It is interesting that in the 29CFR 1910, there are 2 parts that have similar, yet vastly different relationships.  Both parts deal with hazardous materials but the difference is only one (1) zero or is it?  1910 part 120 is the regulation for hazardous waste operations and emergency response, and 1910.1200 is the compliance regulation for hazardous communications. 

Hazardous communications almost always is in the top 5 of most frequently cited standards of OSHA violations.  The most common citation is for failing to have a written program 1910.1200(e) and failure to train employees 1910.1200(h).

So what does this mean?  Employers are required to have an updated MSDS (Material Safety Data Sheet) book on ALL hazardous chemicals/materials in the workplace.  The book should be available to all employees who work with these hazardous materials.  Each time a new or changed hazardous material enters the workplace the MSDS book should be updated.  In addition, all hazardous materials must be properly labeled with a similar 3 or 4 part hazardous label similar to the ones seen above.  Some labels include proper PPE (personnel protective equipment) to be worn when working with this hazardous material.

Another key part of the Hazardous Communication standard is the training.  The training 1910.1200(h)(3) shall include at least:

• Methods and observations to detect the presence or release of a hazardous material in the work area.
• Physical and health hazards of hazardous materials in work area
• Measures take for protection.
• Information including how to use the hazardous labels, MSDS sheets and where employees can get information.

To avoid compliance issues with the Hazcom standard, start with a hazardous materials audit and develop you policies and procedures.  Next write a Hazcom program that includes training, and then do the training.  Remember, every time a hazardous material changes or is introduced into the workplace, or a new employee is put into that environment you must train or retrain all involved.  Avoid the problems and avoid the fines.  Write the program and do the training.