With OSHA assessing over $3 million in penalties in 2021 for Hazard Communications violations, it’s more important than ever to make sure your HazCom program is in tip-top shape. Although OSHA does not have formal requirements in place for re-assessing your hazard communication program, it’s still a best practice – and one that can be applied to most facets of your safety program.
Is Your HazCom Program Meeting its Objectives?
You want to periodically evaluate and reassess your hazard communication program to ensure it’s current and relevant for you and your employees. Key questions you’ll want to ask include:
- Does the program reflect the current hazards of your workplace?
- Are the Program Manager and other key roles assigned and working effectively?
- Are procedures adequate to maintain the program?
What’s Changed Conditions in Your Workplace?
Start with your chemicals.
Start with the list of hazardous chemicals maintained as part of your written program. Double-check that your process for maintaining your chemical inventory is functioning as you expected. Verify that:
- When you bring in a new hazardous chemical, add it to the chemical inventory
- If a chemical on the list is eliminated from your inventory, remove it from the list
Program managers should routinely walk around the workplace to check that containers are labeled as required and that employees follow established work practices to protect themselves from chemical exposure.
Next, move on to workplace hazards.
Are there new hazards that have developed since your last review? Proactive monitoring of the workplace is critical to ensuring compliance with the HCS.
Tips for Hazard Communication Program Spot Checks
- Check storage closets for chemical labeling, including janitor closets that may house chemicals that are not present in the rest of the facility.
- Review the documents to ensure signatures are current.
- Review training records to ensure employee training is completed.
- Check with the Program Manager to make sure the chemical inventory is up to date.
How KPA Helps Strengthen Your Hazard Communication Program
KPA is here to help you maintain a comprehensive Hazard Communication program.
HazCom Written Program
KPA’s expert EHS consultants will help you develop a written program that is tailored to your business. It will include everything OSHA looks for including:
- A list of all the chemicals present in your workplace
- How and where employees can access Safety Data Sheets
- Identify the individual designated as responsible for the oversight of your program
Hazard Communication Awareness Training
KPA also provides online and on-site Hazard Communication training. Courses for both employees and managers cover how information about hazardous materials is communicated in the workplace. They also include information about how to read hazard labels and safety data sheets as well as the importance of the written program and training.
SDS Management
Ensuring your employees have quick and easy access to Safety Data Sheets may be the most important component of your Hazard Communication program. With KPA EHS you have access to a database of over 70 million datasheets. You can create your own SDS folders and custom SDS library with an easy to search interface. You’ll also have offline access and hardcopies to ensure all your staff can easily find SDSs. Finally, you can print pre-populated secondary container labels for GHS compliance.
