Hazard Communication Programme
Written Programme — OSHA 29 CFR 1910.1200 (GHS Aligned)
Regulatory requirement: A written HazCom programme must describe how the facility complies with the requirements for labelling, SDS, and employee information and training.
Supervisors are responsible for ensuring their employees are trained before working with hazardous chemicals, have access to SDS, and use appropriate PPE. Employees are responsible for following this programme and reporting any labelling or SDS deficiencies.
Required: A list of hazardous chemicals known to be present in the workplace must be compiled and maintained. The inventory must reference the SDS for each chemical.
The chemical inventory is a master list of all hazardous chemicals at this facility and cross-references the corresponding SDS. New chemicals must be reviewed and added to the inventory before first use. Discontinued chemicals are removed from the inventory when no longer on-site.
SDS must be obtained from the manufacturer/supplier for every hazardous chemical before first use. If an SDS is not provided with a shipment, it must be requested in writing within 30 days. SDS are reviewed for currency at least annually; outdated SDS are replaced.
SDS must be accessible to employees during all work shifts without any barrier (employees must not need to ask a supervisor or use a password to access SDS in an emergency).
GHS-aligned labels on shipped containers must include: product identifier, signal word (Danger/Warning), hazard statements, precautionary statements, pictogram(s), and supplier identification.
Original containers: Labels on containers received from suppliers shall not be removed or defaced. If a label becomes illegible, a new label containing the same information shall be applied.
Secondary/portable containers: When hazardous chemicals are transferred to secondary containers, those containers must be labelled with at minimum the product name and words, pictures, or symbols that provide hazard information. Exception: immediate-use containers used and emptied during a single work shift by the person who filled them need not be labelled.
Training must cover: (a) the requirements of OSHA's HazCom standard; (b) operations in the work area where hazardous chemicals are present; (c) location and availability of the written programme, chemical inventory, and SDS; (d) methods to detect hazardous chemical releases; (e) physical, health, and environmental hazards of the chemicals; (f) protective measures including PPE, engineering controls, and safe work practices; (g) how to read and understand GHS labels and SDS.
Required: Employers who produce, use, or store hazardous chemicals at a multi-employer worksite must ensure other employers on-site are informed of the hazards.
This programme shall be reviewed and updated at least annually. All updates require approval from the EHS Manager and notification to affected employees. Previous versions shall be retained for a minimum of 5 years.