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Poor Hazard Communication Among OSHA’s Most Cited Violation

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Each year the Occupational Safety and Health Administration releases the Top 10 Most Cited Violations of safety and health standards. For any employer, it's a good starting point when doing their own safety and health audit. Holding the number two spot in 2017 is Hazard Communication, most violated across all industries.

The premise behind the hazard communication standard is that employees have a right to know the toxic substances and chemical hazards they could encounter while working.

Surprisingly, the most cited infraction of the standard is the one requiring a hazard communication plan in the first place. So, if you don't have a written plan that's been implemented and maintained at each workplace, then getting one done could actually prevent all other citations on this standard.

The premise behind the hazard communication standard is that employees have a right to know the toxic substances and chemical hazards they could encounter while working. They also need to know the protective things they can do to prevent adverse effects of working with those substances. Here are the steps to comply with the standard.

1. Get a copy of the rule.

2. Understand the requirements.

3. Name the people responsible for implementing, activating and maintaining your plan. 

4. Inventory the chemicals.

5. Confirm containers are labeled.

6. Get a material safety data sheet for each chemical.

7. Put your plan in writing (there are some sample templates here but be sure to evaluate them for relevance to your work and adapt them as needed).

8. Make MSDSs available to workers.

9. Train workers.

10. Schedule regular maintenance. 

11. Set up procedures for evaluating how effective the plan is.

Multi Employer Job Site

Construction is in a unique position because there are usually multiple business entities working on one project. For the prime contractor that means making sure hazard communication happens across the entire jobsite, and that it includes all hazardous materials used on the project.

When Consumer Products are Unsafe

While construction workers might work with many consumer products like cleaners and degreasers, those substances generally don't require you to communicate the potential hazards they present. However, if the workers will use those substances longer, and more often than what a typical consumer would use them, then workers have higher exposure. That should prompt you to make sure you communicate their hazards and required protective measures.

Not All MSDSs Required

Sometimes manufacturers create material safety data sheets for substances that aren't hazardous. They do that to identify chemical properties, set safe use guidelines, point out incompatibilities and reference safe storage and handling practices. If the substance is nonhazardous it will say so at the top of the MSDS, and you don't need to communicate with employees about it or maintain the MSDS on file.  

If your workplace is in one of the 28 states having a state OSHA plan, follow their guidelines when developing your hazard communication plan.

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