This article started by mentioning the written program and discussing the various examples of chemicals workers may encounter because the second, and often confusing, requirement of the HAZCOM standard is to have an inventory of ALL chemicals available on jobsites and in fabrication shops. In addition, each chemical in your inventory must have a matching Safety Data Sheet (SDS). Formerly known as Material Safety Data Sheets, SDS provide very specific information on the chemical / product, and they must be available for workers on all shifts, especially emergency response. Maintaining the inventory and corresponding SDS can be a challenge for many companies, but it is important because it helps to ensure the chemicals being used are accounted for and proper use / disposal training is provided. Also, OSHA inspectors will review documentation of these requirements as part of an OSHA inspection / investigation. The inspector may identify a chemical in use and ask to see that the chemical is in the inventory and review the appropriate SDS.

Two items to consider including in a HAZCOM program are multi-employer worksites and non-routine tasks. On multi-employer worksites, you should consider the possibility of “cross-exposure” whereby your employees could be exposed to chemicals used by other contractors (or other contractor workers exposed to chemicals your firm uses). One example of this is cutting or grinding concrete which can create silica dust plumes, potentially exposing all workers in the area. Non-routine tasks that can create unique chemical exposure issues to consider are working in confined spaces including pipes and ductwork, fiber reinforced polymer (FRP) bonding, and working near asbestos-containing materials.

A HAZCOM program must also include labeling of containers. The HAZCOM standard was revised in 2012 to adhere to Global Harmonization System guidelines. In general, this revised requirement states that all chemicals must be properly labeled with the following:

1. Chemical Identity;
2. Applicable Pictograms;
3. Applicable Hazard Signal Word;
4. Applicable Hazard Statement; and
5. Name and address of the chemical manufacturer, importer, or other
   responsible party.

The use of pictograms was a welcome addition due to varied languages and reading / comprehension levels of workers in the United States. Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import and prepare labels and safety data sheets to convey the hazard information to their customers. However, your company must comply with “secondary” container requirements if the chemicals are used or stored in smaller containers. This can be tricky so be sure you understand the rules as they apply to labeling and use of “downstream” chemicals.

The final part of HAZCOM compliance is providing adequate information and training. To quote from OSHA, “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. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals.”

There are companies in the marketplace that provide HAZCOM assistance including specializing in HAZCOM inventory / SDS compliance. In addition, Federal OSHA has several good resources at their HAZCOM web page: Hazard Communication - Overview | Occupational Safety and Health Administration (osha.gov). Specifically, OSHA publication OSHA3695.pdf is the Hazard Communication Small Entity Compliance Guide for Employers that Use Hazardous Chemicals.