This document discusses hazard communication and labeling requirements for hazardous chemicals. It outlines what information must be included on labels, such as the identity of chemicals, hazard warnings, and manufacturer details. It also discusses employer responsibilities to maintain labels and provide safety data sheets (SDS) to employees. SDS must include 16 sections with specific safety information. Employers must train employees on hazardous chemicals, SDS, labeling, and safety procedures. The training program and hazard communication plan must be in writing and designate responsible parties.

1. HAZARD
COMMUNICATION
BY MARSHAL MILLER

2. HAZARD
COMMUNICATION Why is Hazard Communication (HazCom) important?

3. LABELS
• Each container of a hazardous chemical must be
labeled, tagged or marked with:
• The identity of hazardous chemicals contained
inside
• Hazard warnings appropriate for employee
protection
• The name and address of the chemical
manufacturer
• Importer or other responsible party

4. LABELS
• Labels must be:
• Legible
• In English
• Prominently displayed
• Cross-referenced with the SDS and the list of
hazardous chemicals

5. EMPLOYER RESPONSIBILITIES
• Employers must ensure that labels on incoming containers of hazardous
chemicals are not removed or defaced
• All containers of hazardous chemicals, even very small ones, must be labeled
• Employers who become aware of any new significant information regarding the
hazards of a chemical must revise the labels for that chemical within three months
of becoming aware of the new information

6. EXEMPTIONS FOR INDIVIDUAL CONTAINERS
• Employers can post signs or placards that convey the hazard information if there are a
number of stationary containers within a work area that have similar contents and
hazards
• Employers can substitute various types of standard operating procedures (process
sheets, batch tickets, blend tickets and similar written materials) for container labels
on stationary process equipment if they contain the same information and the written
materials are readily accessible to employees in the work area.
• Employers are not required to label portable containers into which hazardous
chemicals are transferred from labeled containers and that are intended only for the
immediate use of the employee who makes the transfer.
• Employers are not required to label pipes or piping systems.

7. LABEL COMPLIANCE
• Designation of person(s) responsible for
ensuring labeling of in-plant containers
• Designation of person(s) responsible for
ensuring labeling of shipped containers
• Description of labeling system(s) used
• Description of written alternatives to labeling on
in-plant containers (if used)
• Procedures to review and update label
information

8. SDS FORMAT
• OSHA adopted ANSI Z400.1 standard in 2012
• (Formerly OSHA Form 174)
• Used by OSHA, DOT and EPA
• Broken down into 16 sections

9. SDS SECTIONS
• Exposure/ Engineering Controls, PPE, Exposure Guidelines
• Physical and Chemical Properties
• Stability and Reactivity
• Toxicological Information
• Ecological Information
• Disposal Considerations
• Transport Information
• Regulatory Information
• Other Information

10. SDS SECTIONS
• Chemical Product and Company Identification
• Composition and Information on Ingredients
• Hazards Identification Emergency Overview Potential Health Effects
• First Aid Measures and Note to Physicians
• Firefighting Measures
• Accident Release Measures
• Handling and Storage

11. SDS CHECKLIST
• Information in English
• Same Identity as used on label
• Chemical and Common names of single chemical or ingredients
• State if information withheld as Trade Secret
• Physical and Chemical characteristics of the chemical (Vapor Pressure, Flash Point)
• Physical hazards (Potential for fire, explosion, reactivity)
• Date of last change
• Name, Address and Telephone number for the responsible party

12. SDS CHECKLIST
• Health Hazards (Signs and Symptoms)
• Primary Routes of Entry
• Exposure Limits (OSHA, ACGUH, TLV)
• Information on carcinogen listings. (Check NTP Annual Report, IARC)
• Procedure and precautions
• Control Measures
• Pertinent Emergency and First Aid Procedures

13. SAFETY DATA SHEETS -
EMPLOYER RESPONSIBILITIES
• Employers:
• Shall maintain copies of any SDSs that are
received with incoming shipments of the sealed
containers of hazardous chemicals
• Shall obtain an SDS as soon as possible for
sealed containers of hazardous chemicals
received without an SDS
• Shall ensure that the SDSs are readily accessible
during each work shift to employees when they
are in their work areas

14. TRADE SECRETS
Trade Secret Requirements:
• The claim can be supported that the information withheld is a trade secret
• Information contained in the SDS concerning the properties and effects of the
hazardous chemical is disclosed
• The SDS states the specific chemical identity is being withheld as a trade secret
• The specific chemical identity is made available when a treating physician or nurse
determines that a medical emergency exists and the chemical identity is needed
for appropriate first-aid treatment

15. ELECTRONIC SDS ACCESS
• Employees must be trained to operate the data retrieval devices, including the specific software
involved
• An adequate back-up access procedure must be provided in the event of power outages,
equipment failures or loss of Internet access
• The electronic SDS retrieval system must be integrated into the overall hazard communication
plan.
• Hard copies must be available on demand so that they can be provided to employees and
medical personnel in the event of emergencies
• Employers with remote work sites must have a written procedure as part of their HazCom plan
for transmitting data to those work sites

16. SDS WRITTEN PLAN COMPLIANCE
• Designation of person(s) responsible for obtaining and maintaining
the SDSs
• How such sheets are to be maintained in the workplace (i.e., in
notebooks in the work area(s) or in a computer with terminal access)
• procedures on how to retrieve SDSs electronically, including back-up
systems to be used in the event of electronic equipment failure
• How employees can obtain access to them when they are in their work
area during the work shift
• Procedures to follow when the SDS is not received with the first
shipment
• For producers, procedures to update the SDS when new and
significant health information is found
• Description of alternatives to data sheets in the workplace, if
applicable

17. EMPLOYEE INFORMATION &
TRAINING PROGRAMS
Employers shall 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.

18. MINIMUM TRAINING TOPICS
• An overview of HazCom and its requirements
• The components of the hazard communication program in the employees’
workplaces
• Work areas where hazardous chemicals are present
• Where the employer keeps the written hazard evaluations, hazard communication
program, lists of hazardous chemicals and required SDS forms

19. TRAINING ELEMENTS
• How the hazard communication program is implemented
• How to read and interpret information on labels
• How employees can obtain and use available hazard information
• Location, use and interpretation of SDSs (including use of software if an electronic form
is used)
• The hazards of the chemicals in the work area and risks of exposure to them
• This includes the chemical and physical properties of the hazardous materials (i.e., flash
points, vapor pressures), as well as methods of detecting the presence of hazardous
substances, including detection of chemicals in unlabeled pipes

20. TRAINING ELEMENTS
• Measures employees can take to protect themselves from the hazards
• Specific procedures put into effect by the employer to provide protection, such as
engineering controls, work practices and the use, care and maintenance of
personal protective equipment (PPE)
• Methods and observations - such as visual appearance or smell - workers can use
to detect the presence of a hazardous chemical to which they may be exposed
• Physical signs and symptoms of exposure and which preexisting medical
conditions might be aggravated by exposure

21. COMMON TRAINING
DEFICIENCIES
• Training the wrong Employees
• Not covering the right subject matter
• Training too infrequently
• Training materials are ineffective

22. HELPFUL HINTS
• Keep reminding workers of the importance of safe work practices using department safety
meetings, a top-level safety committee and constant vigilance
• The most effective programs are ones where employees and their representatives participate in
all aspects of the program’s design and implementation.
• Safety and health information and instruction is more effective when incorporated into other
training about performance requirements and job practices, such as: management training on
performance evaluation, problem solving or managing change; supervisors’ training on the
reinforcement of good work practices and correction of poor ones; and employee training on
the operation of a particular machine
• Some means of verifying comprehension is essential, such as formal testing, oral questioning,
observation and other means

23. WRITTEN PROGRAM
COMPLIANCE
• Designation of person(s) responsible for training
• Format of the program to be used
• Elements of the training program
• Procedure to train new employees at the time of their
initial assignment to work with a hazardous chemical,
and to train employees when a new hazard is
introduced into the workplace
• Procedures to train new employees regarding new
hazards to which they may be exposed when working
on or near another employer’s worksite

24. RESOURCES
• OSHA (https://www.osha.gov/dsg/hazcom/)
• Association of Water Technologies, Inc. “Hazard Communication Standard:
Reference Guide for Water Treatment Companies.”
• Add me on LinkedIn (https://www.linkedin.com/in/marshalmiller52)
• You can also download it directly from SlideShare (bit.ly/dbiahazcom2017)