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Hazard Communication Compliance and Waste Management

Course Number: 697

Introduction

The use of chemicals and creation of waste are unavoidable components of almost every aspect of life. 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 including health and physical hazards.1

No one knows exactly how many chemicals may be present in workplaces. The total number of substances that have been registered in the Chemical Abstracts Service Registry exceeds 270 million. 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.1

To protect workers from hazardous chemicals and to reduce related illnesses and injuries, employers need hazard information and to recommended protective and disposal 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.2

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 (HazCom Standard), 29 CFR 1910.1200, which was first promulgated in 1983. The latest revision of HCS was published on May 20, 2024 and took effect on July 19, 2024.2 This revision was done to align the U.S. with the 7th edition, and select provisions of the 8th edition, of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS), and international trading partners. The Health and Safety Specialists in each office need to familiarize themselves with the updates in labeling and reclassification of any aerosols, desensitized explosives or flammable gases used in their facilities. In addition, employees should be updated with training on these updates to ensure continued adherence to safety recommendations.3

In many states and U.S. territories HCS 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.2 State plans must be equal to or at least as effective as Federal OSHA standards and abide by the same classification systems for labels and SDS.2 The State-by-State Occupational Safety and Health Resource Locator provides program information for specific jurisdictions (Figure 1).

ce697 - Figure 1

Figure 1.State-by-State Occupational Safety and Health Resource Locator.