How to Develop a Foolproof Manufacturing HazCom Program
If you’ve ever heard someone yell “Fore!” on the golf course, you’ve had a front row seat for hazard communication. But when communicating about potential dangers, the stakes are far higher in your manufacturing plant; there, workers are likely to encounter potentially deadly chemicals or debilitating levels of heat or noise.
That’s why an airtight Hazard Communication Program is absolutely crucial to health and safety in manufacturing. Read on for guidance on how to establish a comprehensive Hazard Communication Program to ensure safety and take a proactive approach to managing risk at your workplace.
What is Hazard Communication?
OSHA’s Hazard Communication Standard (HCS, also called “HazCom”) mandates that employers must inform and train their employees about hazardous chemicals, materials and processes in the workplace. Manufacturers must first evaluate the hazards of chemicals involved in their manufacturing process, before utilizing a labeling system and safety data sheets (SDS) to inform workers. Employers must also conduct regular training for exposed workers so they know how to handle chemicals appropriately.
The goal is always to ensure workplace safety through clear communication about chemical hazards.
What is a Hazard Communication Program?
A Hazard Communication or HazCom Program is the systematic approach that employers take to inform workers about and protect them from hazardous chemicals in the workplace. A successful HazCom Program will include policies, documentation (i.e., labeling and SDS), and training for employees.
7 Necessary Steps to Build an Effective HazCom Program
There are several components to an effective HazCom Program—a written program, a chemical inventory, up-to-date Safety Data Sheets, in-plant labeling, and employee training. We’ll cover each of these items, plus the specific action items that you’ll need to check off to ensure your HazCom Program is effective and thorough.
Step 1. Identify hazards and assess risks.
Before you can actually get started on building a successful HazCom Program, you’ll need to take a step back and identify what the hazards and risks are in your workplace.
Common health & safety hazards include:
- Chemical hazards (e.g., solvents, adhesives, paints, toxic dusts)
- Physical hazards (e.g., noise, radiation, heat)
- Biological hazards (e.g., infectious diseases)
- Ergonomic risk factors (e.g., heavy lifting, repetitive motions, vibration)
- Falls from heights
- Electrocutions
- Accidental release of hazardous energy while maintaining equipment (aka: Lockout/Tagout)
For a HazCom program, you’ll start by performing a chemical inventory to identify all chemical materials that your workers come into contact with. Conduct hazard assessments as well to pinpoint other risks that your employees face.
You can only ensure a safe environment when you know what your workplace hazards are—and what to do about them.
Step 2. Build your Hazard Communication team.
For HazCom to be truly effective, it must be a team effort. Managers and employers don’t need to—and shouldn’t—go it alone.
Identify potential candidates to join the team. Consider employees with safety experience as well as those who are dedicated to creating a safety culture. If you already have a safety committee, this is a great place to start.
When you’ve assembled your team, work with them to designate roles and responsibilities for each member and ensure they are prepared with any necessary training.
Step 3. Develop written Hazard Communication Programs.
Your HazCom team’s first task should be to create written HazCom policies. Every policy needs to articulate objectives for clear communication. After all, the heart of HazCom is communication. A strong program will emphasize the importance of documentation, specifically Safety Data Sheets. SDS need to be utilized, organized, and maintained.
The HazCom team should also focus on what to do when new policies need to be developed or existing policies require updates. Identify specific process steps for policy development.
Step 4. Put an in-plant labeling system into action.
Putting a label on anything dangerous is a straightforward way to keep workers safe. Utilize the Globally Harmonized System (GHS) to standardize hazard labels.
Don’t forget, you’re not just labeling chemicals and products. You also need to customize labels for specific manufacturing processes. Train your employees on how to interpret and understand all the labels in the workplace. This kind of training can’t be one-and-done. Conduct refresher training with regular label-reading exercises.
Step 5. Implement communication protocols.
It’s not enough to create policies and expect nothing to go wrong: accidents can, and will, happen. Make sure your policies include established channels of communication in order to report when a hazardous incident has occurred.
Enact procedures for emergency communications and use technology to your advantage. Consider incorporating digital platforms and mobile apps into your process; they’re a fast way to send out hazard alerts and instant notifications.
Step 6. Hold employee trainings.
Never assume that training is finished. Initial training for new employees is practically rote, but it’s important to develop a training program that also includes periodic refreshers for your current employees.
Training can also be less formalized. Schedule regular safety meetings to raise awareness about manufacturing hazards. Part of the goal of regular training and meetings is to promote a strong safety culture throughout the workplace, which can help reduce accidents.
Step 7. Conduct regular audits.
Don’t wait for OSHA compliance offers to show up at your door. Instruct your HazCom team conduct regular internal audits to ensure your employees are up to speed on training, policies, and procedures. An on-site safety manager or outside consultant can also provide valuable insight on how best to enforce your HazCom and safety policies.
Once you get your audit results, update your programs as needed. Perhaps an audit has uncovered room for improvement, or perhaps your manufacturing process has changed. If an incident occurred, follow up on the lessons learned and adjust your policies. And when regulations get periodic updates, your policies should adapt as well.
Clarify Your HazCom Program With Berg Compliance
A HazCom Program is a basic necessity of manufacturing, but it’s worth going above and beyond with your HazCom policies. Whether you’re just getting started with your program or your existing policies could use a professional refresh, Berg Compliance is ready with solutions.
Book a free strategy call today and discover the best way to implement your HazCom program.
