March 2011- Hazard Communication

What is the purpose of the Hazard Communication standard?

The purpose of the Hazard Communication Program is to inform employees about hazardous substances in the workplace, potential harmful effects of these substances and appropriate control measures. The primary tools of this program are warning labels, MSDSs and employee training.

Is the Hazard Communication Standard a performance standard?

Yes. This means that you have the ability to adapt the rule to the needs of your workplace, rather than having to follow a specific set of requirements. It also means that you have the responsibility to implement an appropriate and effective program.

To whom does this standard apply?

Employers that "use" hazardous chemicals must have a program to ensure the information is provided to exposed employees. "Use" means to package, handle, react, or transfer. This is an intentionally broad scope, and includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.

What are the requirements of the rule?

The requirements of the rule that deal specifically with the hazard communication program are found in the standard in paragraphs (e), written hazard communication programs; (f), labels and other forms of warning; (g), material safety data sheets; and (h), employee information and training. The requirements of these paragraphs should be the focus of your attention.

Where can I find more information?

As an employer you should concentrate on becoming familiar with the Hazard Communication standard using paragraphs (b), scope and application, and (c), definitions, as references when needed to help explain the provisions.

  • A Chemical Inventory List (CIL), a list of all hazardous substances in the workplace - The list may be compiled for the workplace as a whole or for individual work areas and can serve as a checklist to ensure that all hazardous substances in the workplace have MSDSs and labels. 
  • A completed MSDS for each hazardous material listed/used in the workplace - The MSDS contains useful information on the nature of the hazards and how to use, store, and dispose of the material. It also describes what protective measures to take while using the material and what first aid measures to follow if an exposure to the substance occurs. MSDSs must contain all of the sections required by the standard and be readily available to employees. 
  • Methods for employee training and awareness. 
  • Labels and hazard warning information - Employers are required to use legible labels and other forms of warning to clearly and quickly communicate what’s in a container, its hazards, the safety precautions, and the name and address of the manufacturer. Labels and other forms of warning are to be conspicuously placed on containers so that the message is readily visible. Labels should not be removed and, if torn or defaced, they must be replaced. What employee training is required for Hazard Communication?
  • Employees must receive training on the Hazard Communication program requirements including its location and availability, the identification and location of hazardous substances, and how to read and understand MSDSs. Training must be done at the time of initial work assignment or when a new material is introduced. Training must be appropriate in content and vocabulary for the education, literacy, and language comprehension level of the employee(s).

What are some training specifics?

Train your employees on:
  • An overview of the requirements contained in 1910.1200 - Hazard Communication Rule.
  •  Chemicals (any element, chemical compound or mixture of elements and/or compounds) present in their workplace operations.
  •  Location and availability of the written hazard communication program 
  • Physical and health effects of the hazardous chemicals 
  • Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area 
  • How to reduce or prevent exposure to these hazardous chemicals through use of control/work practices and personal protective equipment 
  • Steps the facility has taken to reduce or prevent exposure to these chemicals 
  • Safety emergency procedures to follow if the employee is exposed to these chemicals 
  • How to read labels and review MSDSs to obtain appropriate hazard information.

For more info visit OSHA's Hazard Communication page here

Upcoming EPA Deadlines

 Topic  Brief Overview  Deadline  Links
Air Permitting (Title V Mj Source, Mn Source, Emissions Inventory Reporting)
Facilities that exceed specific emissions limits must apply for and maintain an air emissions permit. Annual reports are also required to report the emissions to the regulating authority (EPA, State or local depending on location).

Semi-annual reports and compliance certifications may also be required depending on your location and specific permit requirements.
Emissions reports due April 1st (will vary by state)

Semi-annual reports and compliance certifications typically due January 31st and July 31st. May vary by state.

State Environmental Agencies

Laws and Regs

Plain English Guide to Clean Air Act

Air Pollution Operating Permit Program: Key Features and Benefits

PDF of above

Who has to get a permit

EPA List of HAPs

E&SSG Solution

Storm Water Runoff Permit and Annual Inspection Report
Facilities must develop and implement a SWPPP to outline the procedures and equipment in place to prevent contaminants from getting into the run-off from storm water. A Storm Water permit must also be obtained from the state or local regulatory entity. Depending on your local regulations and SIC Code periodic reports may be required.
Annual Inspection Report due dates varies by state. Many states require them by March, 31st, however, some states are due by January, 31st.

Visual or analytical monitoring (typically quarterly -but some industries monthly)

Stormwater Discharges From Industrial Facilities

Annual Reporting Form

MSGP Industrial Discharge Monitoring Report (MDMR)

E&SSG Solution

Disclaimer: These Regulatory Reminders are not intended to be an exhaustive source for all of your particular facility’s compliance issues. They are designed to address the basics requirements with which most companies are required to comply. Following the Regulatory Reminder’s deadlines and Monthly Focus will not guarantee your compliance as these reminders are simply designed to help in your environmental/safety compliance efforts. You should always refer to the federal and your state’s regulations for all your requirements. Ultimately, your compliance with federal and state regulations is your responsibility. E&SSG assumes no liability for your compliance or the resources provided in these “Reminders”.

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