“What’s in that bottle?!” seems to be one of the most frequent questions Environmental, Health and Safety Managers ask. The ever-changing chemical inventory at many manufacturing facilities makes it challenging to remain constantly aware of what hazardous chemicals are present on-site; however, not knowing can be costly and, at times, catastrophic.
Each year, the Occupational Safety and Health Administration (OSHA) publishes the "10 Most Frequently Cited Workplace Safety Violations." For the past several years, the list has remained consistent with the same violations occurring, including Hazardous Communication Standard (HazCom) violations ranked among the top five.
The OSHA HazCom standard (29 CFR 1900.1200) is in place to ensure that hazards of all chemicals are evaluated, and details are communicated to employers and employees. General Industry HazCom violations most frequently stem from a failure to communicate risks caused by exposure to hazardous chemicals in the workplace, with some of the most common mistakes including:
- Proper chemical labeling,
- Providing safety data sheets,
- Employee training; and
- Having a written hazard communication program.
Although the requirements of the standard are not complex; many facilities find it challenging to implement a sustainable, systematic, chemical inventory management program. Without a program in place, these facilities risk finding themselves on OSHA’s enforcement ledger and subject to hefty fines.
We are offering some quick tips and tricks to help you stay compliant with HazCom requirements.
1.Develop a written Hazard Communication Program that includes: how your facility will implement the standard; an inventory of all hazardous chemicals present in the workplace; specific procedures for container labeling; maintaining, managing, and deploying safety data sheets; and a process for training employees.
TIP: This plan does not have to be lengthy or complicated; think of it instead as an outline for implementing your program that assures all requirements have been addressed in a systematic and organized way.
2.Put together a cross-functional team to help keep track of chemical purchases, inventory, labels, and safety data sheets.
TIP: A chemical acquisition request form that can be submitted to a designated person or department is a great place to start.
3. Invest in a chemical inventory management system.
TIP: Cornerstone offers a chemical management solution, called Foundation, that combines software with the knowledge and expertise of experienced environmental and safety professionals to help manage SDS’s and product inventory. Click here to learn more about Foundation.
4. Do the training! Employees have a right to receive information regarding hazardous substances to which they may be exposed.
TIP: A combination of classroom and hands-on training will help employees retain the information they are learning longer. Start in the classroom with practicing reading Safety Data Sheets and end on the floor with a container labeling exercise!
5. Evaluate and reassess your program and practices frequently.
TIP: Include HazCom in your annual program management review.
If you need help with your chemical inventory, are looking for a more practical approach, or just wanting to talk through these preventative steps, please contact us at info@corner-enviro.com or (317) 733-2637.