Labeling hazardous chemicals at your project
OSHA requires every jobsite to inform its workers about classified chemical hazards that are on the project. Project managers and supervisors should refer to section 1910.1200, Hazard Communication Standard, for guidance about how to inform workers about chemical hazards properly.
OSHA’s construction industry standards don’t have separate hazard communication requirements. Instead, 1926.59 directs contractors to use 1910.1200 for guidance about hazard communication (HazCom) requirements.
If contractors are on a multi-employer project, each company must follow OSHA’s hazard communication requirements.
Here are three essential duties that every contractor has towards other contractors on the same jobsite where hazardous chemicals are present:
- Provide access to safety data sheets for chemicals
- Establish preventive measures to avoid exposure to these chemicals, and
- Share information about the container labeling system being used.
These duties are separate from each company’s personal obligation to protect its workers, which include:
- Make sure labels on containers are in place and not defaced;
- Maintain SDSs, and make them accessible to workers; and
- Train and provide information to employees about how they can avoid exposure to chemicals and how to stay safe.
OSHA defines a hazardous chemical as “any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.”
Workers should review SDSs of chemicals at their project to determine their classification and manufacturer’s safety recommendations.
Hazardous communication training essentials
The most straightforward part of the Hazard Communication standard to understand is its training requirement. Jobsites must train their workers about the hazards of chemicals used or stored in their work area.
Review SDSs during new-hire orientation and whenever using a new chemical on the job. Training must include specific topics like protection, prevention, mitigation, sources of exposure, and first aid. Use SDSs as guidance when developing HazCom training.
Make HazCom training specific and relevant to the workplace — train workers about how to review a chemicals’ SDS for specific storage recommendations from the manufacturer.
Use safety data sheets to supplement the jobsite hazard analysis
Safety data sheets (SDSs) have a 16-section format. Supervisors should use them to supplement their workers’ safety plans. Here are some examples of how to do this:
- Note the chemical and product names on the SDS. They will be different from each other. Product names might be more recognizable to workers. For instance, workers might not realize that Acetaminophen is also called Tylenol®.
- Use health hazard information to identify sources of exposure to workers. For example, a chemical might harm a worker’s body if it comes into contact with their eyes or a worker inhales a fume. Employers can use this information to implement controls.
- The first-aid section in the SDS will describe what a contractor should do if an employee has exposure to the chemical. Jobsites can use this information to ensure an offsite medical facility or first-aid supplies are readily available.
- Use PPE and housekeeping information to support other control measures used to protect workers. PPE should be a jobsite’s last line of defense to protect workers from hazards. Proper housekeeping contributes to a safer working environment.
- Using proper storage requirements will help contractors safely store chemicals at their projects so workers can avoid accidental exposure to them.
Store SDSs in a binder or make them accessible to workers online. Supervisors should remember that workers need to have access to SDSs. If workers will be using an online database, ensure they know how to access it.
Using an online SDS database may not be possible for certain jobsites if the project is in a remote area where internet access isn’t available or reliable. In these cases, use a jobsite binder to manage the SDSs, and it should be kept in a shared area for all workers to access them easily.
Key to remember: Jobsites must understand how to use HazCom GHS-compliant labels, and they must train their workers about how to avoid exposure to chemical hazards.
