Checklist for Employers and Supervisors:
Develop a written hazard communication program. Federal OSHA’s Hazard Communication Standard requires you to do this if hazardous chemicals are present at your company’s worksites. As part of the program, you must provide education and training to employees, maintain current safety data sheets (SDS) for all chemicals employees are required to use, ensure chemical containers are properly labeled and keep an up-to-date log of all hazardous chemicals used. Include the hazard communication program in the workplace analysis segment of your company’s written safety and health program.
Assign responsibility for coordinating the hazard communication to a particular person. This person should designate other staff members to be responsible for particular activities, such as training.
Train employees who might be exposed to hazardous chemicals. Training must occur before the initial assignment to work with a hazardous chemical and whenever the hazard changes. OSHA’s training requirements are not met solely by giving employees SDSs to read. Training must explain the hazards of each chemical as well as how workers can protect themselves and should include opportunities for employees to ask questions and for the trainer to ensure they understand the information. Training must be conducted in a manner and language employees understand, and you must train temporary and season al workers as well as long-term employees.
Document all training in writing. Have employees sign a logbook containing a description of training, the date, location, and trainer’s name. Keep these logs on file.
Ensure proper labels are prominently displayed on chemical containers. Labels must be in English, and other languages can be displayed in addition. Manufacturers and importers are required to provide labels with: product identifier, signal word, pictograms, hazard statements, precautionary statements, and the name, address and phone number of a responsible party. As the employer, you can use the same label or an alternative that contains, at a minimum, the product identifier and general information concerning hazards. Employees must have access to complete hazard information.
Inspect labels regularly. Make sure information is legible and not faded, washed off or removed in any way. Re-label containers as needed.
Designate someone to read the labels of all new chemical shipments. Labels of chemicals your company regularly uses should be read as well. The dilution rate, PPE required or other instructions might have changed based on new regulations or product reviews, and your company will be in violation if it does not update its practices.
Store SDSs at all company facilities and in a standard location in all company vehicles or another location at every jobsite. You can provide electronic access to SDSs through smartphone apps or online services; however, you must have a back-up system in place in case of a power outage, equipment failure or other disruption of access to the electronic system. You must also train workers to use the electronic system and make sure they can obtain hard copies of SDSs. In an emergency, hard copies of SDSs must be immediately available to medical personnel.
Provide emergency eyewash stations. Per federal OSHA regulations, workers must be able to access these stations within 10 seconds or approximately 55 feet if they get chemicals in their eyes. Portable eyewash stations ideal for landscaping jobsites are available.
Make sure employees know the locations of SDSs and eyewash stations.
Supply and strictly enforce the use of all PPE called for on product labels.
Provide each crew with a jug of water and soap so employees can wash their hands between jobs. This will reduce the risk of chemical exposure that could occur when a worker touches his eyes, face, food, a steering wheel or equipment levers.
Equip vehicles transporting liquid chemicals with spill kits. They should be large enough to contain the number of gallons being hauled. Ensure employees know how to use the kits.
Regularly maintain chemical-application equipment. Also provide crews with spare parts such as clamps and hoses.
Review your hazard communication program periodically to make sure it’s working. Revise the program as needed to address flaws and changing conditions (new chemicals, new hazards, etc.).
Know EPA-regulated pesticide labels might not match OSHA-regulated SDSs. Pictograms could be different, and the signal word on the SDS might not match the signal word on the pesticide label. EPA uses only two pictograms, while the Globally Harmonized System OSHA uses includes additional symbols. “Danger” and “Warning” are the only two signal words that appear on SDSs, while pesticide labels can use the signal words “Caution,” “Warning,” and “Danger.” Management personnel and employees of companies that use pesticides need to understand both systems.