Right-to-Know (RTK) Laws

Some businesses utilize commercially available labeling systems that use non-text methods to convey hazard warnings. These alternative systems may use icons, color coded numbers, or pictographs to describe levels of hazard and required personal protection equipment.

Institute Updating System

Employers should develop a system that allows them to efficiently update their chemical information list and MSDS holdings as each new substance arrives in their workplace. Updates should take place within 30 days of receiving the materials in question, as state and federal right-to-know programs require chemical lists to be updated regularly.

Hazard Assessment

Many employers use the hazard information contained in each MSDS to carefully review all processes in which the material is used. At this time, business owners can decide whether current workplace practices are adequate to ensure the safety and health of employees. Specific elements to review include level of engineering controls, adequacy of personal protective equipment, emergency procedures, and work practices.

Hazard Communication Program

Employers should put together a written hazard communication program for their employees. This program should explain how the company is meeting state/federal right-to-know requirements. Effective hazard communication programs will also include detailed explanations of the company's system of identifying and labeling hazardous substances; information about the company's material safety data sheets and chemical information lists, including how they are maintained and how they can be accessed by workers; and details on policies and procedures that employees should follow when engaged in non-routine tasks that require usage of hazardous chemicals and other potentially dangerous materials.

Training

Effective training programs must be implemented in conjunction with RTK laws. Right-to-know training programs should provide guidance and information in several key areas, including the purpose and content of the law; the nature of the hazardous substances in the workplace; protection from hazards; location and usage of information on these workplace materials, including material safety data sheets, labels, and chemical information lists; and overall employee rights. In essence, all right-to-know training programs should be based on the knowledge that information that is not understood by workers will be of little utility to them in preventing or limiting their exposure to hazardous chemicals in the workplace.

Business experts and state and federal administrators cite several keys to shaping and implementing an effective training program for your workforce:

• Identify who needs training. Employers should utilize organizational charts and personnel records to identify the training needs of various staff. Assess each employee's actual and potential exposure to hazardous chemicals during normal working situations and in potential emergencies (for example, production and custodial workers are likely to have a higher level of training than salespeople and secretaries).
• Determine which chemicals your employees may be exposed to, either under normal working conditions or emergency situations.
• Ensure that employees are aware of the location of chemical information lists and material safety data sheets.
• Make sure that employees know how to use labels, MSDSs, and chemical information lists to obtain information on hazardous materials.
• Make sure that employees understand control programs and personal protective equipment.
• Institute measures to ensure that new and transferred workers receive training. Many businesses integrate Right-to-Know training into general orientation programs or existing departmental safety programs.
• Make contingency plans to provide additional training if new hazards are introduced into the workplace.
• Evaluate effectiveness of training programs after workers have completed them. This can be done through written tests, one-on-one meetings with employees who completed the program, or employee demonstrations of acquired skills and knowledge. Employee feedback on the training program should also be encouraged. Business owners and managers should ask workers which aspects of the program were most valuable and informative, and which aspects were least useful. In some cases, this feedback phase may reveal that the training program did not provide staff with the necessary level of knowledge to safely and effectively deal with hazardous materials they encounter in the workplace. In those cases, programs should be revised until they meet expectations.

Experts note that many facilities utilize literally thousands of chemicals in their operations. Training all employees about the characteristics of each one is an unrealistic burden for any employer. Over the years, OSHA policies have shown a general recognition of this reality. According to OSHA, "information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets'¦. If there are only a few chemicals in the workplace, then you may want to discuss each one individually. Where there are large numbers of chemicals, or the chemicals change frequently, you will probably want to train generally based on the hazard categories (e.g., flammable liquids, corrosive materials, carcinogens)." The market has also responded with helpful products. Thus Del Williams reported, in Medical Laboratory Observer, on Windows-based right-to-know labeling software which enables OSHA compliance officers to prepare labels on ordinary printers—having done so by hand before. Williams' report was based on an interview with a supplier servicing 200 hospitals—indicating the often massive size of the compliance task. Suzanne Shelley, reporting on the same product (called RTKV2 HazCom) in Chemical Engineering made the point that the product comes with online access to a database of 160,000 MSDS records—thus making the job significantly easier.

 PREV  1 | 2