Hazard Communication

 The Hazard Communication Standard (HCS), sometimes called “The Right to Know Law” or “HazCom”, is a set of regulations first promulgated in 1988 by the Office of Occupational Safety and Health Administration (OSHA). Its purpose is to ensure that the hazards of workplace chemicals are evaluated, and that information on the hazards is provided to employers and employees. HCS covers nearly all employers and is applicable to most work operations where hazard materials are present.

The Scope

The Standard requires that every affected employer establish a program to inform employees of the hazards associated with the materials in their workspace. The program must possess the following five key components:

  1. Written Hazard Communication Program documentation;
  2. Identifying and keeping an inventory of hazardous chemicals;
  3. Obtaining and keeping MSDSs on the identified hazards;
  4. Ensuring that the hazardous materials are labeled with name and hazard; and
  5. Training employees on The Standard, safety information, labeling, and protective measures.

Hazardous Chemicals and Materials

Many people think of chemicals as only being liquids in containers; however, chemicals may actually be liquids, solids, gases, vapors, fumes, and mists. The HCS covers chemicals in all physical forms whether contained or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If a chemical is hazardous and there is a potential for exposure, the rule applies. Therefore, many items are covered e.g. floor cleaners, fuels, welding rods, paints, adhesives, compressed gases and concentrated acids.

1. Written Program

Under The Standard, each employer (and/or department) must complete and keep a written Hazard Communications Program. The written program describes how the requirements for labels and other forms of warning, material safety data sheets (MSDSs), and employee information and training are implemented in the workplace. It indicates who is responsible for MSDSs, labels, warning signs and training, as well as the location of the inventory, MSDSs, and other information and resources pertaining to hazardous chemicals and safety measures. An inventory list of hazardous chemicals is required to be maintained as part of the written program. A copy of Drury University’s written program is available in Administrative Services and Facilities Services.

2. Chemical Inventory

In order to know how to protect oneself, each employee needs to know about the hazards. It’s imperative that departments compile and maintain a Chemical Inventory, which must include the typical maximum quantity, its location within the workplace, and where the MSDS for the material will be kept. The Chemical Inventory will be located in an easily accessible area designated by the Department Head. The Chemical Inventory must be updated at least annually or as new chemicals are brought into the workplace. The Chemical Inventory must be readily available to employees. New or newly assigned employees shall be made aware of the Chemical Inventory before working with hazardous chemicals or before working in an area containing hazardous chemicals. It’s important that all Chemical Inventories be retained by each department for a minimum of thirty years.

3. Material Safety Data Sheets (MSDS)

Material Safety Data Sheets are documents containing information on each hazardous chemical, including its potential hazardous effects, its physical and chemical characteristics, and recommendations for appropriate protective measures.

When purchasing hazardous chemicals, each department shall request from the chemical manufacturer and distributors a MSDS for each hazardous chemical they have inventoried. It is each department’s responsibility to maintain copies of the MSDSs for each chemical they possess and have them available for review by employees or their designated representatives and students. Employees or students who desire a copy of the MSDSs for hazardous chemicals to which they may be exposed should contact their supervisor, instructor, department head or another designated individual.

4. Labeling

Hazardous chemicals shall be obtained with original labels with the following:

    1. Identification of the chemical (common, technical name, or primary components)
    2. Hazard warning (flammable, corrosive, poison, etc.)
    3. Name and address of the chemical manufacturer (if provided).

Department heads must ensure that the container original labels are not defaced. If the labels become damaged, the department head must ensure the label is replaced. When a hazardous chemical or material is transferred into a secondary container, the secondary container and/or container enclosure must be labeled with the identity of the chemical and the hazard warning using the NFPA warning system or equivalent.

5. Employee Information and Training

Drury University Department Heads or a designated individual will provide employees with information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard is introduced into their work area. In addition to the elements of the Hazard Communication Standard and Drury Hazcom Program, each affected employee will be trained on:

A. Any operation or location in their work area where hazardous chemicals are present.

  • Definitions and information provided on MSDSs as well as the availability of other sources of information on hazardous materials.
  • Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as visual inspection, odor, monitoring devices, etc.).
  • The physical and health hazard of the chemical, including protective measures used to protect the employee from exposure. They may include personal protective equipment (PPE) such as safety eyewear, laboratory coats, tyvek suits, respirators, etc.
  • An explanation of the labeling system such as the NFPA system for secondary container.

Non-routine tasks involving hazardous chemicals will require additional information and training prior to implementing such tasks. This includes hazards associated with chemicals contained in unlabeled pipes. Training documentation will be kept with the written program and/or by the department head. The department supervisor or a designated individual provides classes on the Hazard Communication Standard requirements and provides information to supervised employees on the specific chemical hazards in the work areas.