Workplan – Hazard Communication/WHMIS
As a supervisor, you need to be aware of and provide information about hazardous chemicals to which employees (and any contractors) may be exposed at the workplace. Use these steps along with your hazard communication/WHMIS plan to keep you workers safe from obvious or hidden chemical hazards.
There are FIVE elements of a Hazard Communication plan.
1: CHEMICAL INVENTORY
Knowing what chemicals you have in the workplace is essential to being able to communicate hazards to your employees. If you operate in multiple areas, develop an inventory list for each area as they may contain different types of hazardous chemicals. The inventory list needs to be updated when new products are introduced into the work area, and if those new products pose a new safety hazard – ALL EMPLOYEES MUST BE TRAINED ON THIS NEW HAZARD.
All chemicals require a hazard assessment too. Once you have evaluated the hazards, you need to communicate to your employees with a written hazard communication. You are also required to properly label and provide SDS (safety data sheets) for each hazardous product.
An SDS (safety data sheet) must be obtained for each hazardous product BEFORE it can be used. All distributors and manufacturers are required by law to provide an SDS upon request.
Your SDS need to be readily available to all employees working in the area of the hazardous chemicals, no matter what shift. Electronic SDS are an alternative to paper copies, so long as there is no barriers to immediate access. When a new product is added, you need to have the SDS, when a product is no longer actively used, it can be removed from the active file and placed in a file of inactive products. Your inactive file must be maintained for 30 years.
GHS Safety Data Sheets contain 16 sections including the following:
- Hazard(s) Identification
- Composition/Information on ingredients
- First aid measures
- Fire-fighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/Personal Protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information*
- Disposal considerations*
- Transportation information*
- Regulatory information*
- Other information
Employers are responsible for ensuring hazardous products in the workplace are labelled and if not labelled, must provide them where appropriate.
The supplier label is a quick reference for anyone that is using or moving the hazardous product and must contain the following:
- Name, Address, Telephone Number
- Product Identifier
- Signal Word
- Hazard Statements
- Precautionary Statements
Labels are never to be removed or defaced. If a label is unclear or torn and missing information, it must be replaced immediately.
A workplace label is required when a hazardous product is made at the workplace and used in that workplace, when a hazardous product is poured or transferred into another container or a supplier label becomes lost or unreadable.
Every work task where workers are exposed or have the potential to be exposed to hazardous chemicals, including non-routine tasks, needs to be evaluated to determine the appropriate measures of protection. Appropriate measures can/should include engineering controls and personal protective equipment (PPE). If the hazard assessment determines that PPE is required to protect employees, the company is responsible for providing such equipment at no cost.
- PPE must properly fit each affected employee
- You must enforce the requirement that affected employees use PPE
- Ensure PPE is properly maintained and cleaned
- Replace ppe when it is lost or damaged
If an employee provides their own custom PPE, you must inspect it to ensure it complies with safety standards. PPE inspections should be done on an as needed basis or at least annually.
Each employee is required to receive training on the hazards in the workplace.
In both the US and Canada, if a workplace uses hazardous products, there must be a HazCom/WHMIS program in place and any workers who work with or may be exposed to a hazardous product as part of their work activities must learn about the hazard information for these products.
Refresher training is expected to be offered as needed, but best practice dictates an annual refresher for already trained employees.
Employees are required to be trained prior to working with hazardous products, which could pertain to a new employee or a new product.
Employee training should include:
- Policies and procedures related to the Hazard Communication Plan
- Location of the unit’s written HCP
- Location of SDSs
- How to read and interpret an SDS
- Physical and health hazards of hazardous chemicals in their work area
- Work practices that may result in exposure
- How to prevent or reduce exposure to hazardous chemicals
- Proper selection and use of personal protective equipment
- Methods to determine the presence or release of hazardous chemicals
- Procedures to follow if exposure occurs
- Emergency response procedures for hazardous chemical spills
- Non-routine task training (i.e. confined space entry)
- Results of any monitoring done within the work area.
Upon completion of the training program, each employee shall sign a form documenting that he/she has received the training.