OSHA HazCom & Sealant Usage by WCOs

OSHA HazCom Standard … What is it and Why do I need it?

Believe it or not, OSHA classifies the majority of professional sealants we use as “Hazardous Chemicals.” This classification triggers the requirements of the Hazard Communication Standards, which must be followed when storing, using, and training employees exposed to, working near, or utilizing these substances during their workday.

A Story That will Make You Shiver

A WCO I know recently shared a story about how an incident directly impacted him, his company, and his employees. One day, while performing routine tasks on a rooftop, his technician was using Solar Seal 900. Unfortunately, the technician was not wearing fall protection gear. As he was descending on a ladder, an OSHA inspector happened to drive by and noticed the unsafe practice. The inspector turned his vehicle around and approached the worksite. He asked the technician about the chemical he was using and requested the Safety Data Sheet (SDS) for Solar Seal 900. The technician could not provide an SDS for this product, nor did he have any for the commonly used sealants the team worked with regularly.

The OSHA Investigation Begins

My good friend explained that OSHA began their investigation by requesting to see his written Hazard Communication (HazCom) Program, which should include training records, Safety Data Sheets (SDS), and details about the storage and signage of his hazardous chemicals, including sealants and a few other items. He was surprised and unprepared for this, as he was completely unaware that sealants were classified as hazardous materials and that he needed to have a HazCom program in place to ensure compliance.

What Happened Next?

My friend and fellow WCO is a highly professional individual. He cooperated with OSHA and the inspector, explaining that he was unaware of the required regulations and requested guidance on how to achieve compliance. OSHA informed him that he needed to implement a written policy, provide training for employees, and maintain records of that training. Additionally, he was advised to conduct periodic evaluations of the program, ensure that sealant labels and Safety Data Sheets (SDS) were available, and keep an inventory of chemicals along with appropriate signage in storage areas. Furthermore, specific protocols must be established for work conducted off-site (at job locations).

The End Result

He considers himself very lucky to have escaped with the several citations and fines amounting to a few hundred dollars. It could have been much worse, as fines of up to $16,550 for each first-time violation could have been imposed. I encourage everyone to learn about the OSHA HazCom program and implement it in your workplace before it’s too late.

HazCom Applies to More than Just Sealants

The OSHA HazCom Standard applies not only to sealants but also to many commonly used chemicals that businesses use daily. Consider reaching out to your local OSHA office for guidance, or learn more about this standard at https://www.osha.gov/hazcom.

To gain a deeper understanding of this topic, consider enrolling in our short course, “OSHA HazCom & Sealant Applications,” designed specifically for WCOs. It is currently available online and on-demand for $ 35.00. Click here to learn more: https://nwcotraining.thinkific.com/courses/Short-Course-OSHA-HazCom-and-Sealant-Applications