Summary: The US Occupational Safety and Health Administration’s Hazard Communication Standard can be a good tool to ensure safe chemical usage by employees because it allows employers, cleaning and facility managers and workers the opportunity to take control of chemical safety in the cleaning workplace. Implementing a thorough hazard communication program as part of the standard is not a one-time act — it’s an everyday requirement for all cleaning operators.

By Wilbert L. Dawkins, Jr.

The Health Communication Standard (HCS) from the US Occupational Safety and Health Administration (OSHA) has been revised, most recently in March 1998, to simplify and clarify some of its original components.

Though the intent of the HCS was to promote chemical safety, its goal is not always met. Each year, HCS violations are frequently cited by OSHA officials following their workplace inspections.

The HCS (OSHA 1910.1200) originally took effect in 1983 to provide employees some measure of protection against chemical exposure. Its rationale is straightforward: Employees have a need and a right to know about the effects and possible hazards of chemicals they use as part of their cleaning maintenance duties.

The HCS established uniform requirements to ensure that chemicals and their potential effects on users are identified and recognized by employers — including cleaning and facility managers. Employers are responsible for delivering this information to their employees.

The HCS is designed to reduce worker injuries and illnessses caused by any hazardous chemicals, including cleaning chemicals. To be covered by the HCS, an employee must have potential exposure to the chemical.

Employer efforts to comply with the standard must address several areas.

Hazard determination

Chemical manufacturers and importers must perform hazard determinations for all of their chemicals. A determination must address physical and health hazards, potential exposure to chemicals by cleaning workers, and use of labels and material safety data sheets (MSDS) to convey potential hazards.

Employers and managers can conduct their own hazard evaluations for the cleaning chemicals used by their workers. The person performing the evaluation is responsible for the accuracy of the information. Employers who do not perform chemical hazard evaluations should state in a written hazard communication program (HCP) that they will rely on the evaluations of chemical manufacturers and importers.

If a manufacturer or importer discovers a new physical or health hazard for their chemicals, they must relay the information to their customer end-users within 90 days. Labels and MSDS also must be amended to reflect the new hazard.

Written program

Employers or managers whose employees are exposed to hazardous chemicals in the workplace must have a written HCP that addresses potential and actual chemical exposures. The written program should examine:

• Labels and forms of warning

• MSDS

• Employee training.

An HCP designates a person responsible for labeling chemical containers and describes the company or facility’s labeling system. It must explain procedures used to review and update chemical labels. The HCP should detail the system used to inventory and store all workplace chemicals.

It should designate the person responsible for obtaining and updating MSDS and how MSDS will be made available to employees. The HCP must explain procedures to follow when MSDS are not received or are not available.

The program must describe the format used to train employees about the HCP and specify the trainer. Procedures used to train new cleaning workers before their initial job assignment must be outlined. The HCP must include procedures to train employees when new hazards are identified.

Chemical labeling

Labels represent the initial warnings for hazardous chemicals, so they must

• Identify the chemical and its appropriate hazard warning.

• Include the name, address and telephone number of the chemical manufacturer, importer or other originating source.

• Identify body organs that can be affected by the chemical.

• Be printed in English and must always be legible.

Alternative labeling systems from the hazardous materials information system (HMIS) or the National Fire Protection Association (NFPA) may be used when an employer’s overall HCP has been deemed effective by regulators. The HMIS and NPFA systems use numerical, color-coded information to identify hazards.

An effective label will immediately convey a chemical’s hazards.

Material safety data sheets

MSDS must be supplied by chemical manufacturers and importers for each hazardous chemical they manufacture or import. They must be in English and must include emergency information telephone numbers.

Specific information deemed necessary by the HCS must be on the MSDS. All sections of the MSDS must be complete and accurate.

OSHA mandates that the sheets be immediately available to employees during each work shift.

Employers and managers are given some flexibility when providing immediate access; computers, fax machines and other electronic means of transmission may be used to supply the information. However, the electronic sources of MSDS information must be immediately available. Employees must be trained to use the specific electronic device providing the MSDS. Backup systems (other items used to provide MSDS information) also must be readily available if electronic mediums fail.

Employee training

Employees must be trained before they work with a hazardous chemical. Training carried out weekly or monthly is inadequate.

The training must explain the HCS, HCP and the cleaning operations that can expose employees to hazardous chemicals. The training must describe the workplace location’s HCP, where MSDS can be found and the location of hazardous chemicals.

Included in the training should be identification of proper emergency procedures and the person designated to handle emergencies.

Remember to train all employees when a new physical or health hazard is identified.

If employees receive job instructions in a language other than English, HCS training also must be conducted in the other language.

During training, employees should be given the opportunity to ask questions and become familiar with the hazards associated with the chemicals they use to clean. Training depends on the employee’s ability to read and understand labels; functionally illiterate workers must have information conveyed verbally and pictorially to them.

Cleaning and facility managers who use temporary workers have a shared responsibility with the placement agency to train the temporary employees. The "host" employer or manager is primarily responsible for training temporary employees because the workers will be using their chemicals. The employer or manager creates and controls the chemical hazards.

A host employer or manager should train temporary employees in the same way they train their regular staff.

The temporary agency should support the host employer’s training efforts; at a minimum they should inform their personnel of the HCS repuirements.

Training in emergency procedures should be stressed; the greater the hazard, the more extensive the training should be. Employers and managers who expect employees to respond to chemical emergencies should provide those workers with more detailed training.

Be sure to include followup programs to reinforce your company or facility’s HCP. Employee job descriptions and evaluations should stress and support your hazard communication program.

Not only is chemical safety training a smart thing to do, it’s the law.

Wilbert L. Dawkins, Jr. is senior manager with Sanitation Solutions (Sani-Solv) Groups, Inc., a Jacksonville, FL-based janitorial consulting and services firm.