Pub. 2 2013 Issue 2

30 San Diego Dealer H azard Communication Program (HCP) of OSHA is one of the most frequently cited code violations against auto- motive dealers. This program, also known as Right-To-Know in California, requires employers to provide information to employees on hazardous chemicals at the workplace. See http://www.dir.ca.gov/title8/5194.html and 29CFR1910.1200.We stumbled upon a checklist that OSHA provides to their inspectors to audit the HCP at your workplace. So now that we know what they are checking for, it is time to get ready for an inspection! Questions from the checklist are in italics below. To facilitate a quick compliance audit, we have added a possible short answer after each question. 1. Has a list of all hazardous chemicals in the workplace been prepared? A list of chemicals should be available in your MSDS (soon to be SDS) binder. The fact you have all the MSDS available does not mean the list is not required. List is needed. Retain list in the front of your MSDS/SDS binder. 2. Does the company have a method for updating the hazardous chemical list? The consultant or the manager of the program must update the list every 12 months. An updated list is needed. 3. Has the company obtained or developed a MSDS for each chemical used? The MSDS for each chemical should be available in hard copy or on the web portal for each chemical you use under your facility ID. 4. Has a systembeen developed to ensure all incoming hazardous chemicals have labels and data sheets? The purchasing manager aka Parts man- agermust ensure all chemicals have labels and MSDS available. 5. Are procedures in place to ensure labeling for containers of hazardous chemicals? PartsManager toensure chemicals coming inhave labels and shopmanager toensure all secondary containers have labels too. 6. Are employees aware of the requirements of the Haz Comm. Standard and information specific to their workplace? Do employees know where the written program is, where the MSDS is, who to ask questions about HCP and how to read and OSHA INSPECTION Cheat Sheet By Sam Celly