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Hazard Communication
Host Employer and Contractor Responsibilities

Hazard Communication programs required under OHSA’s construction standard (29 CFR 1926.59), state that information about hazardous chemicals, their potential hazards, and appropriate precautions, must be communicated by an employer to all workers, including other employer’s personnel and outside contractors who share the work site. There are six required elements of a hazard communication program.

Written Program - documents how hazardous chemicals are identified, how employees are notified of these hazards, instructs on necessary precautions and the location and use of material safety data sheets (MSDSs).

Labeling - the minimum information required for hazardous chemicals consists of identifying the chemical by name, and indicating the specific physical hazard (including the organs likely affected) in words or pictures, and list a contact for emergency situations.

Inventory Lists - of all hazardous chemicals used at the worksite must be listed by the name that appears on the MSDS and the label.

Other Hazards - as part of the written program, other hazards must be identified and indicate how employees are informed about hazardous chemicals encountered in non-routine tasks such as infrequently performed operations, spills and emergencies, and chemicals in unlabeled pipes.

MSDSs should be used by supervisors and others in pre-job planning to determine what precautions and/or controls are needed for working with hazardous chemicals. MSDSs are also useful to emergency medical personnel in the event of an accident.

Training - mandatory training prior to performing work with hazardous chemicals, and/or when a work process or type of chemical hazards change is required. Periodic retraining is also recommended.

Communication is the key to ensuring that these requirements are carried out at a construction site where there are often multiple employers. Both the Host employer and the contractor employer have responsibilities to share their hazard communication programs and training with each other. Understanding what is expected from each party is very important. Here are some suggested guidelines to follow:

The host employer should maintain a program consisting of the six elements previously discussed, and share the program with the contractor employees on the job site.

Contractor employees who bring in or use hazardous chemicals that others may be exposed to should have specific reporting responsibilities. The written program should describe how this information is communicated to other employers on site including the method for providing MSDSs, informing others of precautions/personal protective equipment, and informing others of their labeling system.

Training may be provided by the current employer, past employers, unions and outside firms. However, it is the current employer’s responsibility to assure that employees are adequately trained.

New employees who have been previously trained by someone else should be evaluated on the basis of their level of knowledge. Site-specific information such as the location and content of the written program, and the MSDS file should be covered.

When a contractor employee is assigned to work directly under the supervision of another employer, generic training should be conducted on hazard recognition, precautions, labels and MSDSs at a minimum. Then the contractor employer can provide training specific to the hazardous material at the job site

Article Provided by: The Argus Group

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