The Hazard Communication Standard (HCS) was written and enacted in 1983 by the Occupational Safety and Health Administration (OSHA) and is enforced in the State of Wisconsin by the Wisconsin Department of Safety and Professional Services (WI Statues 101.055). It is based on a simple concept that employees have both a need and a right to know the hazards and identities of the chemicals that they are exposed to when working in non-laboratory work areas.
In March 2012, the Hazard Communication Standard was revised to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals also known as GHS. The revised standard requires the manufacturer or importer of chemicals to classify their chemicals according to their physical and health hazards, establish specific formatted shipping labels with the chemical identity, pictograms, signal works, precautionary statements, hazard statements and the manufacturer name, address and phone number as well as create a 16 section Safety Data Sheet (SDS) formerly Material Safety Data Sheet (MSDS) for each chemical.
There are six elements of the HCS and GHS: hazard determination and classification, chemical inventory, labeling, Safety Data Sheets (SDS), employee training & written program.
Chemical inventories are a vital part of a chemical safety program. Inventories provide a record of room and building content which is important in emergency situations as well as inventory control.
Each campus department working with or using hazardous chemicals must complete and maintain a chemical inventory. At a minimum, the inventory should include the chemical name as it appears on the shipping label and SDS, the manufacturer’s name and address and the location of the chemical (building & room). It must be updated annually or as needed and kept with the written plan.
All containers of hazardous chemicals must be labeled by the manufacturer or importer according the recently revised Hazard Communication Standard and Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The label created and used by the manufacturer is called the shipping label. Chemicals that are transferred to secondary containers must also be labeled with a workplace label.
- Shipped containers which are the original container must be labeled with the GHS label which includes the identity of the chemical, signal work, pictogram, hazard statements, precautionary statements and the name, address and phone number of the manufacturer.
Example of a GHS Shipping Label
- Secondary containers (transferred chemicals) can be labeled with either the GHS label or a label which contains the identity of the chemical and words, pictures, symbols or a combination which provides information regarding the physical and health hazards of the chemical. This is called the workplace label.
- Container for use by one person. A portable container which is filled from a labeled container that is for the employee’s immediate use during that work shift, will be used by the same employee, will not be left unattended by that employee and will be used entirely, need not be labeled.
- Stationary process containers. Instead of a label, a posting, placard or sign may be used on stationary process containers, pipes or piping systems. The identity of the hazardous chemical and appropriate hazard warning must be included.
- Never deface or remove any container labels.
- Labels and other forms of warning must be legible, prominently displayed and in English. Employers having employees who speak other languages may add the information in their language as long as the information is presented in English as well.
Each employee shall be provided with information n the hazardous chemicals they work with upon their initial assignment and whenever a new chemical is introduced. The information must include any operations in their area where hazardous chemicals are present, the location of the written program and location of the chemical inventory and Safety Data Sheets.
Written Hazard Communication Program
The written Hazard Communication Program describes how the facility will develop, implement and maintain at each workplace, the elements of the standard. It is intended to be a blueprint for implementing the program and provides assurance that all aspects of the requirements have been addressed. The written program must include a list the chemicals present in the workplace. Who within the organization (by job title) is responsible for the various aspects of the program such as labeling, Safety Data Sheets (SDS), non-routine tasks, outside contractors and employee information and training.
The written program includes information on how the employees have access to the SDS, precautionary measures to be taken when working with chemicals, the labeling system used in the workplace, employee information and training, non-routine tasks, contractor employees and multi-employer worksites. The written program is available to employees and evaluated annually.
The purpose of the Hazard Communication Standard is to ensure that the hazards of chemicals are identified by the manufacturer and then transmitted to employers and employees. This is true also for contractors working with hazardous chemicals.
Contractors who perform work on campus need to have a Hazard Communication Program in place. The contractor must inform the campus of any hazardous chemicals they intend to bring in or use while on university property and precautionary measures that need to be taken to protect employees and the labeling system. Likewise, when contractors are working on the campus, they must be informed of any hazardous chemicals that the campus uses that they may come in contact with or be exposed to in the project area. Both parties must have Safety Data Sheets (SDS) for each hazardous chemical accessible for the duration of the project and provide information on their labeling systems and any precautionary measures that need to be taken to protect employees.
When employees are required to perform hazardous non routine tasks involving chemicals (tasks that are completed infrequently), training must be conducted to inform the employees of the physical, health, asphyxiation, combustible dust and pyrophoric gas hazards of the chemicals, precautions needed, Personal Protective Equipment (PPE) required, first aid, emergency and spill procedures and methods to detect the release or presence of chemicals.