Last week we discussed OSHA and Hazard Communication.
This week we are going to discuss Step 1 and Step 2 for creating a Hazard Communication program.
Step 1) Learn the Standard and Identify Responsible Staff for Oversight
Hazard communication must be a continuing program, compliance is not a “one shot deal” and then you are done. Responsibility for coordination of initial and ongoing activities will have to be assigned to responsible staff, this could be one person or several persons can split these responsibilities. So, who is your Program Coordinator?
Note, while the coordinator is responsible for overall compliance, they may not be the best person to complete all of the activities, for example training may require expertise the coordinator does not have.
Step 2) Prepare and Implement a Written Hazard Communication Program
The program must describe how the employer will manage:
- Labels and other forms of warnings
- Safety Data Sheets or SDSs
- And employee information and training
Also, the program must include:
- A list of hazardous chemicals, known to be present in the workplace
- How an employer will inform workers of new hazards outside of their normal work routine
- And how to interact and communicate with other employers about SDSs, safety and labeling when working on multi-employer worksites, like a construction jobsite
If OSHA comes a callin, the compliance officer will ask to see your written plan, make sure you are ready!
You can find a sample written program for Hazard Communication at OSHA’s website www.osha.gov/Publications/osha3186.pdf and additional product stewardship guidance related to Hazard Communications is available at spraypolyurethane.org.
Stay tuned next week as we discuss Step 3 of creating a hazard communication program.
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