It’s time to dust off your Hazard Communication Program

It’s time to dust off your Hazard Communication Program

7 steps to update your workplace, because pumpkin lattes and hazardous chemicals should never meet

Ah Fall… The smell of leaves and pumpkin lattes is in the air. It’s a great time to take out your hazard communication program and dust it off. Chances are you have hazardous materials in your workplace. Even in an office setting, you are likely to have cleaning chemicals. The last thing you want to see is someone confusing detergent with powdered coffee creamer.

Unfortunate mistakes can happen. So, let’s make sure to communicate the hazards of working with those chemicals so employees know how to work with them safely.

7 questions to evaluate your workplace hazard communication game.

You can establish a great HazCom program with a little attention to these best practices. If you already have a program in place, answering these questions can help you evaluate how effective it is as part of your overall safety program.

1.    Are your hazardous materials labelled?

The easiest thing to do is to keep materials in their original containers and make sure the original labels are visible. If you put chemicals in secondary containers, then you must make sure they are labelled with much of the same information that required on the original container. This includes what the chemical substance is, who made it, hazard warnings, precautionary statements, and hazard pictograms. If you must use secondary containers, preprinting your labels will make it easier.

2.    Do you have a chemical inventory that is current and accurate?

Oregon law requires you to maintain a chemical inventory with a list of materials that employees may be exposed to, along with their locations.

3.    Do your employees have access to Safety Data Sheets (SDS)?

Do they have access even in an emergency?

As an OSHA compliance officer, I would always ask employees if they knew where to find the SDS? If they didn’t know, the employer would be cited for inadequate training. It isn’t enough for managers to say “look it up on the internet.”  The internet is not  considered adequate access during an emergency. My goal as a compliance officer was simple: every employee should know that  if someone had a chemical exposure and was seeking medical attention, the SDS should go with them to the emergency room.

4.    Are your employees trained?

Do they know where to find the SDS? Do they know how to read them? Do they know the signs and symptoms of exposure to the materials that they work with? Do they know what hazards they face during non-routine tasks?

Employees should know how to minimize their exposures. They must be trained prior to any exposure, and again whenever a new material is introduced. I encourage supervisors and employees to regularly review the materials that they are using, at least annually. If you have a team that works with several hazardous materials, reviewing a couple during team meetings on a regular basis will keep the information fresh. Heck, I have even played hazardous materials bingo with crews to make it more fun.

5.    Do you notify others of the presence of hazardous materials when they work with your business?

You are required to communicate to contractors and vendors that they may have exposure to the hazardous materials at your workplace. This could be through labelling, signage, and language in the contract that includes hazard communication information.

6.    Do you have a written hazard communication program?

Have you updated your written communication program in the last year?

Your written HazCom plan should include your inventory of hazardous materials, how you will label your materials, and where your SDS are located. It should also describe your plan for training employees, including for non-routine tasks that involve hazardous materials.

7.    Are there more hazard communication requirements for your operation?

If your workplace includes a laboratory, uses pesticides or materials such as lead, carcinogens, or other highly toxic materials, there may be additional legal requirements for your hazard communication program. In this case, it’s always a good idea to consult OR-OSHA, which has many hazard communication resources.

I highly recommend working through these seven questions to optimize your workplace’s hazard communication program this fall. To a former OSHA inspector like me, that sounds almost as enjoyable as eating candied apples in October.

Yours in success,


Rebecca Wale

Chief Safety Consultant


Rebecca is the Chief Safety Consultant of Integrated Success HR Consulting & Coaching, LLC. She has extensive credentials and experience as an Environmental Health and Safety/Risk Management professional and leader across a variety of industries.  Her background in for-profit, non-profit and governmental organizations, and as a former OSHA compliance officer, means Rebecca knows how to design cost-effective programs that really work. Rebecca’s passion is translating her vast experience into straight-forward programs for busy leaders.