Hazard Communication Compliance
Course Number: 502
Course Contents
Introduction
The use of chemicals is an unavoidable component of almost every aspect of life. These chemicals are produced in workplaces and are used in workplaces downstream, including oral healthcare settings. While these chemicals have utility and benefits in their applications, they also have the potential to cause adverse effects or events. These adverse effects or events include health hazards, physical hazards, and hazards not otherwise classified.
No one knows exactly how many chemicals may be present in workplaces. The total number of chemical substances that have been developed and registered in the Chemical Abstracts Service Registry exceeds 60 million and the last 10 million of those were added in less than two years. In addition, most chemical substances are formulated into mixtures and the exposure of workers to unique chemical mixtures is far greater than the number of individual substances.
In order to protect workers from hazardous chemicals and to reduce related illnesses and injuries, employers need information related to the hazards of the chemicals they use and to recommended protective measures. To assure safe and healthy working conditions, the U.S. Congress enacted the Occupational Safety and Health Act of 1970 to provide platforms for research, information, education, and training in the field of occupational safety and health.1
The Act created the Occupational Safety and Health Administration (OSHA), the Occupational Safety and Health Review Commission (OSHRC), and the National Institute of Occupational Safety and Health (NIOSH). The OSHA sets and enforces workplace health and safety standards; the OSHRC reviews enforcement priorities, actions, and cases; and the NIOSH conducts research and makes recommendations to prevent worker injury and illness.
The OSHA developed a Hazard Communication Standard (HCS), 29 CFR 1920.1200, which was first promulgated in 1983. The latest revision of the HCS, also known as HazCom 2012, was published in the Federal Register on March 26, 2012.2,4 This revision was done to align the U.S. with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The effective date for total compliance with HazCom 2012 was June 1, 2016.
In many states and U.S. territories HazCom 2012 is enforced by the state agency responsible for the OSHA-approved state plan. Some states operate OSHA-approved state programs that only apply to state and local government employees. State plans are identical to or are at least as effective as Federal OSHA standards. The State-by-State Occupational Safety and Health Resource Locator provides program information for specific jurisdictions (Figure 1)3
Figure 1.State-by-State Occupational Safety and Health Resource Locator.
This continuing education course is based on HazCom 2012 and OSHA’s Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals (OSHA 3695-03 2014).2,4 It is advisory in nature and informational in content, it provides assistance to employers (e.g., dental practices) that use but do not produce chemicals, and identifies parts of the rule that are relevant to developing and implementing an effective