Roles, training and the written HazCom program

HazCom works only when everyone involved does their part: manufacturers and importers provide accurate labels and SDSs, employers create the conditions for safe work and train employees, and employees apply what they learn and speak up. This final lesson brings the course together. It explains the duties of manufacturers, importers, distributors, employers, supervisors and employees; what training must include and when it must be provided; how to write and maintain a hazard communication program, including the chemical inventory, labeling, SDS management, non-routine tasks and contractors; the role of safety committees; inspections and continuous improvement; and the capstone project.

Duties of suppliers

Chemical manufacturers and importers must classify each chemical they produce or import according to the HCS appendices, prepare compliant labels and SDSs, provide them with shipments to downstream users, and update them when significant new information becomes available (within three months for SDSs and six months for labels). Distributors must ensure that labels and SDSs are passed on to customers.

Duties of employers

Employers must develop, implement and maintain a written hazard communication program; keep a list of the hazardous chemicals known to be present; ensure containers are labeled; keep SDSs readily accessible during each work shift; provide information and training at the time of an employee's initial assignment and whenever a new chemical hazard is introduced; inform employees of operations where hazardous chemicals are present and of the program's location; and control exposures according to other OSHA standards.

Duties of supervisors and workers

Supervisors translate the program into daily practice: making sure workers have been trained on the products they use, enforcing safe procedures and PPE use, checking that containers are labeled and SDSs are available, responding to reports, and setting an example. Workers must take part in education and training, follow safe work procedures, use controls and PPE properly, not remove or deface labels, report hazards such as missing labels, damaged containers, leaks and symptoms, and ask questions when unsure. Workers also have the right to refuse work they believe is dangerous, under the procedures of their jurisdiction, and must not face reprisal for raising safety concerns.

What training must include

OSHA requires that training cover: the requirements of the HCS; operations in the employee's work area where hazardous chemicals are present; the location and availability of the written program, the chemical list and SDSs; methods and observations used to detect the presence or release of hazardous chemicals, such as monitoring and visual appearance or odor; the physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards and HNOC of chemicals in the work area; measures employees can take to protect themselves, including work practices, emergency procedures and PPE; and the details of the program, including the labeling system, the SDS and how employees can obtain and use the information. Training must be in a manner and language employees understand. OSHA does not require a specific frequency, but training is needed at initial assignment and when new hazards are introduced, and many employers refresh it annually. Keeping training records is good practice.

The written hazard communication program

The written program must describe how the employer will meet the requirements for labels and other forms of warning, SDSs and employee information and training, and must include a list of hazardous chemicals known to be present, using the product identifiers on the SDSs. It must also describe the methods the employer will use to inform employees of the hazards of non-routine tasks, such as cleaning tanks, and of chemicals in unlabeled pipes; and, in multi-employer workplaces, how the employer will share SDS access, precautionary measures and labeling information with contractors and other employers. A typical program includes:

• Responsibilities: who manages the program, maintains SDSs, provides training and inspects.
• Chemical inventory: a list of every hazardous product by location, with links to SDSs.
• Purchasing and receiving controls: approval of new products, checking for safer alternatives, and confirming that labels and SDSs arrive with products.
• Labeling procedures: supplier label checks, workplace labels, decanting rules, pipes and vessels.
• SDS management: how SDSs are obtained, updated, stored and accessed.
• Education and training: content, delivery, verification and records.
• Exposure control and emergency procedures linked to the hazards.
• Contractors and visitors: how hazard information is shared.
• Inspection, audit and review schedule.

Participation and committees

Safety committees, required in some states and common in many workplaces, often take part in hazard communication by reviewing the program, participating in inspections and raising concerns from employees. Employees have the right to file a complaint with OSHA about hazards, and OSHA's whistleblower protections prohibit retaliation for reporting safety concerns.

Inspections and continuous improvement

Regular inspections keep a hazard communication program working. A simple inspection checklist might include: Are all containers labeled and labels legible? Are SDSs available and current for every product in the inventory? Are new products appearing that are not in the inventory? Are incompatible products segregated? Are spill kits, eyewash stations and safety showers in place and tested? Do workers know where to find SDSs and how to use them? Can workers explain the hazards of the products they use? Findings should be recorded, assigned and corrected, and trends reviewed. Incidents and near misses involving hazardous products, such as spills, exposures and mislabeled containers, should be investigated to find root causes and improve the program.

Capstone project

The capstone asks you to apply the course to a real or realistic workplace area, such as a maintenance shop, a cleaning cupboard, a laboratory bench, a print room or a warehouse aisle. Your project should include:

• A chemical inventory of at least ten hazardous products, with product identifiers, locations, quantities and SDS revision dates.
• For three of the products, a one-page hazard summary drawn from the label and SDS: classification, pictograms, signal word, key hazard and precautionary statements, PPE, storage requirements, incompatibilities and first aid.
• A storage and segregation plan for the area, using SDS section 10.
• A workplace label you design for one decanted product, meeting your jurisdiction's requirements.
• A short spill response procedure for one of the products.
• An inspection checklist for the area, completed once, with corrective actions.
• A brief reflection, of about 300 words, on the most important improvements you identified.

Discuss your findings with your supervisor or safety committee, since real hazards you identify should be corrected.

Contractors, visitors and shared workplaces

Many workplaces host contractors, temporary workers and visitors who may encounter hazardous products. Before work begins, the host employer should tell contractors about the hazardous products in their work areas, provide access to SDSs, explain labeling systems and emergency procedures, and coordinate on products that contractors bring with them, which must also be labeled and have SDSs available. Temporary agency workers must receive education and training on the products they work with, with the host and the agency clarifying responsibilities. In shared workplaces, such as construction sites and multi-tenant buildings, coordination between employers is essential.

Non-routine tasks

Non-routine tasks, such as cleaning tanks, maintenance on process equipment, responding to unusual spills or working with a product for the first time, often carry greater hazards than everyday work, and the usual procedures may not apply. Before such tasks, supervisors should review the SDSs of the products involved, consider residues and by-products, plan controls, PPE and emergency arrangements, and brief the workers. Permits, such as confined space and hot work permits, often apply. Many serious chemical incidents occur during non-routine tasks.

Measuring program performance

Organizations can track indicators to see whether hazard communication is working: the percentage of products with current SDSs, the number of unlabeled containers found in inspections, training completion and verification rates, the number of chemical incidents and near misses, results of exposure monitoring, and worker feedback. Indicators help focus effort where it is most needed and show improvement over time.

Your role in a culture of hazard communication

Hazard communication is ultimately about culture as much as rules. In workplaces with a strong safety culture, workers read labels as a matter of habit, ask questions about unfamiliar products, remind colleagues when containers are unlabeled, and report problems without fear. Supervisors respond to reports quickly and treat them as useful information rather than complaints. Managers invest in safer products, good ventilation and effective training. You contribute to this culture every time you read a label before using a product, check the SDS for an unfamiliar task, label a container you fill, or speak up about a hazard.

Keeping your knowledge current

Products, rules and knowledge change. Keep your hazard communication knowledge current by attending refresher training, reading updated SDSs, following notices from your employer and regulator, and asking about new products before using them. If you change jobs or workplaces, expect new products and procedures, and make sure you receive workplace-specific training before starting work with hazardous products.

Course review

Over the course, you have learned why hazard communication matters and how the GHS and national laws structure it; how physical and health hazards are classified; how to read pictograms, signal words and statements on labels; how supplier and workplace labels work; how to find and use information on SDSs; how exposure is controlled; how to handle, store and respond to hazardous products; and how roles, training and programs fit together. Combined with your employer's workplace-specific training, this knowledge will help you protect yourself and others.

Questions to ask on your first day with a new product

When you are asked to use a product for the first time, ask: What is it, and where is its SDS? What are its main hazards? What controls and PPE do I need? How should I store it and dispose of it? What should I do if it spills or if I am exposed? Who can I ask if I have questions? If you cannot get answers, do not start the work until you do. These questions put the right to know into practice every day.

Final reminder

This course is an awareness-level course. It does not replace workplace-specific training on your employer's products and procedures, or any certified training required for your job. Use it as a foundation, and build on it with the training, procedures and supervision your workplace provides.

Where to go for help

If you have questions about a product, start with the label and SDS, then ask your supervisor, your joint health and safety committee or safety representative, or your safety department. Regulators and organizations such as occupational health and safety agencies and poison centers also provide reliable information.