Hazard Communcation. What does that mean?
The OSHA Hazard Communication, or HazCom, standard, 29CFR 1910.1200, establishes responsibilities for providing hazardous chemical information to employers and employees. While the standard establishes requirements for container labeling, material safety data sheets and employee training, the basis of the standard is that chemicals hazards must be communicated to those affected. How one defines “communicated” is a key point in establishing a hazard communication process.
In 1995, the “New OSHA”* was unveiled with a central idea that a program or site should be evaluated in whole and determined effective based on performance results, versus by compliance to excerpts from specific regulatory requirements (paraphrased). This new focus on a “performance based” regulatory agency, as it has been commonly referred to, was meant to clarify employer requirements under the OSH Act and promote the real purpose of OSHA, preventing employee injuries. Evaluating HazCom utilizing this performance based approach, presents some interesting potential non-compliance situations. What does communicated mean in a performance based model?
After studying communication in college there was one concept I was absolutely sure of, no model will ever be created that can accurately depict how communication works. There are too many variables. The fact that each person is unique makes it impossible to depict a communication process that applies in all situations, not to mention all the medias available, distractions and the basic fact we as humans are always communicating. We are always sending and receiving messages. What we do or not do, what we say or not say, etc. is communicating something. With such an unpredictable process, how do we ensure our communication of hazard information will provide the results required? Traditionally, we would meet the communication requirement by simply making the information available. Is that enough in a performance based environment?
Fortunately, OSHA has not (at the time this was written) defined performance based Hazard Communication to include comprehension or understanding by all target recipients. They have defined performance based in letters of interpretation to include making manufacturer Material Safety Data Sheets available for employee review without request, labeling of hazardous materials, having hazardous material inventory for work sites and training of employees on hazards upon initial assignment and anytime a new hazard is introduced. But ask yourself, “Could someone be seriously injured as a result of a chemical hazard not being understood, despite being clearly “communicated”?” It is hard to deny that possibility so including employee comprehension in your HazCom program is important.
Testing of employees after training will at a minimum verify the basics were understood. Including HazCom elements in your routine audit process can also provide verification that the basics are understood. Questioning employees about chemicals in their work area and where they would find information on those chemicals during routine audits is usually a highly effective method of ensuring HazCom comprehension.
* From the May 1995 National Performance Review Report
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