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HazCom or HazMat, What’s the Difference?
Many employers are confused about the difference between a Hazard Communication Program (HazCom, sometimes referred to as HCP) and a Hazardous Material Program (HazMat). Both the HazCom and the HazMat Programs are vital to a safe and healthy workplace and environment. Employers who know the difference between the two programs and comply with both can protect their workers and themselves and avoid possible citations.
Put simply, a HazCom or "Right to Know" Program ensures that employees have access to information on the chemicals they use in the workplace. Cal/OSHA's HazCom standard is a health and safety regulation that requires employers to provide workers with information and training on the characteristics, hazards, and uses of chemicals in the workplace. HazMat Programs are environmental regulations governing the storage, handling, treatment, and/or disposal of hazardous materials used or produced in facilities.
Under the HazCom regulation, chemical manufacturers must label their products with detailed hazards and characteristics and provide Material Safety Data Sheets (MSDSs) with this information. Employers must inventory their chemical storage and use, and ensure that MSDSs for all chemicals in the facility are available to employees. Employers should document their inventory and labeling systems, MSDS access, training methods, and responsibilities in a written document or HazCom Program.
Current, accurate MSDSs must be maintained for each of the hazardous chemicals in the workplace. The MSDS collection and the written HazCom Program must be made available to employees during their work shifts. Employees require training on the hazards, health effects, protective equipment and devices, proper use, handling, and storage of the hazardous chemicals in the workplace. Training must be given when employees are new to an assignment or when new hazards are identified. The HazCom Program and the training must cover both routine and non-routine tasks and chemicals.
Note: A Proposition 65 Warning provides information on the hazards of any substance included in Title 22, California Code of Regulations §12000 (Safe Drinking Water and Toxic Enforcement Act of l986). Proposition 65 information should be included in a HazCom Program.
To comply with the Hazardous Materials standard (HazMat), facilities must inventory the chemical amounts stored and used on site. Based on the type and amount of hazardous materials, facilities may be required to submit and follow a Hazardous Materials Business Plan (HMBP) with local government agencies (Note: One chemical inventory can be used for the HMPB and HazCom Program, but the HMBP requires chemical amounts while the HazCom Program inventory does not). HMBP's require facilities to evaluate, document, and train employees on material storage, use, and emergency procedures for spills and fires. Employers must properly label, collect, dispose, and track hazardous materials through recordkeeping.
Because of the confusion between HazCom and HazMat Programs, Cal/OSHA often cites employers for deficiencies in their required HazCom Program. Common citations include not having a written program, not having a chemical inventory, and improper labeling. Employers should develop and maintain a written HazCom Program that includes a list of hazardous substances used and/or stored in the workplace. Labeling procedures must be outlined and the employer must ensure that secondary containers (even pipes containing hazardous substances) are properly labeled.
The above evaluations and/or recommendations are for general guidance only and should not be relied
upon for legal compliance purposes. They are based solely on the information provided to us and relate
only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.
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