Reviewed November 17, 2003

The Hazard Communication Standard (29 CFR Part 1910.1200 et al., a.k.a. Employee Right-to-Know law, HAZCOM, and HCS) is enforced by the Occupational Safety and Health Administration (OSHA). Its purpose is to provide employees with knowledge of hazards and identities of chemicals they are exposed to in the workplace, as well as measures to take to protect themselves. All employers must have an active HAZCOM program in place, or they will be subject to heavy fines for regulatory violations. The Standard itself is quite lengthy and complex, but its Appendix E "Guidelines for Employer Compliance" is very informative.

An acceptable HAZCOM program consists of three parts: Container Labeling, Material Safety Data Sheets, and Training. The program must be written. A brief description of each part is listed below.

1. Container Labeling – All containers used in the workplace must be clearly labeled with the product’s name and a hazard warning (if any). Manufacturers are required to have this on all containers sold. If you transfer the chemical to another container, it must be labeled or tagged to identify contents and hazards. Exception: It is permitted to transfer a chemical to an unlabeled portable container if it is used immediately by the employee who does the transfer.
   
   
2. Material Safety Data Sheets (MSDS) – Manufacturers are required to evaluate the hazard potential of their products and prepare MSDSs for distribution to users. The MSDS includes precautions for safe handling and use and emergency and first aid procedures. These MSDSs must be maintained at the work site. All employees must know where they are and have access to them. The only exception to this is for an employee who works at multiple work sites in a day. In this case, the MSDSs can be kept at a central work station, as long as there is a planned and effective means of communication for quick access by the employee.
   
   
3. Training – All employees must be trained for:
   1. Hazards of chemicals used. This can be done for each chemical, if there are just a few, or by hazard grouping, such as flammables, carcinogens, etc.
   2. Knowledge of the existence, purpose, and a general understanding of the Hazard Communication Standard.
   3. Location, details, and availability of your written program, MSDSs, and list of all hazardous chemicals used in the workplace.
   4. Detection of the presence or release of a hazardous chemical.
   5. Protective measures.

Written Hazard Communication Program – Employers must develop a written plan which includes information on labeling, warnings, MSDSs, training, methods of implementation, and a list of all hazardous chemical used.

Important Note: An acceptable Hazard Communication Program cannot be developed from this Overview, the purpose of which is to provide an awareness of the standard and how it affects your operation. Obtain copies of OSHA 3084 "Chemical Hazard Communication" and/or OSHA 3111 "Hazard Communication Guidelines for Compliance" at the links provided here, if you have Adobe® Acrobat® Reader software, or order them with the OSHA web site’s Publications Order Form, for guidance in developing your program.

Forest Resources Association Inc. 600 Jefferson Plaza, Suite 350, Rockville, Maryland 20852 Phone: (301) 838-9385     Fax: (301) 838-9481