Has your facility met the December 1, 2013 deadline for training on hazard communication (hazcom) revisions? OSHA requires that you train your staff on the new safety data sheets and changes that manufacturers are required to make on product labels.
Use this checklist to ensure that your facility is compliant with new (and existing) OSHA requirements for hazard communication.
1. Make a master list.
Take a physical inventory and make a master list of the hazardous chemicals in your facility today. If you don’t know what you have on hand, you can’t ensure that you have the appropriate safety data sheets (SDSs).
2. Update your SDS library, as each updated SDS becomes available, for each and every chemical on your inventory.
The revised Hazard Communication Standard requires manufacturers to make changes to the format that is used for Safety Data Sheets. As manufacturers roll out their updated SDSs, Stericycle customers on the Steri-Safe Preferred and Steri-Safe Select programs have immediate and unlimited access to the most up-to-date SDSs through the MSDS/SDS system at MyStericycle.com. Stericycle offers these customers easy electronic storage and print access.
3. Properly dispose of chemicals you no longer need or that are outdated.
To ensure that you comply with all local and federal regulations, hire a hazardous waste disposal company for disposal of hazardous wastes. Stericycle provides lab packing services that are appropriate for hazardous waste disposal—even if you’re not sure what type of chemicals you have.
4. Make sure employees know how to recognize and retain any SDSs for your SDS library.
Chemical manufacturers are in the process of updating their SDSs from the older MSDSs. These manufacturers must send an updated SDS with only the first chemical shipment (not reorders), or with the first shipment after a change is made.
5. Compare any SDS against the previous version as they arrive at your facility.
Are there any new hazards, instructions, or safe handling recommendations? Again, you’ll want to have the most recent version of the SDS.
6. Train employees on new information and hazards.
December 1, 2013 is the deadline for training on the new SDS format and on changes that are coming to product labels.
7. Archive old SDSs and MSDSs.
Employees must have access to some record of hazardous chemicals to which they were exposed. Records on those hazardous chemicals are required to be kept for a period of 30 years, and one way to comply with that requirement is to keep SDSs and MSDSs on file, even for chemicals that are no longer in use. Keeping a record for 30 years is required by 1910.1020, Access to Employee Exposure and Medical Records Standard.
8. Use up-to-date resources that can save you time.
For example, Stericycle customers who have access to the Preferred or Select programs, have access to revised Hazard Communication Awareness training that explains the necessary OSHA requirements. The automated MSDS/SDS management tool is an innovative online resource that helps you build your e-book of up-to-date safety data sheets. A Safety Meeting Library with Hazard Communication Safety Meetings is also available.