Does your facility have a fully functional OSHA Hazard Communication Program?
One of the most effective ways to ensure employee safety is to be proactive. The OSHA Hazard Communication Standard provides guidance on the requirements of all facility owners (and their designated representatives) for employee safety around hazardous chemicals in the workplace.
Most regulations, specifically cannabis, vary widely depending on the state or jurisdiction; however, this standard has been globally adopted to communicate safety precautions for employees who work with and around hazardous chemicals.
The OSHA Hazard Communication Standard includes the usage of a Globally Harmonized System(GHS). This system was enacted in 2012 to ensure consistency in hazard notification warnings and information; regardless of location or industry. The GHS includes criteria for the classification of health, physical, and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals and safety data sheets.
The purpose of the OSHA Hazard Communication is to ensure workplace hazards are communicated to employees. A compliant Hazard Communication program includes 5 tenants:
Chemical Inventory
The chemical inventory contains every chemical’s name, Chemical Abstracts Service registry number (or CAS number for short), common name, and synonyms. It also contains the names of any products or mixtures if applicable, and the percentage of ingredients in each product or mixture.
Safety Data Sheets
An SDS goes into detail about a chemical’s hazards and how to protect yourself. You should consult the Safety Data Sheet when working with hazardous chemical for appropriate PPE usage, first aid response, and other environmental and health information.
Container Labels
Container labels provide a “first line of defense”. Labels must be affixed to any container that holds hazardous chemicals.
Training
Employers are responsible for ensuring that employees receive training on the relevant chemical hazards whenever they begin a new job, or when hazardous chemicals are newly introduced to the workplace.
Written Program
Employers are responsible for assessing the risks in the work environment and creating a written program that details the facility’s compliance with the Hazard Communication Standard. This document, which assigns responsibilities and describes facility specific work procedures, must be made available to all employees and impacted individuals upon request.
Hazard communication is a pretty straightforward standard; and should be applied to safety precautions throughout the facility. Signage should be posted in workspaces where new or changing hazards exist; indicating risks such as slip trips and fall hazards, noise, dust, excessive heat, or other hazards requiring a behavior modification or change in PPE.
Talya Mayfield is the CEO and Principal Consultant for Delta Compliance Consulting. Talya has a B.S. in Biology, an M.S. in Industrial Engineering Management, and a Certificate in Lean Six Sigma. She spent 8 years in cement manufacturing and hazardous waste working on a range of environmental compliance requirements, from improving safety and employee exposure, to hazardous material management and disposal permitting. She has now merged this expertise with her love of all things cannabis, and launched Delta Compliance Consulting to help cannabis operators run safe, compliant and successful facilities. Delta Compliance consultants are certified in Cannabis Compliance and Risk Management, as well as OSHA-30. Contact us and let the certified experts assist you with all your compliance and risk management needs.