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: The OSHA Hazard Communication Standard was revised in 2012. All individuals who work with chemicals at Vanderbilt must complete training that covers all requirements of this law.
Frequency: Initial with annual retraining
Contact the VEHS webmaster if you have questions about HCS training requirements.
Part One: General Hazard Communication Training
Required for all employees. Required annually for all employees who are exposed to and work directly with hazardous chemicals. Also required annually for all VUMC employees, per VUMC policy.
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 new staff online in the Learning Exchange as part of University or Medical Center online orientation or can be provided within their department. To satisfy training requirements for Part One, department managers may also use this online training video . The Hazard Communication Standard online training that is available in the University or Medical Center Learning Exchange can be self-assigned.
Part Two: 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 VEHS.
This specific training must include
- The Hazard Communication Written Program
- VUMC Policy SA 20-10.03: Hazardous Chemical Right to Know/Hazard Communication (Medical Center only)
- The VU Hazard Communication Standard Written Program (University only)
- The list of hazardous chemicals used by your unit/department.
- Locations and situations that may occur 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.
Class length varies and depends on the extent of chemical use within the department or unit.
Class Schedule/Location: This training is provided within an individual department.
Hazard Communication Standard Resources
Vanderbilt Hazard Communication Standard Written Programs
- VUMC Policy SA 20-10.03: Hazardous Chemical Right to Know/Hazard Communication
- The VU Hazard Communication Standard Written Program
Vanderbilt Chemical List and Safety Data Sheet Verification Log
Additional VUMC Resources
- VEHS Resources
- OSHA Resources
- OSHA Brief HCS Labels and Pictograms - OSHA Brief
- OSHA HCS Standard Labels - OSHA Quick Card - required format for labels
- OSHA Comparison of NFPA 704 and OSHA 2012 Labels
Safety Data Sheets (SDS)
- Safety Data Sheets - provides links to online resources for SDS
- HCS Safety Data Sheets - OSHA Quick Card (PDF version) - required format for SDS
- HCS Safety Data Sheets - OSHA Brief
Chemical Safety Resources
VEHS provides extensive chemical safety information through this web site:
- Safety Data Sheets
- Chemical & Laboratory Safety
- Chemical Waste
- Chemical Safety Links
- Chemical Safety Databases
If you have questions about the Hazard Communication Standard or Hazard Communication training, please contact one of the following: