In 2023, OSHA wrote citations for an astounding 3,213 violations related to hazard communication systems (HCSs). That number is not as astounding as the 7,271 violations for fall protection in the same year. Fall protection took the No. 1 spot, and HCS took a distant second. What is astounding is that there could be so many violations for this particular part of OSHA regulations.
The HCS regulations are covered in 29CFR1910.1200. It breaks down into these subparts:
(a) Purpose.
(b) Scope and applications.
(c) Definitions.
(d) Hazard classification.
(e) Written hazard communication program.
(f) Labels and other forms of warning.
(g) Safety data sheets.
(h) Employee information and training.
(i) Trade secrets.
(j) Effective dates.
For the typical employer getting cited and fined, what’s missing is a decent implementation of d, e, and h from that list. This is where the citations start accruing. But at root is a failure to understand a, b, and c from that list. In this multi-part series, we’ll cover each of those.
Let’s start with the purpose. There are really two of them:
- To ensure that the hazards of chemicals that employees may be exposed to are identified and classified.
- To ensure that the information concerning those chemical hazards is communicated to the employees.
Look at that purpose again, and you can see why 3,213 violations is an astounding number. HCS is not a big ask and yet failure to comply is endemic. The purpose of this multi-part article is to give you the information you need to ensure your company isn’t among those cited.
