Learn the Standards and Identify Responsible Staff

OSHA provides online access to the full regulatory text of HazCom 2012, as well as guidance, interpretations, and other relevant materials on its hazard communication website.2,4,5 The provisions of HazCom 2012 that apply to oral healthcare settings are found primarily in paragraphs (e), (f), (g) and (h); other parts, such as paragraph (c), may provide additional guidance on understanding the requirements (Table 2).2,4

Table 2. Organization of HazCom 2012 Regulatory Requirements.4
Paragraphs of the Standard Appendices to the Standard
(a) Purpose Appendix A, Health Hazard Criteria (Mandatory)
(b) Scope and Application Appendix B, Physical Hazard Criteria (Mandatory)
(c) Definitions Appendix C, Allocation of Label Elements (Mandatory)
(d) Hazard Classification Appendix D, Safety Data Sheets (Mandatory)
(e) Written Hazard Communication Program Appendix E, Definition of “Trade Secret” (Mandatory)
(f) Labels and Other Forms of Warning Appendix F, Guidance for Hazard Classifications re: Carcinogenicity (Non-mandatory)
(g) Safety Data Sheets
(h) Employee Information and Training
(i) Trade Secrets
(j) Effective Dates

In order to have a successful HazCom program, workplace personnel should be engaged both in initial and ongoing activities needed for compliance. To address all of the necessary components of an effective program, responsibility for overall program management should be assigned to a HazCom Coordinator. The HazCom Coordinator may then identify additional staff to be responsible for specific activities (e.g., on-the-job training).