Hazardous Chemical Communication

Hazardous chemicals and worker right-to-know

OSHA has estimated that more than 32 million workers are exposed to 650,000 hazardous chemical products in more than 3 million American workplaces. This poses a serious problem for exposed workers and their employers.

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Employers need to communicate the following information to their employees:

What Are Hazardous Chemicals?

Many products used at work contain hazardous ingredients including "household" products.

"Hazardous Chemical" is a term that is broadly used in the hazard communication rule. A hazardous chemical includes things like solvents, glues, or paints, but the term is also applied to products that may release a hazardous chemical.

Table 1. Examples of products that may be considered a hazardous chemical

Product Hazardous chemical released
Bricks, Masonry and Concrete Silica - damages the lungs and causes cancer
Wood Saw dust - many common species of wood can cause cancer
Textiles Many textiles with "permanent press" sizing can off-gas formaldehyde in significant quantities

Generally if an item is regulated by another federal rule it is not covered by hazard communication. The following list presents items that may be exempted from the rule; please see WAC 296-800-17055 for the specific exemptions.

  • Consumer Products
  • Hazardous Wastes
  • Tobacco or tobacco products
  • Wood or wood products (unless they will be worked with in a way that will generate dusts or they have been treated with hazardous chemicals).
  • Articles (items with a specific shape with an end function that depends on the shape and do not release more than minute amounts of hazardous chemicals)
  • Food
  • Drugs
  • Cosmetics
  • Radiation (ionizing and non-ionizing)
  • Biological Hazards

Training and Information

Online Course: Overview of Hazard Communication

Working Safely with Hazardous Chemicals

Employees must be trained on how to work safely with hazardous chemicals. This includes the things you have done to protect employees including:

  • Engineering controls, such as exhaust ventilation.
  • Work practices
  • Emergency Procedures
  • Personal Protective equipment, such as splash resistant goggles, gloves or chemical resistant clothing.
  • The labeling system you use to quickly tell workers about the chemical, physical and health hazards of the compound.
  • How to find information on the hazards in the material safety data sheet or label.

Recognizing Releases and Over-exposures

Employees must be trained on the methods used to detect the presence or release of hazardous chemicals in the work area. Some examples of these methods can include:

  • Air monitoring such as personal exposure monitoring conducted by your company.
  • Continuous monitoring devices, these monitors may be connected to alarms.
  • The visual appearance or odor of the hazardous chemical
  • The physical and health hazards of the hazardous chemical; including the likely symptoms from an over-exposure.

Information found in a Material Safety Data Sheet .

The following items must appear on a material safety data sheet:

  • The product name or chemical identity used on the product lanbel.
  • Name, address and phone number for hazard and emergency information.
  • The chemical and common name of hazardous ingredients
  • The WISHA or OSHA permissible exposure limits (PEL) or if no PEL is established for the compound other exposure limits such as the threshold limit value (TLV) established by the American Conference of Governmental Industrial Hygienists (ACGIH) or the recommended exposure level (REL) established by the National Institute for Occupational Safety and Health (NIOSH).
  • Physical and chemical characteristics such as vapor pressure or flash point.
  • Physical hazards including the potential for fire or explosion and the reactivity of the chemical
  • Primary routes of entry into the body, such as inhalation, skin contact, or ingestion.
  • Short and Long term (acute and chronic) health hazards including signs and symptoms of overexposure and medical conditions aggravated by exposure to the chemical
  • If the chemical is cancer causing
  • Emergency and First aid procedures
  • Precautions for safe handling and use
  • Exposure control measures such as engineering controls, work practices and personal protective equipment.

Hazard Communication Program

Most workplaces will be required to develop a written hazard communication program. This written program describes how the required information will be gathered and how it will be passed along to workers. The written program must also cover employee training.

This link will take you to a sample Hazard Communication Program

To set up a program:

  1. Identify which chemical products are "hazardous" and make a list of these products.
  2. Get and keep current MSDSs for each product on the list.
  3. Ensure that workers can access the MSDSs easily and without delay in their work area.
  4. Make sure all in-house portable, stationary and shipped containers have labels.
  5. Develop a written hazard communication program and keep it available.
  6. Inform and train workers.
  7. Plan on sharing your chemical product information with visiting contractors' workers (e.g., construction, cleaning services, etc.) when these workers can also be exposed while working on your job-site. In addition, obtain information on their chemicals for your workers when necessary.
  8. Plan to inform visiting contractors' workers about any emergency or routine precautionary measures to take while in your workplace.

Rules and Laws covering Hazard Communication 

Hazard communication is covered by two separate rules in Washington State. Everyone using products with hazardous ingredients needs to follow the Core Rule on Hazard Communication.

  • WAC 296-800-170 Core Rule - Employer Chemical Hazard Communication
  • WAC 296-839 - This rule describes what must go into a Material Safety Data Sheet and how they are distributed to workers. For companies manufacturing, importing or distributing chemicals in Washington State.
  • WAC 296-307 - Agricultural operations

The hazard communication core rule does not require hazard evaluations, or hazard controls. The rule ensures that information about chemicals is passed along to workers, other rules cover how to control exposures.

Washington's Regional Directive on Hazard Communication contains enforcement policy and interpretations related to the HCS standard. This document will give you an idea of what inspectors will be looking at when they evaluate your program for compliance with the rule.

Additional Resources 

Additional Links

View copies of sample MSDSs:

OSHA's Web Site (Letters of Interpretation on Hazard Communication)   Note: Type "Hazard Communication" in the search box on this page.

 

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