The following is adapted from an article I wrote for the latest edition of OHS magazine. Used with permission.
OSHA’s Hazard Communication Standard is among the most common safety citations in general industry, with over 4,000 violations annually. Hopefully, the following information will help you comply and have a safer workplace.
The HazCom Standard requires a written outline for a hazard communication program, proper employee training on workplace hazards, and documentation that each employee who could be exposed a hazard understands how to protect himself. This includes a process for proper container labeling—curled masking tape with smudged ink won’t satisfy a compliance officer.
Chemical manufacturer responsibilities
The manufacturer or importer of a chemical must determine its hazards [29 CFR 1910.1200(d)(1)]. OSHA lets employers treat this information as accurate.
A container of hazardous chemicals must have a Material Safety Data Sheet (MSDS) listing hazardous components and describing health hazards, proper use, and emergency procedures. OSHA also requires thefollowing information on the container, label or tag [29 CFR 1910.1200(f)(1)]:
- Identity of the chemical
- Appropriate hazard warnings
- Name and address of the manufacturer, importer, or other responsible party
If a chemical manufacturer or importer learns of a new hazard, labels and information must be revised within three months. Hazardous materials in transit must meet not only OSHA requirements but also those of the Department of Transportation (DOT).
Employer responsibilities
Creating an employer’s hazard communication plan will include the following steps:
- Create an inventory of hazardous chemicals on site
- Gather an MSDS for each
- Develop a program describing how a container will be marked so workers can easily identify the chemical and its hazards. [29 CFR 1910.1200(f)(5)]. OSHA requires that markings be legible, in English, and prominently displayed. The chemical’s identity may be a common or trade name or the actual chemical name. Hazard warnings may be words, pictures, symbols, numeric representations, or a combination.
- Document training plans, including schedules for refresher sessions.
Labeling requirements apply when a hazardous chemical is transferred to a smaller portable container unless the dispensing person immediately uses the chemical. [29 CFR 1910.1200(f) (5), 29 CFR 1910.1200(f) (7)]. Employees who do such dispensing must understand the requirements and know how to mark a portable container when needed, or how to get this done.
Facilities often use the labeling standards of the NFPA (National Fire Protection Association) or HMIS (Hazardous Materials Information System). Both systems indicate hazard levels with a numeric scale. Using established systems like these aids labeling, training and compliance, as an MSDS will often include the NFPA and HMIS numeric values.
An employer should designate someone to ensure that container markings follow the established format and always have proper and current information. This includes documenting these duties and the review and updating process.
Training
OSHA requires that each employee receives information about:
- Any hazardous chemical exposure possible in his workplace
- How to protect against such exposure
- How to read container markings and MSDS
- Where MSDS are stored and how to get more information
Some employers give all workers the same HazCom training. Others tailor training to hazards in an employee’s main work area so training is more realistic. Proper signs help remind employees of hazards in areas they rarely visit.
Receiving crews should be trained to accept only properly labeled chemicals, perhaps only those on a specified inventory. Some facilities establish protocols for MSDS; for instance, requiring chemical suppliers to send them in advance and/or only to a safety officer.
Rounding out safety
The Hazard Communication Standard is far-reaching and sometimes overwhelming, but proper training helps employees understand how it improves safety and be better able to comply.

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Portable Label Makers