Chemicals are used in many dairy farm operations, and many of these chemicals pose a wide range of health and physical hazards. Chemical exposure may cause or contribute to many serious health effects such as heart ailments, central nervous or reproductive systems, kidney and lung damage, sterility, cancer, burns and rashes. Some chemicals may also pose physical hazards and have the potential to cause fires and explosions and other serious accidents.

Professor / University of Texas School of Public Health
Compliance Assistance Specialist / Wisconsin Eau Claire OSHA Area Office

The Occupational Safety and Health Administration (OSHA) issued the Hazard Communication Standard over 25 years ago to ensure that employers and employees know about chemical hazards in the workplace and how to protect themselves.

In some states, it is called the “Right to Know” law. In 2012, OSHA finalized HazCom 2012 to align chemical classifications and labels under the Globally Harmonized System (GHS). The goal is to reduce the incidence of chemical source illness and injuries.

If OSHA inspects your workplace for compliance with the HCS, the OSHA compliance officer will ask to see your Hazard Communication Program at the outset of the inspection. Hazard Communication citations are always amongst the Top Ten Most Frequently Cited Standards.

What is the Hazard Communication Standard?
The OSHA Hazard Communication Standard (HCS) establishes a uniform requirement to make sure that hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated and that this hazard information is transmitted to affected employers and exposed employees.


The HCS incorporates a “downstream flow of information,” which means manufacturers must determine the hazards associated with each chemical. Chemical manufacturers, importers and distributors must communicate the hazard information and associated protective measures to downstream customers through proper labels and material safety data sheets (MSDSs) or safety data sheets (SDS).

Employers must identify and inventory hazardous chemicals used in the workplace, obtain MSDSs or SDSs, develop and implement a written hazard communication program (HCP) and communicate hazard information to employees.

What are the components of a Hazard Communication Program?
OSHA requires each employer to have a HCP which is composed of five key elements:

1. Written program
The HCS requires all workplaces where employees are exposed to hazardous chemicals to have a written plan that describes how that facility will implement the standard. Preparation of the plan is not just a paper exercise. All of the elements must be implemented in the workplace to comply with the rule.

The written program must describe how the requirements for labels and other forms of warning, MSDSs and employee information and training are going to be met in your facility. The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementing your program and an assurance that all aspects of the requirements have been addressed.

Sample HCPs and other assistance materials may be found at the OSHA website. Although such general guidance may be helpful, you must remember that the written program has to reflect activities that take place on each dairy farm. Therefore, if you use a generic program, you must adapt it to address the specific dairy farm that it covers.

For example, the written plan must list the chemicals present on the farm and indicate where written materials will be made available to employees. The written HCP also may indicate who is responsible for the various aspects of the program in your facility.

2. Hazardous materials inventory
The standard requires a list of hazardous chemicals on the dairy farm as part of the written HCP. The list will eventually serve as an inventory of everything for which you must maintain an MSDS.

At this point, however, preparing the list will help you complete the rest of the program since it will give you some idea of the scope of the program required for compliance in your facility.

The best way to prepare a comprehensive list is to survey the workplace. Purchasing records also may help, and certainly owners and managers should establish procedures to ensure that future purchasing procedures result in MSDSs being received before using a material on the farm. Articles and household-use products are exempt from the program.

Look around the farm and in particular the shop. Identify chemicals in containers, including pipes, but also think about chemicals generated in the work operations.

For example, welding fumes, dusts and exhaust fumes are all sources of chemical exposures. Veterinarian supplies and drugs are included if there is a potential for employee exposure. Read labels provided by the suppliers on hazard information. Make a list of all chemicals in the workplace that are potentially hazardous.

For your own information and planning, you also may want to note on the list the locations of the products within the workplace and an indication of the hazards as found on the label. This will help you as you prepare the rest of your program.

3. Material safety data sheets or safety data sheets
Once you have compiled as complete a list as possible of the potentially hazardous chemicals in the workplace, the next step is to determine if you have received MSDSs for all of them.

Check your files against the inventory you have just compiled. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by copy of a letter or a note regarding telephone conversations.

If you have MSDSs for chemicals that are not on your list, figure out why. Maybe you don't use the chemical anymore. Or maybe you missed it in your survey. Some suppliers do provide MSDSs for products that are not hazardous. These do not have to be maintained. If you have questions regarding the hazard status of a chemical, contact the manufacturer, distributor or importer.

The MSDS is a detailed information bulletin prepared by the manufacturer or importer of a chemical that describes the physical and chemical properties, physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures, and control measures.

Chemical manufacturers and importers must develop an MSDS for each hazardous chemical they produce or import and must provide the MSDS automatically at the time of the initial shipment of a hazardous chemical to a downstream distributor or user. Distributors also must ensure that downstream employers are similarly provided an MSDS.

There is no specific format for the MSDS under the rule, although there are specific information requirements. Under the rule, the role of MSDSs is to provide detailed information on each hazardous chemical, including its potential hazardous effects, its physical and chemical characteristics, and recommendations for appropriate protective measures.

This information should be useful to you as the employer responsible for designing protective programs, as well as to the workers.

Under HazCom 2012, SDSs will replace MSDSs. SDSs will have a standardized format.

MSDSs must be readily accessible to employees when they are in their work areas during their workshifts. This may be accomplished in many different ways.

You must decide what is appropriate for your particular dairy. Some employers keep the MSDSs in a binder in a central location such as the front office. MSDS binders may also be kept in work trucks.

As long as employees can get the information when they need it, any approach may be used. The employees must have access to the MSDSs themselves.

In order to ensure that you have a current MSDS for each chemical in the plant as required, and that you provide employee access, OSHA compliance officers will be looking for the following types of information in your written program:

• Designation of persons responsible for obtaining and maintaining the MSDSs:
• How such sheets are to be maintained in the workplace (e.g., in notebooks in the work areas or in a computer with terminal access), and how employees can obtain access to them when they are in their work area during the workshift
• Procedures to follow when the MSDS is not received at the time of the first shipment
• For producers, procedures to update the MSDS when new and significant health information is found
• Description of alternatives to actual data sheets in the workplace, if used

4. Labeling
Containers of hazardous chemicals must be labeled, tagged or marked with the identity of the material and appropriate hazard warnings. Chemical manufacturers, importers and distributors must ensure that every container of hazardous chemicals they ship is appropriately labeled with such information and with the name and address of the producer or other responsible party.

Dairies which purchase chemicals can rely on the labels provided by their suppliers. If the material is subsequently transferred by the employer from a labeled container to another container, the employer will have to label that container unless it will be immediately used by the employee performing the transfer.

The primary information to be obtained from an OSHA-required label is the identity for the material and appropriate hazard warnings.

The identity is any term which appears on the label, the MSDS and the list of chemicals, and thus links these three sources of information. The identity used by the supplier may be a common or trade name or a chemical name. The hazard warning is a brief statement of the hazardous effects of the chemical ("flammable," "causes lung damage").

Labels frequently contain other information, such as precautionary measures ("do not use near open flame"), but this information is provided voluntarily and is not required by the rule. Labels must be legible and prominently displayed.

With these requirements in mind, the OSHA compliance officer will be looking for the following types of information to ensure that labeling is properly implemented in your facility:
• Designation of persons responsible for ensuring labeling of in-plant containers
• Designation of persons responsible for ensuring labeling of any shipped container
• Description of labeling systems used
• Description of written alternatives to labeling of in-plant containers (if used)
• Procedures to review and update label information when necessary

Dairy owners and managers will primarily be concerned with ensuring that every purchased container is labeled. The most important thing to remember is that this is a continuing task and all containers of hazardous chemicals must always be labeled.

Therefore, it is important to designate someone to be responsible for ensuring that the labels are maintained as required on the containers on your farm and that newly purchased materials are checked for labels prior to use.

5. Training
Each employee who may be "exposed" to hazardous chemicals when working must be provided information and be trained prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes.

"Exposure" or "exposed" under the rule means that an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption) and includes potential (e.g., accidental or possible) exposure.

Information and training may be done either by individual chemical or by categories of hazards (such as flammability or carcinogenicity). If there are only a few chemicals on the farm, then you may want to discuss each one individually.

Employees should have access to the substance-specific information on the labels and MSDSs. Employers must ensure, however, that employees are made aware of which hazard category a chemical falls within.

Information and training are a critical part of the hazard communication program. Workers obtain information regarding hazards and protective measures through written labels and MSDSs.

It is through effective information and training, however, that workers will learn to understand such information, determine how to acquire and use it in their own workplace, and understand the risks of exposure to the chemical in their workplaces as well as the ways to protect themselves.

A properly conducted training program will ensure comprehension and understanding. It is not sufficient to either just read material to the workers or simply hand them material to read.

You want to create a climate where workers feel free to ask questions. This will help you to ensure that the information is understood. You must always remember that the underlying purpose of the HCS is to reduce the incidence of chemical source illnesses and injuries.

This will be accomplished by modifying behavior through the provision of hazard information and information about protective measures. If your program works, you and your workers will better understand the chemical hazards within the workplace.

The procedures you establish regarding, for example, purchasing, storage and handling of these chemicals will improve and thereby reduce the risks posed to employees exposed to the chemical hazards involved.

When reviewing your written program regarding information and training, consider the following items:
• Designation of persons responsible for conducting training;
• Format of the program used (audiovisuals, class room instruction);
• Elements of the training programs
• Procedure to train new employees at the time of their initial assignment to work with a hazardous chemical and to train employees when introducing a new hazard into the workplace.

The written program should provide enough details about the employer's plans in this area to assess whether or not a good-faith effort is being made to train employees. OSHA does not expect that every worker will be able to recite all the information about each chemical in the workplace.

In general, the most important aspects of training under the HCS are to ensure that employees are aware that they are exposed to hazardous chemicals, that they know how to read and use labels and MSDSs, and that, as a consequence of learning this information, they are following the appropriate protective measures established by the employer.

OSHA compliance officers will be talking to employees to determine if they have received training, if they know they are exposed to hazardous chemicals and if they know where to obtain substance specific information on labels and MSDSs.

The rule does not require employers to maintain records of employee training, but many employers choose to do so. This may help you monitor your own program to ensure that you have trained all employees appropriately.

If you already have a training program, you may simply have to supplement it with whatever additional information is required under the HCS.

The training provisions of the HCS are not satisfied solely by giving employee the data sheets to read. An employer's training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area but also how to use the information generated in the hazard communication program.

An employer can provide employees information and training through whatever means found appropriate and protective. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video) and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them.

Furthermore, the training must be comprehensible. If the employees receive job instructions in a language other than English, then the training and information to be conveyed under the HCS will also need to be conducted in a foreign language.

Regardless of the method relied upon, however, the employer is always ultimately responsible for ensuring that employees are adequately trained. If the compliance officer finds that the training is deficient, the employer will be cited for the deficiency regardless of who actually provided the training on behalf of the employer.

In addition to these specific items, compliance officers also will be asking the following questions in assessing the adequacy of the program:
• Does a list of the hazardous chemicals exist in each work area or at a central location?
• Are methods the employer will use to inform employees of the hazards of non-routine tasks outlined?
• Are employees informed of the hazards associated with chemicals contained in unlabeled pipes in their work areas?
• Is the written program made available to employees?

The OSHA website addresses the Hazard Communication Standard and frequently asked questions regarding hazard communication programs.

Future articles
Upcoming articles will address regulatory standards and best practices related to worker safety and health issues such as manure pits, safety training, machinery operation, livestock-handling, emergency preparedness and human resource management. PD

Those with specific questions about complying with health and safety regulations can leave a comment below or click here to email Douphrate directly. Dr. David Douphrate is an assistant professor at the University of Texas, School of Public Health. Douphrate conducts research and outreach related to worker health and safety through the High Plains and Intermountain Center for Agricultural Health and Safety (HICAHS), headquartered at Colorado State University. Douphrate and his HICAHS colleagues conduct research and outreach with dairy producers to improve safe working environments while simultaneously improving dairy productivity and efficiency.

Click a link below to view previous columns by Douphrate and his colleagues:
Dairy worker safety and health: Injury and illness recordkeeping
Dairy worker safety and health: OSHA inspections, citations and penalties
Dairy worker safety and health: A new column from David Douphrate