What is a Hazardous Chemical? Well under the Occupational Safety and Health Act (OSHA) it sort of depends.There are listed chemicals that are deemed to be “always hazardous” and then there are “highly hazardous chemicals.” However, OSHA also places the burden on each employer to analyze and determine if the chemicals you are using have hazardous traits, despite not being on one of the hazard lists.
As of June 1, 2016, all employers are subject to the new Hazard Communication (HazCom) standard, which mandates that your facility do several thing:
Label, all your chemicals with safety, personal protective equipment (PPE), and other required information. This includes everything from bulk chemicals delivered in 55 gallon drums to the small 6 oz. applicator that your employee uses at their work station. This requires you to have a complete chemical inventory of every chemical your business uses, with very limited exception.
Maintain, Safety Data Sheets (SDSs) for every chemical you in your facility. The SDSs must be kept in a location where employees are aware and have unfettered access during all working hours.The SDSs must also be kept up to date.It is the responsibility of the Chemical Manufacturer to make available a new SDS if the formulation changes. However, it is your responsibility to make sure you reach out and get a copy of that new SDS.
Train, your employees in all the required HazCom materials.You should have completed training your employees in the new materials by December 1, 2013. This training should have included: (1) how to read an SDS; (2) how to know what PPE is required or recommended; (3) how to interpret warning labels and pictograms; (4) all other required information under OSHA’s HazCom standard.
Here at Prince Law Offices, P.C., we have the expertise to provide your business with an OSHA Safety Solution for HazCom. We can perform your Chemical Inventory, Develop proper labeling procedures, and Train your employees. If desired we can even write your HazCom and Hazardous Waste Programs.