October 09, 2020

Understanding and Complying with OSHA’s Hazard Communication Standard

The primary mission of the Occupational Safety and Health Administration (OSHA) is to keep workers safe. Although the agency has a wide range of regulations that cover a variety of topics, the two most applicable requirements for healthcare organizations are the Bloodborne Pathogens Standard and the Hazard Communication Standard. Given the complexity of these rules, it’s not surprising they also are the two most challenging standards for healthcare organizations to follow. Together, they account for 75% to 80% of healthcare penalties.

While we have previously addressed the nuances of the Bloodborne Pathogens Standard, this article answers some frequently asked questions about the Hazard Communication Standard, providing tips and strategies to safeguard employees and ensure regulatory compliance. 

What is the Hazard Communication Standard?

OSHA requires employers to communicate with employees about hazardous chemicals they may be exposed to at work. The OSHA Hazard Communication Standard, commonly referred to as “HazCom,” details what information needs to be shared, by when and to whom. It’s divided into five main activities:

  1. Maintaining a master list of hazardous chemicals used within the facility
  2. Creating a written hazard communication program
  3. Properly labeling dangerous chemicals
  4. Making Safety Data Sheets (SDS) readily accessible
  5. Providing comprehensive staff training

In 2012, OSHA began aligning the Hazard Communication Standard with the Globally Harmonized System (GHS), a set of internationally created and approved criteria for classifying health, physical and environmental hazards. The GHS specifies information that organizations must use to describe hazardous chemicals on any labels, safety data sheets and other communications.

What Does the Hazard Classification Process Involve?

OSHA has established health and physical hazard classes for different chemicals. Health hazards reflect how the chemical affects a person’s health and may include things like toxicity, carcinogenicity, skin corrosion, eye damage and aspiration. Physical hazards describe a chemical’s properties that could cause harm. For example, if the chemical is flammable, corrosive, an oxidizer, self-heating and so on. Health and physical hazards are also given a category designation that indicates how dangerous the item is on a scale of one to four, with one being the most hazardous and four being the least.

To comply with OSHA’s Hazard Communication Standard, healthcare organizations must maintain a list of the hazardous chemicals they have on site. To do this, an organization may want to conduct an audit in which a team walks through the facility to identify hazardous chemicals. In addition, compliance officers should consider reaching out to department heads and asking them to supply a list of hazardous chemicals found in their departments.

Do We Need a Written Hazard Communication Program?

The Hazard Communication Standard requires healthcare organizations to have a written program that describes what risks employees face due to hazardous chemicals and how it will share information with employees about those risks and any potential health issues that could result.

The level of detail required in these programs is significant, and an organization may want to start with a generic plan created by an experienced third party and modify it as needed to reflect the organization’s unique characteristics. By taking this approach, an organization can be sure to include all the required elements. Healthcare organizations should also review and update their programs regularly to reflect regulatory changes and make sure their written programs are readily accessible to staff.

What Information Must Be Included on a Hazardous Chemical Label?

According to GHS requirements, the manufacturer’s label on hazardous chemicals containers must provide the following information:

  • The product identifier or name
  • A signal word that underscores the threat, such as “danger” or “warning”
  • A hazard statement that relates to the relevant hazard class and category
  • Pictograms or symbols that convey health and physical information. These visual icons show hazard types. For instance, the skull and crossbones denote toxicity. Based on the GHS requirements, OSHA adopted eight pictographs, including ones that represent flammability, corrosiveness, toxicity, and more.
  • Precautionary statements that provide measures to minimize or prevent adverse effects
  • Supplier information, including name, address and telephone number

While product labels are provided by the manufacturer or supplier, if chemicals are removed from the original, labeled container, organizations must create a workplace label that includes the above information and apply it to the secondary container.

However, there are a few exceptions to this requirement. For example, an employee is not required to label a secondary container if they intend to use the chemical immediately. Also, when a pharmacy dispenses drugs to a healthcare provider for direct administration to a patient, it is exempted from the secondary labeling requirement.

In some cases, organizations can use alternatives to labels as long as they convey all the necessary information. Such alternatives should be discussed in the written hazard communication program, and organizations should provide training about the alternatives to employees.

What are Safety Data Sheets?

Safety Data Sheets (SDS) communicate essential information about hazardous chemicals, including their properties and risks, correct handling and storage practices, and what protective measures employees should use to remain safe when handling or interacting with chemicals.

Organizations must have a Safety Data Sheet for each hazardous chemical in their inventories and ensure the information is readily accessible in the work area for staff who could encounter the chemical.

Are There Training Requirements Associated with the Hazard Communication Standard?

OSHA requires organizations to provide hazard communication training at two different times. First, workers should receive training when they are initially assigned to a position where there is a potential for hazardous chemical exposure. Second, training should be required whenever there is a new hazardous chemical introduced in their work environment for which they have not been previously trained.

What Should Be Included in Employee Training for the Hazard Communication Program?

Topics to cover during training include:

  • The nature of the hazards present
  • How employees can protect themselves, including the use of personal protective equipment, workplace practices and emergency procedures
  • How to access the hazard communication program and master list of dangerous chemicals
  • When it’s necessary to create a label and proper labeling elements
  • The purpose of Safety Data Sheets (SDS) and how to access them
  • Methods used to detect the release of chemicals

Ensure Your Organization’s Compliance with OSHA Training

As with other aspects of OSHA compliance, online training modules can provide a user-friendly, accessible format that staff can work on at their convenience. These tools are updated frequently and document when training is complete, which is beneficial for demonstrating compliance.

Learn more about how Stericycle can help your organization fully comply with OSHA’s Hazard Communication Standard.

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