Hazard
Communication
& Temp Workers
OSHA Compliance for Temp Agencies and Host Employers
Background
The Hazard Communication Standard (HCS) is
based on a simple concept
• Employees have both a need and a right to
know the hazards and identities of the
chemicals they are exposed to at work
Background
• They also need to know what protective measures are available
to prevent adverse effects from occurring
• The HCS is designed to provide employees with the information
they need
Hazard Communication Standard
(a) Purpose
(b) Scope
(c) Definitions
(d) Hazard Classification
(e) Written Program
(f) Labels
(g) Safety Data Sheets
(h) Employee Training
(i) Trade Secrets
(j) Effective Dates
Written
Program
Four Major Changes
1. Hazard Classification (changed from
hazard determination)
2. Labels
3. Safety Data Sheets (changed from
(M)SDS)
4. Information and Training
Will affect nearly 40 million workers and 5 million
workplaces.
5
Haz Com Revisions
Benefits:
• Improved worker comprehension = appropriate
handling and use of chemicals
• Improved access to information
• Harmonized classification of health and physical
hazards
• Specific elements for labeling and SDS
• Reduced burden on overseas
exports/imports
6
Effective
Completion
Date
Requirements
Dec 1, 2013
Train employees on new labels and Safety
Data Sheet format
June 1, 2015
Compliance with modified provisions of
final rule except:
December 1,
2015
June 1, 2016
Transition
period
7
Distributors shall not ship containers
labeled unless it is a GHS label
Who
Employers
Chemical
manufacturers,
importers,
distributors &
employers
Update workplace labeling and HAZCOM
program. Additional employee training on
newly found physical or health hazards
Employers
May comply with final HAZCOM std. or
current std., or both
Chemical
manufacturers,
importers,
distributors &
employers
Chemical Manufacturers
• A significant portion of the standard pertains only to chemical
manufacturers, importers, and distributors
• Employers who do not produce chemicals only have to focus on
establishing a workplace program and communicating
information to their workers
Employers
• Employers are required to provide information to their
employees about the hazardous chemicals to which they are
exposed using:
• A hazard communication program
• labels and other forms of warnings
• (material) safety data sheets ((M)SDS)
• information and training
Employer Requirements – Written
Program
• Employers must develop a written program that covers at
least:
• Labels and other forms of warnings
• (Material) Safety Data Sheets
• Employee Information and Training
Written Program
• Employers must develop a written program that covers at
least:
• A list of the hazardous chemicals known to be present at the
facility along with (M)SDS’s for each chemical
• The methods the employer will use to inform employees
of the hazards non-routine tasks
• The hazards of chemicals in unlabeled pipes
Labels on shipped containers
Required Elements on shipped containers
Product identifier
Signal words
Hazard statements
Pictograms
Precautionary statements
Name, address, and telephone number of the chemical
manufacturer, importer, or other responsible party
A new Appendix C, Allocation of Label Elements, has been provided to
indicate the label requirements by hazard class and category
Labels are to be updated within 6 months of getting new and significant
information about the hazards, or ways to protect those exposed
Workplace Labeling
• The employer must ensure that each container of
hazardous chemicals in the workplace is labeled, tagged
or marked with either:
• The label information on the shipped container, or
• Product identifier and words, pictures, symbols, or
combination providing general information on the hazards
of chemicals
• Labels must be legible, in English, and prominently
displayed on the container or readily available in the work
area
Labels, Tags, and Markings
Container Labeling Exemption for
Portable Containers
The employer is not required to label portable containers
into which hazardous chemicals are transferred from
labeled containers, and which are intended only for the
immediate use by the employee who performs the
transfer
Example of Simple Label
Example of Complex Label
Labels
 OSHA is maintaining the current approach to allowing
alternatives to labels on each stationary process container
 The exception for portable containers under the control of
the person who filled them with the chemical remains the
same.
 Labels on incoming containers are not to be removed or
defaced unless immediately replaced by another label
 Workplace labels are to be prominently displayed and in
English, although other languages are permitted as well
Pictograms
Labels
Employers are responsible for maintaining the labels on the
containers, including, but not limited to, tanks, totes, drums, and
for training their employees on the hazards listed on the labels in
the workplace.
Labels must continue to be:
 legible
 contain the pertinent information (such as the hazards and
directions for use)
 not able to be defaced, (i.e., fade, get washed off,) or removed
in any way
Safety Data Sheets (SDS)
(Material) Safety Data Sheets ((M)SDS)
are one of the most important tools
available to employers
for providing information, and protection
to workers from hazardous chemicals
which are used in the workplace.
Safety Data Sheets (SDS)
Identifies chemicals by name
Tells potential harm and how chemicals
will enter the body (Inhalation, ingestion,
and/or skin absorption)
Explains signs and symptoms of
exposures
Explains emergency procedures
Safety Data Sheets (SDS)
The GHS uses a specified order of information, as well as
title descriptions, on the 16-section safety data sheet.
Health, physical and environmental hazard criteria for
substances and for classification of mixtures.
Consistent with voluntary industry consensus standards,
such as ANSI.
Should improve comprehensibility and issues regarding
accuracy of information.
Safety Data Sheet Format
1. Identification of the
substance or mixture
and of the supplier
2. Hazards identification
3. Composition/informatio
n on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release
measures
7. Handling and storage
8. Exposure
controls/personal
protection
9. Physical and chemical
properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information, including
date of preparation or last
revision
Safety Data Sheets (SDS)
SDS in the workplace for each hazardous chemical
Readily accessible during each work shift to
employees when they are in their work area(s)
Employee Information and
Training
• Employers must provide employees information and
training on hazardous chemicals in their work area:
• At the time of their initial assignment
• Whenever a new physical or health hazard the employees have
not previously been trained about is introduced into their work
area
• Training may cover categories of hazards
Employee Training
OSHA standard covered
Detection of chemical
Operations in their work
area where chemical is
used
Hazards of chemical
Pictograms
Location of program, list
of chemical, and SDS
Protection measures
Emergency procedures
Labeling system used
Employee Training
Although this paragraph remains essentially the
same, updates include
Training to include label elements and new safety data
sheet format - by December 1, 2013
Training to reflect any new hazards identified in the
workplace - by June 1, 2016
Training – prescribed label elements and order of
information on data sheets facilitate
training/comprehensibility.
Temporary Employees
 Generic HazCom Training
 How to read SDS
 Worksite Specific HazCom
Training
 Labeling requirements
 Chemicals in use
 Pictograms
 Methods of detection and
prevention
 Elements of HazCom Standard
 SDS maintenance
 Workplace labeling
 Emergency procedures
 Written HazCom Program