Nearly everyone involved in the manufacture, transport, distribution, and use of hazardous chemicals has at least some responsibilities under HCS.

Chemical Manufacturers need to evaluate the chemicals and any components of chemical products they produce to identify potential hazards, and then must create and distribute appropriate warning labels and material safety data sheets (MSDSs) along with any chemicals they ship to importers, distributors or end-users.

Importers and Distributors must also supply labels and MSDSs along with any hazardous chemicals they ship to end-users. If, for whatever reason, they are not able to secure an MSDS from the chemical manufacturer, then the responsibility is theirs to create and transmit all necessary labels and MSDSs.

End-users and Employers responsibilities consist of five key components:

• Creating and Maintaining a Written Plan
• Chemical Inventory
• Proper Use of Labels & Warnings
• Material Safety Data Sheets
• Training

For an expanded discussion of the five key components of employer responsibilities, read the Safety Manager To-Do List under the next tab.

Written Plan — You must have a written plan for your HCS program. This plan should be reflective of your workplace and the hazards that your employees face in their day-to-day working environment. It must describe how your facility meets the requirements for labeling, MSDS management and training. Keep in mind, the written plan is the first thing an OSHA inspector will ask for, so you’re going to have to write it down.

Chemical Inventory — The written plan needs to include a current list of all hazardous chemicals. A properly maintained MSDS library can be used to quickly create a chemical inventory. A good electronic solution, on the other hand, can not only quickly print out a list of chemicals in the workplace, it also tracks where those chemicals are located and it what quantities.

Labels & Warnings — All of the chemicals listed in your inventory must be labeled properly and appropriate hazard warnings must be posted in your work areas. Make sure that products shipped into your facility have labels that are legible and prominently displayed. Also, if you re-bottle or re-drum hazardous chemicals at your facility, it is critical that you have a good secondary label program to ensure the chemicals are properly identified. Note: Label requirements under GHS are substantially different than what the HCS traditionally required. GHS labels use six standardized elements: product identifier, manufacturer information, signal words, pictograms, hazard statements, precautionary statements.

Material Safety Data Sheets (MSDSs) — Think of MSDSs as industrial-strength safety labels telling you everything from the hazards associated with a chemical, how to handle and store the chemical, to the proper personal protective equipment to use when handling the chemical. You must have MSDSs for all the chemicals in your inventory. You must make the MSDSs readily accessible to your employees. And your employees must be trained on where to find and how to read MSDSs so they fully understand the risks associated with the chemicals and the protection they need to use when handling chemicals in the workplace. Note: Under GHS, MSDSs are referred to as safety data sheets (SDSs) and have a 16 part format in fixed order. HCS alignment with GHS necessitates the revision of all SDSs. Employers should expect to update their entire safety data sheet library over the next few years.

Training — The HCS requires that you train your employees on where to find your written plan and MSDSs. And, more importantly on how to read the MSDSs, labels on containers and warning signs. Make sure employees are trained before assigning them to work with hazardous chemicals. Note: HCS alignment with GHS requires additional training for all employees covered under HCS.

• Have an HCS Plan
• Review and Updated it as Needed
• Designate an HCS Coordinator
• Prepare for OSHA Inspections (via Mock Inspections)
• Keep an Eye on GHS
• Identify All Hazardous Chemicals
• Properly Label Containers, Tanks, Pipes, etc.
• Know Reporting and Regulatory Obligations, e.g., Tier II, DHS, California Prop 65
• Monitor Chemical Quantities
• Substitute Safer Chemicals when Possible
• Maintain MSDS for all Chemicals
• Make MSDSs Available to Employees
• Must Have MSDSs in English
• Archive MSDSs for 30 Years from Discontinuation of Use as Part of Medical and Exposure Records Standard (1910.1020)
• Train Employees on:
  • What Chemicals are in Workplace
  • Proper Use and Storage of Chemicals
  • How to Find and Read MSDSs
  • Use of PPEs