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A Primer on Top OSHA Violations - The HAZCOM Standard

Each year, the world produces more than 70,000 different chemicals amounting to over 400 million tones. Households use products containing potentially dangerous chemicals on a regular basis. But truly hazardous are chemicals used at an industrial level, in  automotive, manufacturing and industrial operations.

Essential for industrial activities, chemicals represent a huge danger to workers' health and the environment. According to OSHA, illnesses caused by exposure to chemicals kill nearly 50,000 people, every year, with immediate or long-term effects on the health of the workers who produce them or use them.

Find out what you how to ensure the proper protection against chemical hazards for your workers.

What is Hazcom?

The Hazcom OSHA standard regulates chemical safety in the workplace. Hazcom is aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), an internationally agreed standard managed by the United Nations, and provides a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets (SDS).

Under the Hazcom OSHA standard, producers and importers of chemicals must evaluate and provide information on the hazards of the chemicals they produce or import, preparing Hazcom labels and SDS for their customers. At the same time, in workplaces where hazardous chemicals are used, employers must provide workers labels, safety data sheets, and trainings on how to handle the dangerous substances appropriately.

However, 1910.1200 (Hazcom or HCS), is one of the top three most frequently violated standards in the US, in the past seven years, as employers’ failed to meet compliance requirements through their Hazcom programs.

In 2019, Hazcom violations have ranked third on OSHA’s annual list. OSHA officials conducted 195 inspections of chemical manufacturing facilities from October 2018 to September 2019, according to data posted on the agency’s website. 84 citations were issued for this standard, resulting in fines of $141,975. 

Three steps to classify hazards

 “... For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that applies to the chemical being classified... Chemical manufacturers, importers or employers classifying chemicals shall identify and consider the full range of available scientific literature and other evidence concerning the potential hazards. There is no requirement to test the chemical to determine how to classify its hazards,” (Source: Hazcom OSHA standard.)

Hazcom recommends that hazard classification should indicate only the intrinsic (inherent) hazardous properties of chemicals. According to Hazcom, for many hazards, qualitative and expert judgment is required to interpret the data for classification purposes. There are three steps to be taken:

·         Identification of relevant data regarding the hazards of a chemical;

·         Subsequent review of those data to ascertain the hazards associated with the chemical;

·         Determination of whether the chemical will be classified as hazardous and the degree of hazard.

Health and physical hazards by category

The Hazcom classification divides hazards into health hazards, physical hazards, and chemical mixtures. According to the HazCom standard, there are 10 health hazards putting human health in danger (i.e. breathing or vision) and 16 physical hazards that can cause damage to the body (for example, skin corrosion).

Hazcom divides hazards into classes that describe the nature of the hazard. Within the hazard classes, the degree of hazard is indicated by the category. However, chemical classes include several hazard categories and each chemical can be included in several of those. The category is a number (1-4) or letter (A, B, C), but a few, gases and reproductive toxins, for example, are indicated with words. Within the ranking system, 1 represents the greatest hazard and 4, the least. Also, A is a greater hazard than B and so on. Some of the numeric categories have subcategories, so class 2A is more hazardous than class 2B.

Hazcom standard classification of health hazards

·         Acute toxicity (oral, dermal and inhalation) – categories 1-4

·         Skin corrosion / irritation – categories 1A, 1B, 1C, and 2

·         Serious eye damage/eye irritation – categories 1, 2A, and 2B

·         Respiratory or skin sensitization – category 1A and 1B

·         Germ cell mutagenicity – categories 1A, 1B, and 2

·         Carcinogenicity – categories 1A, 1B, and 2 

·         Reproductive toxicity – categories 1A, 1B, 2; lactation

·         Specific target organ toxicity: single exposure – categories 1-3

·         Specific target organ toxicity: repeated or prolonged exposure – categories 1 and 2

·         Aspiration hazard – category 1

Hazcom standard classification of physical hazards

·         Explosives – divisions 1.1-1.6

·         Flammable gases – categories 1 and 2

·         Flammable aerosols – categories 1 and 2

·         Oxidizing gases – category 1

·         Gases under pressure, groups – compressed, liquified, dissolved, refrigerated liquid

·         Flammable liquids – categories 1-4

·         Flammable solids – categories 1 and 2

·         Self-reactive chemicals – types A-G

·         Pyrophoric liquids – category 1

·         Pyrophoric solids – category 1

·         Self-heating chemicals – categories 1 and 2

·         Chemicals which, in contact with water, emit flammable gases – categories 1-3

·         Oxidizing liquids – categories 1-3

·         Oxidizing solids – categories 1-3

·         Organic peroxides – types A-G

·         Corrosive to metals – category 1  

Hazcom standard classification also speaks about evaluating mixtures – "any combination of two or more chemicals if the combination is not, in whole or in part, the result of a chemical reaction." In the case of chemical mixtures, test data can be used but no testing is required. The degree of hazard can be estimated based on the hazards of the mixture components.  

Bridging principles can be used to estimate the degree of hazard based on the hazards of the mixture components if they do not interact when combined. There are six bridging principles: dilutions, batching, the concentration of highly toxic mixtures, interpolation within one toxic category, substantially similar mixtures and aerosols. If a mixture causes a chemical reaction, the classification of the mixtures would require a search of the scientific literature or laboratory testing.

The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) on which Hazcom OSHA standard is based includes one more classification, for environmental hazards. This classification is not currently enforced in the US but must appear on SDS and refers to acute aquatic toxicity and chronic aquatic toxicity.

How to implement a compliant Hazcom plan?

To assure workers chemical safety, OSHA requires employers who produce, use or store hazardous chemicals in the workplace to implement a Hazcom program that will provide employees information via labels, SDS, and chemical inventory lists. They must also prepare and implement a written Hazcom plan and offer employees training regarding specific chemicals used in the workplace, to facilitate hazard recognition, understanding, prevention, and control.    

A written Hazcom plan must describe:

a.       How the Hazcom standard will be implemented, covering up all its requirements. I

b.       Must include an inventory of all chemicals used in the workplace and each of them should also appear on Hazcom labels and SDS.

c.       Present work activity and the way the Hazcom plan is implemented through SDS deployment and employee training programs.  

Chemical manufacturers and importers are required to provide a shipping label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided. At workplaces, employers can replicate the Hazcom compliant shipped label or can choose an alternative labeling system such as the National Fire Protection Association (NFPA) and Hazardous Materials Identification System (HMIS), also permitted for workplace containers.

SDSs should be aligned to OSHA’s 16-section format and should be made accessible to employees during work shifts. A safety data sheet includes information concerning the properties of the chemicals, the Hazcom classification, protective measures and safety precautions for handling, storing, and transporting the chemical. It also guides the proper personal protective equipment (PPE) to be worn, first aid procedures and spill clean-up procedures.

 Let’s not forget Hazcom training

To reduce the number of chemical source illnesses and injuries in workplaces across the US, OSHA requires employers to offer workers information and training on the chemical hazards they are exposed to. Hazcom training should include methods to detect hazardous chemicals, their physical and health hazards and the measures of protection workers can take. The training should also provide information on the location and the availability of the written Hazcom program, including the explanation of Hazcom labels, the list of hazardous chemicals and the SDSs.

Hazcom training regarding protective measures available in the workplace should be offered to workers at the time of their initial assignment. New information and training should be offered to employees every time a new hazardous chemical is introduced in their work area.