Statistics from the Occupational Health and Safety Administration (OSHA) reveal that standards for hazard communication are regularly not being met in United States workplaces, as it was one of the Top 10 Most Frequently Cited Standards in 2021. Companies from various industries lowered their bottom line margins, in total paying OSHA over $3 Million in fines for falling short when it comes to implementing means for effective chemical hazard communication in the workplace. This article will break down this standard for hazard communication and suggest ways for companies to better handle this difficult task.
The fundamental requirements of Hazard Communication Standard CFR 1910.1200.
Hazard communication is the process of identifying and communicating the hazards of chemicals to employees. The Hazard Communication Standard (HCS) was created to ensure employees understand the risks associated with workplace chemical exposure and what they can do to protect their health, as well as the health of their coworkers. The following details are mandated by the HCS:
- Labels on containers of hazardous chemicals, safety data sheets (SDS) for each chemical, and training for employees who work with hazardous chemicals.
- Employers must also provide appropriate personal protective equipment (PPE) for use during work activities where hazards are present.
- Employers must keep records documenting all aspects of their compliance with the HCS standard, including employee training and information about PPE use.
Governance of chemical substances in the United States.
The United States has several regulations covering the use and handling of hazardous chemicals. The objective of this legislation is to ensure the safe a responsible use of hazardous chemicals. The US Environmental Protection Agency (EPA) oversees chemical safety in collaboration with the:
- Occupational Safety and Health Administration (OSHA)
- National Institute for Occupational Safety and Health (NIOSH)
- Consumer Product Safety Commission (CPSC)
- Food and Drug Administration (FDA)
These governing authorities work together to maintain the safety of chemical production, storage, and handling for workers, consumers, and the environment.
Identification and labeling of hazardous chemicals.
The Hazard Communication Standard (HCS), also known as the “Right to Know” regulation, applies to employers who manufacture, import, export, or use any substance that meets the definition of a hazardous chemical. The proper identification and labeling of hazardous chemicals are the most important components of communicating chemical hazards.
The first step to recognizing the hazards (and their specific properties) that are present in a workplace is to create an inventory of chemicals and set up a database with SDS information. The SDS must always be kept up to date with current chemical manufacturing details. (This is much easier to comply with by the implementation of an electronic SDS management system.) Additionally, as hazardous chemicals are dangerous and can lead to serious injuries if they are not handled correctly, it is important to label hazardous chemicals with the correct information so that employees are aware of their presence and can take the necessary precautions when working with them. This includes the labeling of hazardous chemicals containers and posting of SDSs in locations that are accessible to employees. (With an electronic SDS database, it is possible to accomplish this latter requirement by printing out a QR code that automatically accesses the SDSs via a no-login link when scanned.)
Digital tracking and fully integrated compliance.
Companies must track the container type, location, quantity, expiration dates, and permit information of high-risk chemicals to prevent accidents and ensure that their production is not disrupted due to expired chemicals. Software for chemical inventory management can also assist with this by allowing users to schedule automated reminders and notifications to be sent out when chemicals are about to expire, stock is low, or chemical testing is due. Furthermore, some companies that deal with high-risk chemicals must also ensure that chemicals of interest (COI) listed under the Chemical Facility Anti-Terrorism Standards (CFATS) process are identified and registered to meet the requirements of 6 CFR Part 27.
Managing the details required to meet such complex regulatory requirements in a complete and streamlined fashion can be challenging. To attain this goal, companies need a proactive approach that includes the capabilities of cloud-based data management, electronic SDSs, container-level tracking, and RFID technology for real-time information retrieval. The consequences of not having an adequate chemical management program are severe. In addition to OHSA fines, companies could face further losses due to litigation from stakeholders (contractors, customers, and suppliers). Failure to meet compliance can also affect an organization’s reputation and could sever investor relations.
In choosing an appropriate digital tool for chemical management, management teams should begin the process with a self-assessment by asking three strategic questions:
- Is the software easy to use?
The first thing to consider when investing in chemical inventory and electronic SDS management software is whether it is intuitive and will therefore be easily adopted by users. While training should be based on the needs of individual employees, starting with software that has a simple and easily understood interface will boost the likelihood of a successful roll-out.
2. Is the software externally verified?
The right chemical inventory and SDS management software will not only be easy to integrate with an organization’s current systems but will also be supported by chemical industry experts to offer validated support of the content. This also means that users will have access to the shared understanding of other professionals to make sure companies are using the best practices for compliance.
3. Does the software offer cross-functional communication?
A program for chemical management should keep the inventory of chemicals and electronic SDSs as up-to-date as possible. Cross-functional communication capabilities in chemical and SDS management software can accomplish this in real-time, as well as enabling the secure (and sometimes automatic) sharing of information between suppliers, inventory control, production, and the contractor’s staff.
Robust chemical management software can be a completely customizable solution for ensuring compliance with the Hazard Communication Standard 29 CFR 1910.1200 and Chemical Facility Anti-Terrorism (CFATS) Standards. When using such chemical inventory and electronic SDS software, procurement and production teams can ensure that the chemical inventory is efficiently organized and up to date. This applies to the effective use of resources (manpower, warehouse space, finances, etc.) and the reduction of waste (expired chemicals, time lost for reordering, fines, injuries, etc.). Employers should make sure chemical experts (such as professionals within the American Chemical Society) support the chosen module. Additionally, electronic SDS information can be linked to major chemical manufacturers so that companies will be automatically notified when chemicals are added or when datasheets are updated. The ease of using such tools to manage inventory data not only ensures compliance but also improves a company’s net profits.
Author Bio
The SafetyStratus Research Advisory Group (RAG) brings together thought leaders from the global environmental, health, and safety community to promote best practices and provide key insights in the profession and the industries they serve. The Research Advisory Group also advocates, where practical, the intersection of and advances with the use of technology, such as the SafetyStratus enterprise EHS software platform. Group membership consists of representatives from across varied disciplines and market sectors as well as select members of the SafetyStratus team.
The primary objectives of the SafetyStratus RAG partnership are to:
- Build a strategic partnership between EHS practitioners and the SafetyStratus team.
- Provide engaging and practical content to the global EHS community.
- Provide discipline and market feedback specific to SafetyStratus products and services.
While the objectives of the RAG are varied, the primary public-facing outcome will be available through engaging and practical content found on the SafetyStratus resource pages. Various articles, papers, and other valuable resources will be produced and shared as part of an ongoing effort to cultivate a robust community. Ultimately, the SafetyStratus RAG will expand to have a broader reach and provide opportunities for more inclusion by all interested EHS professionals in a collaborative community environment.
