Tackling OSHA’s Top 10 Citations: 1910.1200 - Hazard Communication
The following is an excerpt from Tackle OSHA’s Top 10.
Hosted by Chief Safety Officer Jill James, you can listen to the webcast on-demand.
Hazard communication is all about informing employees about the type of hazardous substances that they work with. As a former regulator, things that I would be looking for would be labels. Is all of the chemicals that an employee works with, are they labeled properly, so we know what it is?
In this particular picture, I'd be wondering what that jug on the bottom shelf was, and I'd be turning around some of those chemicals, to see if they were labeled properly. I'd also be looking for any kind of bottle that might be used to dispense into a smaller container, and if that's labeled, particularly if maybe it was a food bottle. I guess I could tell you that I can safely say that there are lots of times I saw Mountain Dew bottles that had chemicals in them, so think about the confusion if you're not in that work area, or maybe you're a new employee not understanding that maybe there's something that's dangerous in what was intended for food. So looking for labels on chemicals is definitely something to look for.
Then, a standard question an investigator will ask you is, "Let me see your Safety Data Sheets (SDSs)," and, "Do your employees have access to them? Are they readily accessible?"
So for those of you who are keeping them electronically, know that that's a perfectly fine way to keep your SDSs, as long as your employees have access to them in an electronic format, quick access. So if you think about it this way, if someone has come in contact with a chemical, and is needing medical treatment, emergency medical treatment, maybe it was something that got into their eye, or onto their skin, or maybe it's a medication, in the case of like a vaccine. I worked in the poultry industry for a number of years, and sometimes, a work injury would occur where an employee was inadvertently stuck with a vaccine that was intended for an animal, and we had to have SDSs on those vaccines, and that vaccine SDS needed to quickly accompany the employee to the physician, so they knew how to treat it.
So when you think about quick access, think about if you're using them electronically, can your employees access them? Even if they're in a paper binder, is it behind lock and key, or do employees have access when they need it, particularly in the case of an emergency?
Then some other hazards to consider, that my eyes would be looking for, with regard to chemicals, would be how are they being stored? You know, there's certain limits as to how many hazardous substances can be stored in one area, based on their flammability, and how much of a particular quantity there is.
Then, if they're stored next to anything that's incompatible, or on access points to exits, you want to make sure that we're not creating a greater hazard by storing chemicals somewhere that if you're having a fire, that it's going to compound, or the ability with people to exit a building safety.
Then, whether or not employees have the right personal protective equipment, to be using when they're using. Let's say it's a cryogenic. You know, do they have a cryogenic glove that they're wearing, so that they don't get a thermal burn? Or, is it a particular chemical that requires a neoprene glove, and a standard latex glove isn't going to work? Those are things that are addressed in the SDSs, but those are common questions that investigators will be asking, as well as your insurance auditors, would be asking those kind of questions as well. And I did mention food container use for dispensing chemicals, and really, that's not a best practice that should be used at all.
Is hazard communication training required under the federal OSHA law called Hazard Communication? Yes, it is, so that's something that you ought to be doing training on, if your employees have exposure to hazardous substances.