Little-Known Facts for HazCom Managers

 

OSHA's hazard communications (HazCom) standard is intimidating, and it changes a lot. Due to efforts to align with international regulations, OSHA makes incremental changes to the standard that can make it hard to keep up with. There are also different aspects of the standard that apply to chemical manufacturers, importers, and employers, so it can be hard to know what might apply to you.

You may also think that if you're job title isn't "hazcom manager," then you're off the hook, but if you:

• Manage or update your company's SDS's, 
• Are in charge of purchasing, 
• Or work with chemicals in your workplace,

then you might just learn something important today. Here's a few aspects of HazCom that are maybe not talked about as much and you should be aware of.

1. SDS's should be kept for 30 years after the chemical or material is no longer in use. (See this OSHA letter of interpretation.)

This one can be a shocker to many, but because SDS's can be used as exposure records as well as an inventory of current materials in use, it's not the best idea to get rid of SDS's as soon as you stop using a product. As it turns out, they are a very effective way to record the hazards an employee was exposed to. 

There is technically an alternative to storing SDS's for that long, but it might be taking the hard way out: "Employers may discard [material] safety data sheets if some record identifying the substances used, where it was used and when it was used is retained for at least 30 years." In the long run, it's probably simpler to just keep the old SDS around.

2. There's a consumer use exception for SDS's, but it's not as useful as you may think.  

Do you need an SDS sheet for every single product in the workplace? Technically no. "OSHA does not require that [M]SDS be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience." Great! Get rid of that Windex SDS, stat! 

Except, of course, it's not usually that simple. Is the employee who generally uses Windex using it for the same duration and frequency as a general consumer? Or are they in a facilities maintenance position where they may be using it for many hours a week, much more than a general consumer? If so, an SDS must be kept on file.

The same goes for any product on site. If motor oil is on site, frequency and duration of the product must be considered. Is any one employee exposed more than a general consumer would be? If there's any room for doubt, it's SDS time.

However, that does leave employers off the hook for products that employees may bring into the workplace, such as lotion or hand sanitizer to keep by a desk, or products that genuinely are used in the same manner as a general consumer.

3. All it takes is one unlabelled container. HazCom is almost always one of the top cited OSHA standards, and it's a really easy one to violate. What does it take? One spray bottle without a label can land you a citation. Remember to label your containers, and while you're at it, you want to make sure it's a compliant label too. See example of all required label elements for hazardous chemicals below.

Are there exceptions? Sure, if you transfer a chemical to a portable container for immediate use, you don't need a label. But it might not be a great idea to make a habit of it.

Remember, all of these products may not be as mild or effect-free as you may think. The HazCom standard exists for a reason.... to keep you safe from what might be sneaky effects in the products that you use every day.