Navigating the revised Hazard Communication Standard
Adjustments can be difficult. They’re even tougher with a negative attitude.
By Michael Wayne
Twelve years ago, the Occupational Safety and Health Administration (OSHA) released a revision of its Hazard Communication Standard. Early on, there were issues, confusion, and frustration enough for organizations to fail to comply with aspects of the standard—some blatantly.
The issues, confusion and frustration have hardly abated. My loss control colleagues will attest that, next to fall-protection violations, HazCom violations are regularly OSHA’s highest penalized areas.
This month, OSHA’s latest revision of its Hazard Communication Standard is set to go into effect. Not everyone is happy about that … for various reasons.
Paramount for OSHA, this go-around was the desire to better align its Hazard Communication Standard with the United Nations’ Globally Harmonized System of Classification. Unquestionably, this update will primarily affect chemical manufacturers, importers, distributors, and downstream users as well. The latter will have to update—or put in place—training protocols regarding the handling and storing of products.
The revised standard also calls for greater revelation regarding what is actually being made, handled, and stored. In short, OSHA is compelling manufacturers to divulge the chemical makeup and concentration of their products.
Manufacturers contend this will mean having to reveal trade secrets. OSHA’s counter to that, as it has been for some time, is that employees and emergency healthcare workers are safer when they better understand exactly what they are dealing with in everyday and crisis situations.
If you have a client that is a chemical manufacturer or you have a client that falls under the downstream category, hopefully you have been preparing them for these OSHA changes since before they were announced. If not, however, here are the top five actions you can have your client take to navigate OSHA’s revised Hazard Communication Standard.
Get trained. Your client must have one or more employees they are willing to make OSHA experts or they have to rely upon you to relate the proper information to their employees to ensure they are compliant. If you are not a trained loss control specialist, this duty should likely fall to someone in your organization who is.
Training for those who work with hazardous chemicals, or could potentially come into contact with them, is required. OSHA already has necessary training materials, offers training grants to nonprofit organizations, and offers training via authorized education centers. For more information in that regard, visit OHSA’s training site at osha.gov.
Practice practical application. Although no two organizations are exactly the same, many do share commonalities. As such, it doesn’t hurt to find a model organization and port their practices and procedures into the daily operations of another.
Regardless of the amount of training, it means nothing if it doesn’t go beyond a seminar or classroom setting. Taking the training and extrapolating out what it is intending to teach is necessary. In this instance, what organizations expose their employees to in their respective work environments can differ.
Training has to be tailored, but that doesn’t mean organizations have to approach their own training without a sense of direction. Find a model organization to build off of and work with your client to apply it to their needs. With any luck, you may already have a model organization that you set up a program for previously.
Stay ahead of the curve. Just getting by is commonplace. In business, as it relates to OSHA, you may have a client who meets the minimum standard and is perfectly happy with that. Persuade them to do better. Encourage your client to go beyond the standard with the intention of setting the standard.
While extra expenses may be incurred, including time for training, you have to convince your client that the more they do on the front end to protect their employees and the public from risks, the better off they will be.
Fewer OSHA incidents mean a better, safer work environment. It means less money being spent on fines or lawsuits. It means profit instead of an enhanced possibility of losing the business because of a single incident that may have been preventable.
Lead by example. As previously mentioned, some organizations are dependent upon trade secrets that, if divulged, could lead to their demise. At the very least, profitability could take a massive hit.
Frankly, I empathize with the manufacturers in this instance, but I also completely understand the necessity for employees and first responders alike to know what they are dealing with regarding daily, routine handling as well as in emergency situations.
While consumers may indeed rush toward a lower-priced product, including knockoffs, branding will ultimately win the day. The successful organizations in this space are most likely to be the ones that adapt early and tell the story of how and why they are doing so. Responsibility, fortified with empathy, is the foundation of successful longevity.
Compel your clients to enhance their brand and show the public that they are on the forefront of industry change for everyone’s betterment.
Seek serenity. Your client has to have the serenity to accept the things they cannot change, the courage to change the things they can, and the wisdom to know the difference. In this landscape, there is so much that they can control and new goals that they can set.
Help them to see that and that doing so with a positive mindset, as opposed to fighting everything kicking and screaming, will pay off. Adjustments can be difficult. They’re even tougher with a negative attitude.
These suggestions may come off Pollyanna-ish. The reality, however, is that OSHA is moving forward. Chemical companies and those that benefit from their existence are in business to make money. These rules will unquestionably be a game changer.
Depending upon how your clients decide to play, their experience has one of two outcomes: win or lose. If they lose, you do, too.
The author
Michael Wayne is a freelance insurance writer
