OSHA HCS Written Plan?
Hello all,
I am not very familiar with OSHA or their requirements for a written plan. I know it must describe how the plant will meet the requirements of the Hazard Communication Standards and detailed information regarding labeling, procedures, training, etc.
My question- are all chemicals considered hazardous and must be included in the written plan? I have things like hand soap and sanitizer featured in the MSDS but would these be considered OSHA HCS worthy?
If anyone has an example or other resource that would be amazing too!
Thanks
The new GHS that OSHA is now starting is supposed to make the manufacturers determine what is a hazardous chemical. However, it is not until the end of next year that all manufacturers must comply. We should all start seeing the new labels and key words: Danger vs Warning. https://www.osha.gov...zcom/index.html
Keep in mind that even if a manufacturer says it is not hazardous if used as directed, in a food plant this could still be a hazard to food. Although this may be addressed in your food defense plan.
Yes, include them.
Sanitizer can be dangerous; if it's alcohol based it may be flammable.
We also have food ingredients that need SDS and HazCom as we carry Vodka and other alcohol based ingredients.
Labeling should be covered by the label that is already on the package, unless you put it in secondary containers. But you need to include all chemicals in your chemical inventory, SDS/Right to Know station, etc. Even though OSHA is switching to SDS, you will have much longer than a year to comply. I also include GRAS statements for every ingredient that is not hazardous enough to warrant an SDS and is clearly food, even though this is not required.
OSHA themselves have amazing resources available, including FUN brochures on various safety programs. Here's a link to the HazCom one, but they have a bunch! They're here to help! The FAQ will probably answer your questions -
I live in California and CalOSHA came out to visit and helped us identify hazards and fix our documents for free :w00t:
It was a great experience and as someone who works in a factory with moving equipment, I adore :wub: OSHA