How to Create a HazCom Program

It may not be the most visible workplace hazard, but an effective chemical hazard communication program is essential for workplace safety and Occupational Safety and Health Administration (OSHA) compliance. Hazard Communication — or Hazcom — was the second most cited OSHA violation in 2022, and neglecting your hazardous communication program could result in costly penalties and reputational damage.

Understanding how to create a HazCom program for your business requires a methodical approach to meet all the requirements and prioritize workplace safety.

What Is a HazCom Program?

A hazardous communication program, or HazCom program, aims to protect workers from the injuries and illnesses associated with hazardous chemical exposure. Aligned with the OSHA hazardous communication standard, a HazCom program is based on the premise that workers have the right to know and understand the chemicals they work with and the potential hazards associated with those chemicals.

OSHA mandates the hazard communication system your organization uses and provides safety professionals and business owners written guidelines detailing what information and training they must provide their employees. OSHA’s HazCom standard requires companies to have a written hazard communication program and fulfill other related criteria.

Why Is Creating an Effective HazCom Program Important?

HazCom programs exist to prioritize worker safety by providing training and information to all employees who work with hazardous chemicals. Employers and safety managers are responsible for complying with OSHA regulations with a clearly written, comprehensive hazard communication program. It’s a detailed document outlining all the hazardous materials in an area, safety data sheets (SDSs), container labeling protocols, and employee training.

An effective hazard communication program provides workers with date information on evaluating chemical hazards and details of correct handling, personal protective equipment (PPE), and emergency procedures. HazCom protocols and written workers keep workers safe, and OSHA takes violations seriously. Maintaining OSHA compliance is critical to avoid willful and repeated violation penalties of over $150,000 per violation.

How to Create a HazCom Program for Your Organization

OSHA outlines detailed guidelines to help organizations create compliant and effective HazCom programs. Following the recommended steps is essential to provide your workforce with a chemical hazard communication program that ensures their understanding of hazardous chemicals so they can keep themselves safe. The six main steps to creating a HazCom program include the following:

1. Familiarize Yourself with the HazCom Standard and Choose Responsible Staff

Understanding the provisions of OSHA’s HazCom standard is essential to create a program that works for your organization. Although it’s a comprehensive document, OSHA recommends paying specific attention to the following areas:

  • Paragraph E: Written hazard communication program.
  • Paragraph F: Labels and other forms of warning.
  • Paragraph G: Safety data sheets.
  • Paragraph H: Employee information and training.

Maintaining compliance with your HazCom program requires attention to detail. OSHA recommends identifying one person to oversee your hazard communication, act as a point of contact, and create a team to perform duties such as managing the HazCom program, enforcing safety standards, and meeting training criteria.

2. Prepare and Implement a Written Hazard Communication Program

A written plan detailing how you will address hazard communication is essential. OSHA maintains a written program that helps organizations systematically approach hazard communication, providing employees with easy access to hazard information. Your written HazCom plan must contain all the details on how you plan to handle hazard communication in your facility, including labeling information, SDSs, and safety training information.

One of the most critical elements of an effective HazCom plan is a detailed list of all hazardous chemicals your employees could come into contact with within the workplace.

One of the most critical elements of an effective HazCom plan is a detailed list of all hazardous chemicals your employees could come into contact with within the workplace. This list should be updated continuously as chemicals in the workplace are added or removed. Consider using a database software that will alert you if you add new chemicals to the environment so you can ensure your employees receive the proper training.

Start by writing your HazCom plan and discussing it with your responsible person. Ensure you include all the elements required by OSHA. From there, you can make the plan work in your specific environment. Once you have a workable written HazCom program, your delegated responsible person and their team must ensure you implement it consistently.

3. Label All Hazardous Chemical Containers

OSHA requires you to keep labels on shipped containers and replace them if they become unreadable. If your workplace involves container transfers or mixing chemicals in separate containers, you must ensure these workplace containers are labeled in line with OSHA standards. In simple terms, you can use container shipping labels, as chemical importers and manufacturers must provide all chemical information.

You can choose to label chemicals with labels different than what was provided by the manufacturer. Still, they must provide employees with all the relevant information to ensure their safety, including product identifiers, pictograms, and hazard information. You can engage a third party to print compliant workplace labels or do so in-house as long as they meet OSHA requirements.

4. Maintain Safety Data Sheets

Safety data sheets provide every member of your team with detailed information on a specific hazardous chemical. OSHA regulations require you to have SDSs for each hazardous chemical present in your workspace and ensure they’re accessible to all employees. You can choose how you make them accessible, although if you have significant numbers of chemicals, digital databases may be more accessible. However, printed and bound hard copies and backups are essential in case of a power outage.

Suppliers and manufacturers may send SDSs with shipments — the organization’s responsibility is to request SDSs for each chemical in your workplace if the manufacturer doesn’t include them. In addition to having safety data sheets available, you must keep them updated to provide your employees with the most updated information on chemical hazards.

5. Provide Your Employees with Training and Information

Your HazCom program should focus on employee safety, and you must train your employees on all hazardous chemicals in their work area before they start their first assignment. Additionally, if you introduce new hazardous substances in the work area, you must also train your employees on those chemicals. Your employees should also have access to the OSHA HazCom standard requirements, the potential hazards of the chemicals they work with, and know where and how to obtain chemical and safety information.

Employee HazCom training should include — but not be limited to — the following:

  • Understanding chemical labels and SDSs and where to find information on hazardous chemicals.
  • Knowing the protective measures in the workplace and how to complement these measures.
  • Having capabilities to act appropriately during chemical exposure, including knowing whom to contact in an emergency.

Employees should be comfortable working with hazardous chemicals and know where to access additional information if unsure or working on a new assignment. Encourage your employees to ask questions during training and emphasize the importance of training for their and others’ safety.

6. Evaluate and Reassess Your Program

As a safety manager, you must ensure your program meets its objectives. Review your program periodically to assess elements that meet your objectives and identify opportunities for improvement. There are always opportunities to make your workplace safer for employees. Revise your HazCom program as needed to accommodate changing workplace conditions, and consult with your team to gain further insight into areas you can improve.

Maintain Safety and Compliance in the Workplace with the National Association of Safety Professionals

Maintain Safety and Compliance in the Workplace with the National Association of Safety Professionals

An effective hazard communication program is integral to maintaining workplace safety and OSHA compliance. Ensuring your workers have the appropriate knowledge and training to address safety around hazardous chemicals proactively is a vital element in your HazCom program. The National Association of Safety Professionals (NASP) provides real-world training by safety professionals, for safety professionals to help your organization prioritize workplace safety and remain OSHA compliant.

We have a range of training courses and certifications to suit your needs. Consider an online hazard communication specialist certificate or our two-day train-the-trainer course to boost your safety and compliance. With NASP, you can rely on expert support long after you’ve completed your training. Please find the answers in our resource center or contact one of our professionals with any post-training questions.

Contact us today to learn more about the NASP practical approach to workplace safety.

Purchase Our Hazard Communication Specialist (HCS) Course

About the Author

Eric Gislason

Eric Gislason is the CEO and Executive Director of NASP. He is also one of the principal trainers, specializing in OSHA compliance and development of workplace safety culture. Eric has over 33 years of experience in the EHS field, having trained individuals from across the spectrum on OSHA/EPA compliance including manufacturing, oil and gas, construction, warehousing, healthcare, and retail.
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