THE PROBLEM: Section 1910.1200(e)(1) of the OSHA Hazard Communication standard requires employers to “develop, implement and maintain” a written hazard communication program (HCP) at each workplace. This requirement will continue when the new GHS rule goes into full effect. But between now and June 1, 2016, you’ll have to make revisions to your HCP to reflect the changes required by GHS.
HOW TOOL HELPS SOLVE THE PROBLEM: The following Checklist lists the basic elements that an HCP must include. Using the Checklist will enable you to verify that there’s nothing important missing; the boldfaced items are elements required to comply with GHS rules. Make sure you add any site-specific elements you include in your own HCP, e.g., safe work procedures for handling different kinds of hazardous chemicals.