OSHA's Hazard Communication (HAZCOM) standard (HCS) is designed to protect against chemical source illnesses and injuries by ensuring that employers and employees are provided with sufficient information to anticipate, recognize, evaluate and control chemical hazards and take appropriate protective measures. This HAZCOM information is provided through safety data sheets (SDSs), labels, and employee training. In order for MSDSs, labels, and training to be effective, the hazard information they convey must be complete and accurate. Thus, it is critically important to obtain comprehensive HAZCOM information and correct information about the hazards associated with particular chemicals.

HAZCOM graphic with GHS requirements

What is Hazard Determination?

Hazard determination is the process of evaluating available scientific evidence in order to determine if a chemical is hazardous pursuant to the HAZCOM. This evaluation identifies both physical hazards (e.g., flammability or reactivity) and health hazards (e.g., carcinogenicity or sensitization). The HAZCOM provides the basis for the hazard information that is provided in SDSs, labels, and employee training. Hazard determination does not involve an estimation of risk. The difference between the terms hazard and risk is often poorly understood. Hazard refers to an inherent property of a substance that is capable of causing an adverse effect. Risk, on the other hand, refers to the probability that an adverse effect will occur with specific exposure conditions. Thus, a substance will present the same hazard in all situations due to its innate chemical or physical properties and its actions on cells and tissues. However, considerable differences may exist in the risk posed by a substance, depending on how the substance is contained or handled, personal protective measures used, and other conditions that result in or limit exposure. This document addresses only the hazard determination process, and will not discuss risk assessment, which is not performed under the OSHA HAZCOM.

Who Must Conduct HAZCOM Hazard Determinations?

Only chemical manufacturers and importers are required to perform hazard determinations on the chemicals they produce or import. Under the HCS, an employer that manufactures, processes, formulates, or repackages a hazardous chemical is considered a "chemical manufacturer." Distributors and employers may also choose to conduct hazard determinations if they are concerned about the adequacy of hazard information for the chemicals they use in their business or distribute to others. Regardless of who performs the hazard determination, the procedures used must be described in writing and made available, upon request, to employees and their designated representatives, as well as to OSHA and National Institute for Occupational Safety and Health (NIOSH) officials.

The final step in the hazard determination process is very important. All the other steps will be wasted if you do not document your findings carefully. If a chemical is found to be hazardous, it is recommended that the findings be documented in order to assist in preparing labels and MSDSs, and to maintain a record for future reference and updating. In addition, the HAZCOM requires data documentation of the hazard determination as follows: Chemical manufacturers, importers, or employers evaluating chemicals shall describe in writing the procedures they use to determine the hazards of the chemical they evaluate. The written procedures are to be made available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director [OSHA and NIOSH officials].

The written description may be incorporated into the written hazard communication program required under paragraph (e) of this section [the HCS]. To meet the HAZCOM requirements, it is recommended that a structured approach to data retrieval and compilation be adopted. This structured approach applies to preparation of SDSs and labels. Compilations of four types of data are considered essential: Initial chemical inventory; Description of procedures used for hazard determination; Specific data retrieved for each chemical; and Hazardous chemicals list. Chemical Inventory The chemical inventory should consist of all chemicals that are produced, imported, or used by the company. The chemical inventory should be complete and contain, at a minimum, the following: chemical name; CAS Number; common name; synonyms; product/mixture name (if applicable); and percentage of ingredients in product/mixture (if applicable). It is recommended that this chemical inventory be computerized for future sorting, additions, deletions, and status reports.