Hazard Communication in MPS
Today’s blog topic will focus on the Hazard Communication Standard
(HCS) from the Occupational Safety and Health Administration (OSHA) and
Maryland Occupational Safety and Health (MOSH) in the workplace.
BUT WAIT!
Don’t close this window. Don’t start yawning. Just reading those
acronyms tends to make most of us a little sleepy. Feel free to grab a cup of
coffee, but come right back and keep reading! Here you will find many resources to make hazard communication compliance in
your facility a little easier.
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Background Information
OSHA has outlined a set of standards for hazard communication that
must be followed to ensure safety in the workplace. This includes a
“Right-To-Understand” standard for employees.
MOSH uses similar standards as those set by OSHA, but also applies
regulations specific to the State of Maryland to accomplish the same safety
mission.
Under MOSH guidelines, a hazard communication program must be set
up to inform workers of safety hazards and to advise them of protective measures
to take in order to create safe work spaces. The program must include all of the following elements:
- Hazard
classification
- Safety
Data Sheets
- A
chemical information list
- Employee
training
- A written hazard communication program
The Maryland Park Service has facilities located throughout the entire state. Due to the wide geographic span and variations in procedures, each park/complex should have a hazard communication program in place that is specific to its location. Unfortunately, one standard statewide plan cannot be functional for all facilities.
How to comply
In order to design a program compliant with MOSH standards, there
are 11 steps to complete. The steps are outlined briefly on this page, but are
provided with more detail in the following brochure:
**Please take note: the brochure above states that a chemical
information list must be sent to Maryland Department of the Environment (MDE).
Current legislation advises that this step is no longer necessary, so it has
been deleted from the list below.**
- Make
an inventory of all materials.
- Obtain
Safety Data Sheets (SDS).
- Use the information on the SDS to determine the
chemical name and to identify the hazards of the substance.
- Prepare a chemical information
list. (See pages 9-13 for a template and instructions
to get started. Also check out the sample below from South Mountain Recreation Area. The full document is available as an attachment on the Resources page of the training division website.)
- Develop
a system for updating the list.
- Conduct
a hazard assessment.
- Check
to see that all containers are labeled using GHS standards. (Pictograms are required.)
- Develop
an employee training and notification program. (See pages 14-22 for specific instructions.)
- Train
and educate employees.
- Document
the training given.
- Develop a written hazard communication program. (Check out pages 23-32 for a template and instructions to get started. Another great example from South Mountain Recreation Area can be found as an attachment on the Resources page of the training division website.)
Education and Training
One of the most important aspects of a good hazard communication
program is continuous education. The many staffing changes that occur in our
parks can impact the transfer of this important safety information from year to
year.
The easiest way to find out if your program is current and
effective is to ask other staff members questions about it: Do they know where
SDS are kept in the park? Have they ever received formal or informal training
about how to properly label hazardous chemicals or how to read those labels? If
ANY staff (including seasonal/contractual employees) are unable to answer these
questions, a training program needs to either be created or revised to include
accurate information.
Some resources for developing your park hazard communication training program are below:
OSHA Draft Model Training Program for HCS
OSHA Training Videos
https://www.ceiwc.com/iwif-state-of-maryland/index.html
Username: bethany.watts@maryland.gov
Password: Safetyflicks1
After logging in, click "I Agree." You will be taken to the Chesapeake Employers Insurance website, where several Hazard Communication videos are located under the "My Library" tab. The username and password for this site can be shared with your staff for access to the videos.
Keep in mind that the online GHS for Hazard Communications Moodle
training provided by MPS does not cover all of the information necessary to
have a complete training program. While it is a good resource to use as a
starting point, each facility also needs to educate employees on:
- Specific locations of SDS in your park
- Proper
chemical handling
- Park-specific
chemical information list
- Location and proper application of PPE
The importance of a comprehensive hazard communication program cannot
be overstated. Implementation of a good plan protects the park from possible
fines after a compliance inspection, saves valuable time for important
projects rather than correcting violations, creates less paperwork
due to fewer incidents on the job and, most importantly, establishes a safe
work environment and safe practices.
Phew! That wasn’t too bad, was it? You’ve probably had just enough
time to finish that cup of coffee and can now start thinking about your park/complex-specific Hazard Communication Program.
Resources
If you have additional questions regarding MOSH, OSHA, or Hazard
Communication programs, check out some of the links below.
MOSH general info:
Free consultation services:
MOSH contact list:
OSHA Small Entity Compliance Guide:
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