Writing out a hazcom plan to protect employees

What part of the hazard communication standard do employers most often violate?

Answered by Shane Austin, CSP, director of safety and risk management, PureSafety, Franklin, TN.

Few safety professionals will be surprised to hear that the hazard communication standard is one of the top five most violated regulations every year. In 2009, OSHA reported that it cited more than 6,300 hazcom violations. One reason is that hazcom is so broad in scope and applies to practically every work environment.

The standard covers five major areas:

  1. Hazard determination
  2. Developing a written program
  3. Having Material Safety Data Sheets on hand
  4. Labeling
  5. Training
Most companies fail from the start by not having a written program. This is similar to a chef not having a recipe for a complex dish – he or she will most likely forget some key ingredients. And if the chef is not around, how will others know what to do? A properly written and implemented hazcom program establishes the recipe your company will use to acquire MSDSs, identify specific hazards, use proper labeling techniques and train those impacted. Some people, especially in small to midsize companies, are intimidated by the task of developing a written program, but there are many resources at www.osha.gov and other Websites that simplify the work by providing a basic template to follow.

With a written program implemented, you will find it much easier to acquire MSDSs and appropriately label chemicals. The next hurdle is managing training, which accounts for one-quarter of all hazcom violations. Most organizations have good intentions, but there are real challenges to making sure that consistent, annual training is completed by all employees. Most companies still heavily rely on a manual approach, requiring supervisors and safety committees to invest large amounts of time and resources to train and track everyone. However, a growing number of companies have implemented Web-based training programs, leveraging technology to more efficiently and effectively meet training delivery, tracking, and reporting needs. Web-based training can help meet another training challenge: verifying that employees actually understand the training topic through testing and surveying. Testing and surveying also help gauge the impact of training, so you can adjust as needed.

Starting with an up-to-date written program and providing clear training documentation will go a long way toward providing your company a recipe for success in meeting hazcom compliance – and, more important, in preventing incidents and injuries.

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