Paragraph (e) of HazCom 2012 requires employers to prepare and implement a written HazCom program.2 The main intent is to ensure compliance with paragraphs (f) Labels and Other Forms of Warning; (g) Safety Data Sheets; and (h) Employee Information and Training.2,4 There are no requirements for the format, but it should contain a policy statement (Box A) followed by a hierarchical, customized plan applicable to a specific workplace (Boxes B to G).4
Written HazCom 2012 Program
Section A: Policy Statement
To ensure that information about the dangers of all hazardous chemicals used by (Name of the Employer) is known by all affected workers, the following HazCom program has been implemented. Under this program, workers will be informed of the requirements of HazCom 2012, the activities where exposure to hazardous chemicals may occur, and how workers can access this program, as well as labels and SDSs.
This program applies to any hazardous chemical which is known to be present in the workplace in such a manner that workers may be exposed to under normal conditions of use or in a foreseeable emergency. All work areas that involve potential exposure to hazardous chemicals are part of the HazCom program.
(Name of responsible person and/or position) is the HazCom program coordinator, with overall responsibility for the program, including reviewing and updating this plan as necessary.
Copies of the HazCom program are available upon request in (identify location) for review by any interested parties such as workers, their designated representatives, and OSHA.
Develop and Maintain a List of Hazardous Chemicals
Paragraph (e)(1) of HazCom 2012 mandates that employers develop and maintain a list of hazardous chemicals known to be present in the workplace.2,4 Manufacturers and importers of hazardous chemicals are required to provide labels on all containers shipped. It is also mandated that each label include a product identifier (i.e., the common, chemical, or brand name of the product). A practical approach to develop and maintain the list is by using the product identifier.
HazCom covers all forms of chemicals (i.e., liquids, solids, gases, vapors, fumes, and mists), whether “contained” or not. If there is no potential for exposure (e.g., the chemical is inextricably bound and cannot be released), the chemical is not covered by the standard, but remember to include chemicals that are generated during work operations. For example, the fume or vapor from a chemical sterilizer is a source of hazardous chemicals (e.g., formaldehyde).
Section B: List of Hazardous Chemicals
A list of all known hazardous chemicals in the workplace is attached to this document. This list includes the name of each hazardous chemical and the work area(s) in which they are used.
Additional information on each hazardous chemical may be obtained from the labels on the containers and the SDSs, located in (identify location).
When a new hazardous chemical is received, this list is updated within (x) days. To ensure that the list is updated in a timely manner, the following procedures shall be followed:
Identify procedures to be followed
The hazardous chemical inventory is compiled and maintained by (Name of responsible person and/or position and telephone number).