ASSOCIATIONINSIGHT
Portable Sanitation Association International News
BIWEEKLY EDITION JANUARY 6, 2021
Page 16
Chemical Labeling Dos and Don'ts…continued from page 15
Next, be sure you are communicating about hazards to your employees in an OSHA-compliant manner. Employers
using alternative labeling systems must ensure that their employees are aware of all information required to be
conveyed under the Hazard Communication Standard (HCS).
If you are ever inspected, OSHA will make a site-specific determination of the effectiveness of your complete
safety and labeling program. Any employer who relies on a secondary type of alternative labeling system, instead
of using manufacturer labels containing complete health effects information will —in any OSHA enforcement action
alleging the inadequacy of the labeling system—bear the burden of establishing that it has achieved a level of
employee awareness which equals or exceeds that which would have been achieved if the employer had used
labels containing complete health effects information.
So:
• Make sure you are training your employees about the chemicals you use in your operation, their hazards, and
how to use them safely.
• If you use secondary labels, make sure you cover this in your training program and document it
• Keep good training records
Remember: OSHA establishes policies and procedures at the federal level. States are required to establish their
own plans, enforcement policies and procedures which are at least as effective—generally meaning "at least
as stringent"—as those set by OSHA. States have the option of adopting identical or different language and
requirements as long as they meet or exceed OSHA's requirements. So, keep in mind that regulations in your state
or county could be more rigorous than those described in this article. Always check them out and comply with
their requirements.
For more information, delve into OSHA's 124 page Directive on HCS enforcement and its advisory letter on
secondary labeling. v
Welcome to our newest members!
AirFresh Industries, Inc.—Stillwater, Minnesota
Tiger Sanitation Services, LLC—Baton Rouge, Louisiana
In nity Consulting & Advisory Group—Orlando, Florida
