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March-April-2015

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28 PalletCentral • March-April 2015 palletcentral.com or as long as I can remember, OSHA's Hazard Communication Standard (29 CFR 1910.1200) has been among OSHA's most-cited standards. For fiscal year 2014, it ranked number two out of the hundreds of OSHA standards and could be poised to top the hit parade in 2015. Given that the standard has been around since 1986, although it was most recently updated in 2012, one might wonder why employers are still not "getting it right" when it comes to HazCom compliance. One answer is that this is a very paperwork-intensive standard. The employer must have a written hazard communication program, it must retain (or have immediate electronic access to) Safety Data Sheets for each individual chemical product on site (e.g., if multiple brands of paints are kept in the workplace, a SDS for each brand and color must be retained), a chemical inventory list must be developed and updated every time a new chemical product is brought into the workplace, legible labels must be in place on every chemical product container, and employee training must be documented. If an employer cannot come up with the right document when OSHA requests it, a citation will be issued. Another reason is that employee training is a key component of the standard and employers either do not properly provide the training and document that training was given, or else employees (when questioned privately by OSHA) are unable to give the proper responses to questions about the hazardous nature of the chemicals that they use or to which they are exposed in the workplace. In 2012, OSHA updated its HazCom standard to incorporate elements of the Global Harmonization System (GHS), which seeks to bring United States chemical labeling and warning systems into conformity with the rest of the industrialized world. In fact, the U.S. lagged behind in adopting GHS; we were preceded by the European Union, many Asian countries and even some South American nations. When the rule was finally adopted, it required retraining of every OSHA-regulated employee in America by December 1, 2013! Yet many employers have been slow to come into compliance, or do not provide thorough training in a language that employees can understand, and this contributed to the rise in HazCom citations last year. While labels must be in English, they can also be in other languages that are used in the workplace. If work-related instructions are given to workers in a language other than English, then HazCom training must also be given in the workers' native tongue. Among the things that employees must be trained on are how to read a Safety Data Sheet (SDS), what each of the newly adopted "pictograms" means in terms of worker health, what first aid and emergency response is required in the event of an incident involving a chemical in the workplace, and what personal protective equipment must be used by the worker when handling or being exposed to the chemical. Does OSHA use "gotcha" questions when talking about HazCom with employees? It is possible, but more often they will ask "were you trained on what [a specific pictogram] means …what will happen if you misuse the product … what health effects could you suffer from overexposure … what PPE do you need to wear … where do you find the SDS for the product, what should you do if this splashes in your eyes or gets on your skin …" and so on. When employees have language barriers with the inspector, too often OSHA assumes that they did not get properly trained, and enforcement action follows. Sometimes employees think they are "in trouble" with OSHA for using a product the wrong way and so will deny ever having been trained. In such cases, OSHA HazCom Enforcement, Let's Get it Right By Adele L. Abrams, Esq., CMSP SAFETY F

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