);
- Precautionary statement(s); and
- Name, address and telephone number of the chemical manufacturer or other responsible party.
Product identifier and words, pictures, symbols, or combination of, 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, must provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
The employer must not remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information. The employer must ensure that workplace labels or other forms of warning are legible, in English and prominently displayed on the container or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well.
Safety Data Sheets
Employers must have a Safety Data Sheet (SDS) in the workplace for each hazardous chemical which they use. SDS are available from the chemical supplier or manufacturer and contain specific chemical hazard information such as: physical hazards, health hazards, routes of entry, exposure limits, precautions for safe handling and use, spill clean-up procedures, personal protective equipment, emergency and first-aid procedures and the name, address and telephone number of the chemical manufacturer. The employer must maintain copies of the required SDS for each hazardous chemical in the workplace and must ensure that they are readily accessible to employees during each work shift.
Training
Employers must provide employees with effective information and training 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 on is introduced into their work area. Information and training may be designed to cover categories of hazards or specific chemicals. Chemical-specific information must always be available through labels and SDS.
Employee training must include:
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
- The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
- The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures and personal protective equipment to be used; and
- The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the SDS, including the order of information and how employees can obtain and use the appropriate hazard information.