Every October OSHA releases it’s list of top 10 violations that they issued citations for that year.  Safety professionals dutifully look at the new list every year.  Sadly, the list is never a surprise.  The top 10 are virtually the same every year.   Topping the chart every year at number 2 is Hazard Communication.  The Occupational Safety & Health Administration mandate, 29 CFR 1910.1200, states that companies producing and using hazardous materials must provide employees with information and training on the proper handling and use of these materials.  Hazardous materials such as chemicals must be labeled and employees must be trained on proper handling of these materials.  They must also have access to Safety Data Sheets for all chemicals.

Hazard Communication sounds simple, right?  Just put your SDS’s neatly in a binder in an easily accessible place, put labels on chemical containers and train employees on proper use, storage and disposal of chemicals. Easy, right?  You would think so, but based on the data from OSHA, companies are pretty bad at this.  Why?  I have a couple of theories.

As technology gets more and more advanced, the pace required to keep up gets faster and faster.  When the pace gets faster at work we cut corners.  It’s human nature.  New hires are added quickly and their training can be quick and dirty.  Even when the training is thorough and complete, people will still cut corners to make deadlines.  Chemical containers go without labels because someone thinks that they will use the container quickly and the chemical will be gone before anyone else has a chance to wonder what is in it.  Here’s the thing about cutting corners…It’s one of the “3 Cs of bad business” put bluntly by business magnate John Gokongwei.  Cut the wrong corner and you’re in for a hefty fine from OSHA or worse.

It is also human nature to try and save money.  Why purchase a label for your chemical bottle when you can just write one by hand?  EH&S professionals have seen it all when it comes to companies trying to trim the fat in hazard communication.  We spoke with a long time EH&S consultant who told us horror stories about what he found in some of his client’s labs.  There were bottles containing hazardous chemicals with the chemical name written in chicken scratch either with a sharpie directly on the bottle, or on a piece of tape attached to the bottle.  Some of the chemicals were even labeled with post-it notes! Much worse, some bottles containing very hazardous and volatile chemicals were not labeled at all.

So let’s go over our reasons why companies are failing in the hazard communication department.  Minimal or no training for new employees, cutting corners to beat deadlines, saving money, and frankly plain laziness in some cases.  All of these can be corrected by simply establishing a good safety culture in your company.  A list of rules won’t do the job.  The employees need to embrace safety and take pride in doing their part to make it a safe workplace.  The first step is to know your team and learn what motivates them as a group and also as individuals.  By doing this, you can figure out how to motivate them to make safety their top priority.  Let’s all make it a goal to get Hazard Communication off of OSHA’s top violation list for 2017!