OSHA’s Hazard Communication standard has been around since the early 1980s and has had a few updates since then including the 2012 adoption of the global harmonization standard to make handling chemicals easier to understand. Yet, Hazard Communication continues to be a top 10 violation for OSHA. In fact, it continues to be a top 5 violation.

So, why is this? What are companies doing wrong? And what can our industry do to ensure that if OSHA comes on site, we don’t find ourselves in the crosshairs of an OSHA inspector? This could be a costly mistake on our parts if we are not ready for them. As of Jan. 15, 2022, the maximum penalty for a serious violation is $14,502 and for a willful violation the maximum penalty is $145,027. 

The four most common HazCom violations are the lack of or inadequate written program, lack of training or inadequate training, not maintaining a safety data sheet for chemicals on site and labeling. If you do the math, it can get expensive as each violation will have a separate penalty. 

The first thing any company should do is ensure that they have a well written and adequate program that addresses all aspects of your hazard communication needs. The program must cover all employees who are exposed to hazardous substances in the workplace. The program must also include information for labeling, safety data sheets, warnings and training. Employees also must have access to the written program either in print or digital form. 

When it comes to training it is imperative that employees understand the hazards they are encountering and how to read and understand labels. They must know where the safety data sheets are located and how to read them so that they can be prepared to protect themselves against the hazards. Employees must also be trained before they work with hazardous substances. Lastly, employees need to know the company’s labeling system.

Therefore, it is important to maintain those safety data sheets. Each hazardous substance must have an SDS on site and available to every employee. If you have multiple sites, an SDS for any hazardous substances must be on each site. Employers must ensure that any hazardous substances must be accompanied by an SDS, and employees are made aware of the arrival of the substance and the SDS is available to them.

Lastly, the labels on all hazardous substances must be legible and prominently displayed. Labels must be printed in English and in any other language that employees may speak. If you are going to pour a hazardous substance into an unlabeled container, you must use it all up and it cannot leave the sight of the employee otherwise you will have to include at least the following on the label: the chemical name, manufacturer’s name, PPE required, any hazards and a signal word such as “danger” or “warning.”

Take the time to ensure that you follow OSHA’s Hazard Communication standards before they show up on your site. This might seem like a big undertaking, but in the long run, it could save you thousands in penalties and court costs.