All companies whose employees are exposed to hazardous chemicals are required to have a hazard communication plan. This means if you work with chemicals like form release agents, curing compounds, chemical admixtures, silica hardeners, or patching materials, your company is covered by this requirement. In fact, it would be difficult to think of a situation where any construction company would not be required to comply with this OSHA regulation.
To meet the requirements, a company must have a written hazard communication plan that complies with 29 CFR 1910.1200. The standard is flexible and performance-based, intending for each company to adapt the rules to meet the needs of its workplace. The written plan should be a blueprint to the implementation and operation of the plan and must include details on how employees will be trained in the proper handling of chemicals, how chemical safety data sheets (SDSs) will be collected and stored, and how they will be made available to employees.
In 2012 OSHA published a new Hazard Communications Standard (HCS). This standard applies equally to construction and general industries and is also known as the Right To Know, the new GHS standard, and the Safety Data Sheet standard. This is not a new regulation; it has existed since 1994. But this new version has some updates, changes, and a new, more stringent requirement for labeling containers that hold hazardous chemicals. The publication of these revisions makes this a good time for all companies to evaluate their existing hazard communication plans while making the changes needed to bring them current with the new standard.
In the know
The HCS has been called the Right To Know standard because it gave employees the absolute right to know about the hazards associated with using chemicals in the workplace. The new standard has been called the Right To Understand because it adds a level of standardization to the labeling and SDS requirements intended to make it easier for everyone to recognize the basic hazards of any chemical they may encounter in the workplace.
The new standard does this through using the Globally Harmonized System for chemical hazard classification, or GHS. This system, formally adopted by the U.S. and many other countries, establishes chemical hazard categories (such as flammable, explosive, poisonous), standardizes the format of all Safety Data Sheets (formerly known as Material Safety Data Sheets), and requires standard product labels that employ the use of standard pictograms intended to give quick visual cues to anyone that might use the chemical. This change in labeling requirements will impact the concrete construction industry and will force us to think about how we store and use things like form release agents and curing compounds.