The Hazard Communication Standard (HCS) is a regulatory framework established by the Occupational Safety and Health Administration (OSHA) to ensure chemical safety in American workplaces. It operates on the principle that employees have a right to know about the chemical hazards present in their environment. The HCS mandates that employers with hazardous chemicals must establish a comprehensive system to communicate these hazards through standardized labels, safety data sheets, and employee training.
The Purpose and Scope of the Hazard Communication Standard
The primary objective of the HCS is to ensure that the hazards of all chemicals produced or imported into the United States are properly evaluated and effectively transmitted to employers and employees who use them. This federal regulation, codified as 29 CFR 1910.1200, applies broadly to chemical manufacturers, importers, distributors, and any employer with hazardous chemicals on site. The standard covers more than 43 million workers in nearly all industries, ensuring employees are informed about potential exposure during normal work conditions or foreseeable emergencies.
The HCS places the initial burden of hazard classification on chemical manufacturers and importers, who must determine the potential dangers of their products. This hazard information must then be passed down the supply chain to downstream employers and employees. This comprehensive program relies on container labeling, Safety Data Sheets (SDSs), and employee training. The scope of the HCS is intentionally wide, preempting state-level regulations on chemical hazard communication unless the state operates under an approved OSHA plan.
Key Elements of a Written HazCom Program
Every employer covered by the HCS must develop and implement a formal, written Hazard Communication Program tailored to their specific workplace conditions. This document serves as the administrative blueprint for meeting the standard’s requirements. The written program must detail how the employer ensures all containers are properly labeled and how employees access Safety Data Sheets (SDSs) for every hazardous chemical used.
The written plan must include an accurate, up-to-date inventory of all hazardous chemicals present in the workplace. The program must also specify the methods the employer will use to inform employees about the hazards of non-routine tasks, such as cleaning chemical reactors or performing maintenance on a process line. Additionally, the document must outline procedures for communicating hazards associated with chemicals contained in unlabeled pipes in the work area.
Understanding Safety Data Sheets (SDSs)
Safety Data Sheets (SDSs) are the primary and most detailed source of information about a hazardous chemical, replacing the former Material Safety Data Sheets (MSDSs). Manufacturers and importers are responsible for creating and providing these standardized documents to downstream users. Employers must ensure that all SDSs are readily accessible to employees during every work shift in their work area.
SDSs must follow a rigid, 16-section format, ensuring consistent data presentation regardless of the chemical or manufacturer. OSHA requires the first 11 sections and the final Section 16, which cover identification, hazard information, composition, first-aid measures, and exposure controls. Sections 12 through 15 provide ecological, disposal, transport, and regulatory information. While these sections must be included, they are regulated by other agencies and are not mandatory for OSHA compliance.
Requirements for Chemical Labeling
The HCS establishes dual requirements for chemical labeling, covering containers shipped from a manufacturer and containers used within the workplace. Labels on containers leaving the manufacturer must include six standardized elements to communicate hazard information to downstream users:
- The product identifier.
- A signal word (e.g., “Danger” or “Warning”).
- Standardized hazard statement(s) describing the nature of the risks.
- Specific pictogram(s), which are graphical symbols set within a red-bordered diamond to quickly convey the type of hazard.
- Precautionary statement(s) recommending measures to minimize exposure or improper handling.
- The supplier’s name, address, and telephone number.
For containers used internally, secondary labeling is required if the chemical is not for immediate use. This internal label must include at least the product identifier and a general indication of the chemical’s hazards.
Employee Information and Training Obligations
Employers have a continuing obligation to provide effective information and training to employees who may be exposed to hazardous chemicals. Training must be delivered at the time of an employee’s initial assignment and whenever a new chemical hazard is introduced. This ensures employees understand the information and can take appropriate protective measures.
The training must cover the details of the employer’s written HazCom program and how it is implemented in their specific workplace. Employees must be taught how to read and interpret chemical labels and Safety Data Sheets, enabling them to locate and understand hazard information. Instruction must also include the physical and health hazards of the chemicals in their work area and the protective measures employees can take, such as using appropriate Personal Protective Equipment (PPE).
The Role of the Globally Harmonized System (GHS)
The current version of the Hazard Communication Standard, HazCom 2012, is aligned with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS is an international framework developed to standardize how chemical hazards are classified and communicated across different countries. OSHA adopted this standardization to improve the quality and consistency of hazard information available to workers.
Aligning the HCS with GHS resulted in two major changes to the United States standard: the standardized 16-section format for Safety Data Sheets and uniform requirements for chemical labeling. The GHS provides the foundational criteria for classifying a chemical’s health and physical hazards. This classification dictates the precise signal words, pictograms, and hazard statements that must appear on the label and the SDS. This global alignment facilitates international trade and provides a cohesive approach to chemical safety information.