Employers Must Update their Written Haz-Com Program ASAP!
May 1, 2016 - When OSHA updated their Hazard Communication (aka Haz-Com) standard back in 2012, many employers jumped into action so they could meet the mandatory deadline for training their employees about the new GHS criteria for labeling containers and Safety Data Sheets (SDS). And most employers have been assembling the new SDS’s that are issued by product manufacturers and distributors. And hopefully everyone has updated their in-house container labeling systems to reflect the requirements in the updated Haz-Com standard. But there is one more deadline that employers have hanging over their heads, and it’s coming up VERY soon.
OSHA has given employers a deadline of June 1, 2016 to update their Written Hazard Communication program so that it reflects all the revisions and addition spelled out in OSHA’s updated Haz-Com standard. That means that the sections in your existing written Haz-Com programs that address 1) container labeling, 2) Safety Data Sheets, and 3) employee training will have to be re-written to reflect the requirements for new or updated requirements that are spelled out in the standard. It will also be an opportunity for employers to make sure their entire written program is up-to-date, as it is not uncommon during mock-OSHA audits for me to find written Haz-Com programs with references to information that has been out of date for years!
You know I am not the type to bring up a problem without trying to suggest or even offer a solution. You may even be aware that we provided free toolbox talks on GHS on our website, as well as two free online training tutorials on understanding GHS labeling requirements and how to read an SDS (almost half a million views combined). So we also want to help employers in need to meet this latest requirement too. OSHA provided a sample written program (hard copy) of an updated written Haz-Com program in their small employer GHS / Haz-Com compliance guide. So we took that sample written program, tweaked it to take care of a few minor errors, and then converted it into a Word document that you can download, save, and then modify as necessary to make it specific to your company or organization. Afterwards, you should have an up-to-date, compliant, and site-specific written Haz-Com program (CLICK HERE to go to our GHS Resources page that has a link to download that free document).
While we are on the topic, here are a few things you should keep in mind about OSHA requirements for written Haz-Com programs. First, if you are an organization with multiple fixed sites (such as a manufacturer or restaurant with several locations), make sure you develop a written HazCom program for each site – and make sure it is site-specific. Nothing looks worse than a generic program that only makes general references to the info needed to be provided for each individual site (such as the location of SDSs . . .). Also, MAKE SURE you remember to develop a written inventory of all hazardous products present at each site. The sample program we provided makes reference to this list, so do not overlook the requirement to assemble the list for your site(s). And last but not least, remember that a written Haz-Com program is a living document. If something changes at your site (e.g.: relocate your SDS binder; change the name or title of the person listed as responsible for training; gathering and maintaining SDSs . . . ), make sure to update your written program right away to reflect current conditions.
Won’t it be nice to have all the new (and old) elements of your Hazard Communication program up-to-date? Then you can start worrying about the next big thing OSHA has in the works, which is . . . going to be covered in a later Blog post.
Do you have any comment or advice for those who readers who need to get their Haz-Com program up-to-date? Or perhaps you have a question? If so, I would like to encourage you post that information in the COMMENTS section of this post. And as always, Please Share this Blog post with Others in your Network who might be affected by this topic.
ABOUT THE AUTHOR:Curtis Chambers is a Certified Safety Professional (CSP) and holds a Master of Science degree in Occupational Safety and Health. He has held numerous leadership positions managing and evaluating health and safety programs and providing training on workplace safety and health topics at various public organizations and private corporations. Mr. Chambers is currently the President of OSHA Training Services Inc. Visit their website at www.oshatraining.com.