HazCom: Right to Understand
In last week’s safety tip, we shared OSHA’s top 10 violations for 2013, as presented at this year’s National Safety Council’s Congress. Here’s a link to the top 10 if you would like to see it again: http://news.yahoo.com/oshas-top-10-violations-2013-announced-national-safety-161300619.html. We discussed the top violation last week, which was Fall Protection. Our point was that no matter what height you are working on, the issue remains the same – you should have a safe working surface.
This week we want to focus our attention on the number 2 violation, which has hung in the top 3 violations for several years – Hazard Communication (HazCom). This regulation has received a lot of attention lately, as OSHA adopted the Globally Harmonized System (GHS), incorporating it into the standard. Just a quick reminder, all employees affected by HazCom must be trained in GHS by December 1, 2013.
HazCom is sometimes also known as the employee “Right to Know” standard. We’re taking that a step further, as we believe employees have the “Right to Understand” the hazards of the chemicals they work with. OSHA says something similar when in the regulation, under the subsection for training (29 CFR, 1910.1200 (h) (1) https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099:
Employers shall 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 about is introduced into their work area….
We emphasized the word “effective.” If training is to be effective, then employees need to understand what they are being told and what they are seeing on labels and Safety Data Sheets (SDS). How do you do that?
1. OSHA is working towards a standardization of pictograms (a picture or pictogram may not be worth a thousand words, but it does provide a standard visual representation of a hazard), SDS, and labels. Make sure your employees are trained on this by December 1, 2013.
2. You can work towards a safe and informed workforce by helping employees that might not read or understand English. OSHA allows the addition of labels in languages your employees can understand, as long as those labels do not replace or cover the original label. (See 1910.1200(f)(2) and (10), linked above).
3. As new Safety Data Sheets (SDS) arrive in your workplace, don’t just put them in a folder and file them away. Take this as a good opportunity to review the new GHS and show them to your staff. Review in understandable terms and language, the new standardized pictograms, format of the SDS, and PPE graphics. Ask questions of your employees – make sure they understand.
4. Written HazCom Program. Some of the HazCom violations were that either a business did not have a written HazCom program, or the employees did not know where to find it. If you have hazardous chemicals in your workplace, you need to have a written HazCom program, and you need to make that, if an OSHA representative visited your work site, any employee would know where the program is. It can be on an internal intranet server, or a binder on a shelf.
If you still need to get your employees trained in GHS, we can help. Our HazCom online training class at hazmatschool.com will help you comply with that regulation. Here’s a link to the course description for your convenience: http://www.hazmatschool.com/product/osha-hazard-communication-2-hour/.
There’s a pictogram at the top of this safety tip. It’s one of the new ones for GHS. Send us an email to info@scm-safety.com, or leave a note on our Facebook page of what hazard this denotes, and we’ll send you an SCM Shirt, hat or CPR barrier kit.
