The Hazard Communication Standard (HCS)

Working Safely with Chemicals

The Hazard Communication Standard, also known as the Right to Know Law, is mandated in US federal regulation 29 CFR 1910.1200 with enforcement by the Occupational Safety & Health Administration (OSHA); it is also mandated in State of Tennessee Regulations chapter 0800-1-9 with enforcement by the Tennessee Division of Occupational Safety & Health (TOSHA).  The OSHA web site provides extensive information about the standard.

The Hazard Communication Standard requires that employees receive safety training if they will be working with hazardous chemicals.   The Hazard Communication Standard requires that Safety Data Sheets (SDS) be provided by chemical manufacturers and distributors and that facilities where hazardous chemicals are located must train workers on how to safely handle hazardous chemicals.  Instruction on the use of SDS and proper chemical labeling must be included in this training.

Individuals who work with chemicals in laboratories are required to comply with the OSHA Lab Standard, which includes the requirements of the Hazard Communication standard but also incorporates additional requirements. Please note that the Lab Standard requires a written Chemical Hygiene Plan instead of a written Hazard Communication plan.

HCS Training Requirements

Training must include a description of the Standard, recognition of HCS pictograms, how to obtain, use & understand Safety Data Sheets (SDS), health effects (including reproductive risks), how to interpret information provided on chemical container labels, secondary container labeling requirements, personal protective equipment, safe work practices and emergency procedures.  

Due to the wide variety in chemical use at Vanderbilt, training is provided in two parts:  general information and department-specific information.  General training information is described below in Part One, while department-specific requirements are described in Part Two.

Important: All individuals who work with chemicals at Vanderbilt must complete training required by the OSHA Hazard Communication Standard. 

Frequency: Initial with annual retraining

Contact the OCRS webmaster if you have questions about HCS training requirements.  

Part One: General Hazard Communication Training

Required annually for all employees. See policies VUMC - Hazardous Chemical Right to Know/Hazard Communication and Regional Hospitals - Hazardous Chemical Right-to-Know, Hazard Communication.

Part one training provides general information about requirements of the standard, such as a description of Safety Data Sheets (SDS), the need for chemical container labeling, proper personal protective equipment (PPE),  and other requirements of this standard.  This training is general and does not provide all of the information that is specific to different departments and units.  See Part two: Specific training, below.

The Hazard Communication Standard part one training may be provided to staff online in the Learning Exchange as part of orientation and annual training.

Part Two: Department-Specific Hazard Communication Training

Required annually for all employees who are exposed to and work directly with hazardous chemicals.

Supervisors are responsible for making sure that this training is provided at the departmental or unit level because it must provide specific information about the hazardous chemicals in use at each location. For advice on how to provide specific Hazard Communication training, contact OCRS.

This specific training must include

  • The Hazard Communication Written Program - available through PolicyTech: 
  • The list of hazardous chemicals used by your unit/department.
  • Locations and situations within your unit or department where hazardous chemical exposure can occur.
  • Appropriate PPE and engineering controls for chemicals used in your department/unit.
  • Where to find and how to read Safety Data Sheets (SDS) for chemicals in use in your department or unit.
  • Safe work practices and emergency procedures.
  • Instruction on proper labeling of secondary chemical containers.
  • Recognition of hazard pictograms (symbols) used to represent specific hazards.

The following online courses cover some common chemical hazards that require department-level safety training. These courses are available in the Learning Exchange:

  • Waste Anesthesia Gas Safety
  • Cryogen Safety
  • Formaldehyde Safety in Clinical Pathology Labs
  • Lead and Cadmium Safety in Radiation Oncology

Hazard Communication Standard Resources

Vanderbilt Hazard Communication Standard Written Programs

Vanderbilt Chemical List and Safety Data Sheet Verification Log 

Additional VUMC Resources

Recognize Chemical Hazards 

Pictograms

Labels

Safety Data Sheets (SDS)

General References:

Chemical Safety Resources

OCRS provides extensive chemical safety information through this web site:

Questions

If you have questions about the Hazard Communication Standard or Hazard Communication training, please contact one of the following: