Question

In addition to compliance with the elements of the HazCom Standard, the Occupational Safety and Health Administration (OSHA) requires that employers develop and implement an effective hazard communication program. Select the HazCom program elements you would measure for compliance and effectiveness, explain how you would measure them, and the criteria you would use to determine both compliance and effectiveness. Your response must be at least 500 words in length.

Answer 1

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In addition to compliance with the elements of the HazCom Standard, the Occupational Safety and Health Administration (OSHA) requires that employers develop and implement an effective hazard communication program. Select the HazCom program elements you would measure for compliance and effectiveness, explain how you would measure them, and the criteria you would use to determine both compliance and effectiveness. Your response must be at least 500 words in length.

There are several elements of the HazCom program that can be measured to ensure that it is, both, effective and compliant with the HazCom standard under OSHA. From my standpoint I would examine the following elements of my program:

· The chemical inventory and the SDS database

· The effectiveness of the chemical labeling – for internal and external chemical containers

· The effectiveness of the employee training

The most important and critical element to the entire program is the chemical inventory. Once the chemical inventory has been established, it should be part of an overall inventory control system. This would tie in with the supply chain to ensure that every chemical that is received in-house has been “entered” into our facility and appropriately scanned and coded. This is what I currently do as I have an Oracle database that provides me with a daily inventory of every chemical on site. We worked with our IT department to create a patch that communicates with our SDS website. This communication between our inventory and our SDS website allows the tow to “marry up” the correct SDS with the chemical and the correct vendor. The system auto-generates a report and I can see, in a few moments, what is showing up in our inventory but doesn’t have a SDS in our web based system. I am then able to either find that SDS through the websites library or I have my purchasing department contact the vendor for the SDS.

Measuring the effectiveness of the chemical labeling is much easier for material coming into the facility than it is for material that we are generating. When material is received by our shipping/receiving, it is reviewed against the SDS and reviewed for appropriate markings. If the material isn’t properly identified, it does not enter our premises but is, instead, placed on a hold. Confirmation is then required from the vendor and the necessary labeling is forwarded and attached to the material. It isn’t as clear cut internally, however, our end product is a bar of soap so we fall under article exemptions. However, the secondary containers are most difficult and we do have several “inspection” teams that conduct walkthroughs to ensure compliance.

The effectiveness of employee training can be measured through the incidents that occur in-house as they relate to the handling of chemicals. Supervisors ensuring that employees wear the proper PPE, employees complying with the program and the many trainings that they’ve had as well as the many assessments that have been completed are all integral to measuring the effectiveness of the program. I think the biggest measurement here is the number of incidents, whether a general spill or an incident that lead to medical treatment beyond first-aid are good points of measure. This can be done by examining OSHA incidence rates, near misses, and so forth. Since we require that every type of incident be reported into our incident reporting system, we have a great deal of data that we can review to measure the effectiveness of our training.

The above-mentioned criteria are evaluated and calculated to create a risk score of the program. With a score of 1 for each category being highly effective to a score of 5 being least effective. The score basically provides a summary of the effectiveness of the written HazCom program and all of its elements. The best score would be a “3” and the worst score would be a “15”. It is important to recognize that any score other than a “3” will require that the entire program be reviewed and revised to ensure that it is maintaining its effectiveness.