The majority of employers in the United States would not argue the point that the Hazard Communication Standard (HCS) has cost their company an incredible amount of time, money, and grief since its inception. Though it is a great concept, I question whether the HCS, even after more than 20 years in existence, has produced more than a few positive results in the eyes of most employers and employees.
To make my point, let's examine the opening paragraphs of 29 CFR 1910.1200, appendix E, which are very positive and encouraging remarks.
The Hazard Communication Standard is based on a simple concept: that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse eff ects from occurring. The HCS is designed to provide employees with the information they need.
Knowledge acquired under the HCS will help employers provide safer workplaces for their employees. When employers have information about the chemicals being used, they can take steps to reduce exposures, substitute less hazardous materials, and establish proper work practices. These eff orts will help prevent the occurrence of work-related illnesses and injuries caused by chemicals.
These statements give one the impression the HCS will be the easiest and most successful safety program any company ever will institute on behalf of its employees. In fact, you would wonder why every employer in America doesn't enthusiastically embrace the HCS as a best business practice. Unfortunately, the financial burden placed on companies attempting to comply with this standard have been staggering, while the rate of chemical source illness continues to grow each year and employees still don't buy it.
One of the major components of the HCS requires employers to maintain a current list of their hazardous chemicals (chemicals and mixtures that contain physical and health hazards) in their workplaces. Many employees consider this task to be an exercise in futility, while employers consider it to be expensive and time consuming, producing very few measurable results.
Certainly, it is important to maintain an accurate list of all of the chemicals in a workplace that pose a potential risk to employees. However, if that list is not accurate and does not refl ect the associated risks in a manner that employees understand, then it is just a list, and it never will increase employee awareness or reduce workplace exposures.
Let's be practical: creating and maintaining a chemical list does not make a workplace safer — but it is also impossible to have a safer workplace if half of the required data is missing. And if the list or inventory does not identify the hazards associated with the chemicals, once again, it is just a list. And employees will not support any program they feel does not work for them.
Material Safety Data Sheets, one of the cornerstones of the HCS intended to provide employees with the valuable information and knowledge mentioned in Appendix E, are technical and confusing to most employees. Therefore, most never look at an MSDS except to place it in a yellow binder on a shelf. The question, then, is how an employer possibly can provide the knowledge needed to create a safer workplace environment by simply maintaining a chemical list and a corresponding MSDS.