Written Plan – You must have a written plan for your HCS program. This plan should be reflective of your workplace and the hazards that your employees face in their day-to-day working environment. It must describe how your facility meets the requirements for labeling, MSDS management and training. Keep in mind, the written plan is the first thing an OSHA inspector will ask for, so you’re going to have to write it down.
Chemical Inventory – The written plan needs to include a current list of all hazardous chemicals. A properly maintained MSDS library can be used to quickly create a chemical inventory. A good electronic solution, on the other hand, can not only quickly print out a list of chemicals in the workplace, it also tracks where those chemicals are located and it what quantities.
Labels & Warnings – All of the chemicals listed in your inventory must be labeled properly and appropriate hazard warnings must be posted in your work areas. Make sure that products shipped into your facility have labels that are legible and prominently displayed. Also, if you re-bottle or re-drum hazardous chemicals at your facility, it is critical that you have a good secondary label program to ensure the chemicals are properly identified. Note: Label requirements under GHS are substantially different than what the HCS traditionally required. GHS labels use six standardized elements: product identifier, manufacturer information, signal words, pictograms, hazard statements, precautionary statements.
Material Safety Data Sheets (MSDSs) – Think of MSDSs as industrial-strength safety labels telling you everything from the hazards associated with a chemical, how to handle and store the chemical, to the proper personal protective equipment to use when handling the chemical. You must have MSDSs for all the chemicals in your inventory. You must make the MSDSs readily accessible to your employees. And your employees must be trained on where to find and how to read MSDSs so they fully understand the risks associated with the chemicals and the protection they need to use when handling chemicals in the workplace. Note: Under GHS, MSDSs are referred to as safety data sheets (SDSs) and have a 16 part format in fixed order. HCS alignment with GHS necessitates the revision of all SDSs. Employers should expect to update their entire safety data sheet library over the next few years.
Training – The HCS requires that you train your employees on where to find your written plan and MSDSs. And, more importantly on how to read the MSDSs, labels on containers and warning signs. Make sure employees are trained before assigning them to work with hazardous chemicals. Note: HCS alignment with GHS requires additional training for all employees covered under HCS.
