Safety in the Chemistry Laboratory
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Hazard Communication (HazCom)

The Hazard Communication Standard

The Occupational Safety and Health Act of 1970 established the Occupational Safety and Health Administration (OSHA) within the US Department of Labor. The original Act included language to the effect that employees should be apprised of all hazards to which they are exposed on the job. In the early 80's, OSHA implemented this instruction by enacting the Hazard Communication Standard (HCS) as 29 CFR 1910.1200. (What is all this CFR stuff, anyway?) The HCS became effective in 1986. A fundamental premise of the HCS is that employees who may be exposed to hazardous chemicals in the workplace have a right to know about the hazards and how to protect themselves. For this reason, the HCS is sometimes referred to as the Worker Right-to-Know Legislation, or more often just as the Right-to-Know law. Although the original HCS applied only to the manufacturing industry, subsequent court challenges have modified the scope of the law so that today the HCS applies to nearly all sectors or the work force.

The Hazard Communication Standard sets forth guidelines and requirements in six areas:

1. Chemical Labeling   29 CFR 1910.1200 (f)

   Requires that all chemicals in the workplace be labeled. The information which must be present includes the name of the chemical and warnings about any hazards the material may present. This requirement may be implemented in a variety of ways. Two such systems are the NFPA Hazard Identification System and the Hazardous Materials Identification Guide
2. Material Safety Data Sheets   29 CFR 1910.1200 (g)

   An MSDS is a document that gives detailed information about a material, including any hazards associated with the material. MSDSs must be immediately available to employees at locations where hazardous materials are used. See the linked page for more information.
3. Hazard Determination   29 CFR 1910.1200 (d)

   Says that the employer must identify and maintain a list of all hazardous chemicals used in the workplace.
4. Written Implementation Program   29 CFR 1910.1200 (e)

   Mandates that the employer develop a written plan, the Hazard Communication Program, detailing how the requirements of the HCS are implemented by the employer. The Hazard Communication Program for the University of Oregon is available through the Office of Environmental Health and Safety (EHS).
5. Employee Training   29 CFR 1910.1200 (h)

   Requires that the employer provide to the employees training covering handling of hazardous materials, use and interpretation of both MSDSs and hazcom labels, and information about the HCS.
6. Trade Secrets   29 CFR 1910.1200 (i)

   Sets forth the conditions under which a manufacturer may withhold information about a material, and the conditions under which such information must be divulged to health care providers.

HazCom at the University of Oregon

As students, you are not, technically, employees of the University (unless, of course, you also have a job working for the UO). Strictly speaking, the HCS applies only to communication between employer and employees. Regardless of this, your safety is important and you should have access to the same information provided officially to employees under the HCS. For this reason, all chemical containers you encounter in lab are labeled in accordance with the HCS, and MSDSs are available in the lab. Additional information, including the text of the Hazard Communication Program and a training video are available to you through the Office of Environmental Health and Safety.

In this discussion, references have been made to OSHA, the federal agency. In fact, the State of Oregon also has such an agency, the Department of Consumer and Business Services, Oregon Occupational Safety and Health Division. The University's Hazard Communication Program was written to comply with the OR-OSHA Hazard Communication Standard. However, the Oregon HCS is based on the federal HCS, and differences between the two are minor. If you need to know specifics, the Oregon Standard is available on campus in the Law and Knight libraries, and through the Office of Environmental Health and Safety. The full citation is:

The 1997 compilation of the State of Oregon OARs is on-line, including OAR 437 Division 2 (titled General Occupational Safety and Health Rules). Note that OAR Chapter 437 adopts by reference in their entirety both 29 CFR 1910.1200 and 19 CFR 1910.1450 (described below). For details, see Oregon Rule 437-002-0360.

As an added complication, the Hazard Communication Standard (1910.1200) does not apply to certain kinds of laboratories. Laboratories, such as the teaching labs and research labs in the Department of Chemistry are actually covered by the Occupational Exposure to Hazardous Chemicals in Laboratories standard, (29 CFR 1910.1450). This standard is also know as the "Chemical Hygiene Standard". It is a more technical standard than the HCS, and includes additional material, such as requirements having to do with the proper maintenance of fume hoods and other safety equipment. As students in a chemistry laboratory course at the University, you shouldn't need to worry about the distinction between the HCS and the Chemical Hygiene Standard. The MSDSs, chemical labels, and other compliance measures that you will encounter ought to be exactly the same regardless of which standard technically covers your situation.

OSHA Fact-Sheets

The United States OSHA maintains a number of fact sheets, some of which are relevant to this topic.

• 93-26: Hazard Communication Standard
• 95-35: Employee Workplace Rights and Responsibilities
• 95-33: Occupational Exposure to Hazardous Chemicals in Laboratories
• 92-08: Protect Yourself with Personal Protective Equipment
• 93-03: Eye Protection in the Workplace
• 92-15: State Job Safety and Health Programs

Alphabet Soup -- assorted acronyms

Dealings with the government, or indeed with any bureaucracy of more than modest size, seem to leave one awash in acronyms. Alas, learning about Hazard Communication is no exception. Collected here are various acronyms associated with this discussion. A more comprehensive list is also available.