Although HazCom 2012 does not have specific requirements for periodically updating the written HazCom program, it must remain current and relevant.4 As new chemicals are introduced or old chemicals are eliminated from the workplace, the list of hazardous chemicals must be updated. The new inventory is then used to ensure that relevant SDSs are on file. In addition, designation of people to handle different parts of the program must also be current and accurate.
HazCom program coordinators should routinely walk around the workplace to check that containers are labeled as required and that workers are following established work practices to protect themselves from chemical exposure. Proactive monitoring of the workplace is critical to ensure compliance with HazCom 2012. The HazCom program should be revised to address changed conditions in the workplace (e.g., new chemicals, new hazards, etc.)