What OSHA will look for

• OSHA will confirm that an employer has a written HazCom program, and that it addresses all the required topics.
• Designate someone to ensure all containers have labels that are readable.
• Compliance officers will look for appropriate labels, descriptions of written alternatives to labeling stationary process containers, descriptions of labels on shipped and workplace containers included in training, and procedures to review and update label information.

During an inspection, the Occupational Safety and Health Administration (OSHA) will confirm that an employer has a written HazCom program, and that it addresses all the required topics for that workplace.

The employer is expected to provide access to the written program upon request to all employees and employee representatives — failure to do so is a violation.

Assigning responsibility to one person for keeping the written program up to date can ensure that it remains compliant.

Chemical inventory

The list of hazardous chemicals in the workplace must be kept current. Revise the list as necessary when eliminating chemicals in the workplace, or when bringing in a new chemical.

Labels/Other forms of warning

Labeling is a continuing duty — all in-plant containers of hazardous chemicals, except for portable containers, must always be labeled.

Written programs should include the person responsible for labeling, both shipped containers and workplace containers, a description of the labeling system used, and a description of any alternative labeling for workplace containers, if applicable.

Review and update labeling and the written program’s label information when necessary.

A compliance officer will check to see that container labels are legible and prominently displayed, and that the container can be cross-referenced to a safety data sheet (SDS). The compliance officer will also evaluate any in-house or workplace labeling, or any alternative labeling provisions used.

The compliance officer may also interview employees to determine if they are familiar with the labeling used in the workplace, and the hazards which the labels denote.

Since labels can come off, information can become smudged or otherwise made unreadable, designate someone to be responsible for ensuring that all containers are labeled, that labels are readable, and that newly purchased materials are checked for labels prior to use.

With these requirements in mind, a compliance officer will be looking for the following types of information to ensure that labeling is properly implemented:

1. Designation of person(s) responsible for ensuring compliant labeling of shipped and in-plant containers;
2. Description of written alternatives to labeling of stationary process containers (if used);
3. Appropriate labels on all workplace containers, including those received from a supplier, secondary containers, and stationary process containers;
4. A description and explanation of labels on both shipped and workplace containers included in the employee training program; and,
5. Procedures to review and update workplace label information when necessary.