Hazard Communication - Is it really communication?

When completing a Baseline Risk Assessment one of my personal pet focus areas remain – Hazard Communication. We are not talking about the chemical or nuclear latent hazard, this is more like the subtle overlooked warning that employees could expect to be, informed by.

The size of the company really is irrelevant both large, to small companies are just as negligent and ill informed as to their responsibility toward compliance and reasonable necessary diligence, applicable to the subject.

Here are the major omissions that companies and corporations are guilty of:

a.       Yard or premises speed limit not displayed prominently and not at the entrance.

b.      Loading dock edges are unprotected, and, there is not a single sign warning employees and visitors that the edges are unprotected.

c.       Moving traffic –There is no warning of moving traffic including lifting machinery.

d.      PPE requirements for certain areas – there is no signage, indicating PPE preferences and mandatory requirements.

e.      Crush Injuries at loading bays – No warning or requirements regarding trucks backing into an elevated loading bay.

f.        Environmental – Absolutely zip or no communication regarding environmental requirements, leaving carbon laden engines running, plastics littering the premises, trees and plant beds used as refuse areas and ash trays.

g.       Authorised and unauthorised areas are not, clearly demarcated.

h.      Warning of waste pallets which incidentally have nails protruding from them is non- existent.

i.         Clearly and prominently displayed, emergency procedures, and assembly area are lacking..

j.        No meaningful welcome sign, one that perhaps implores visitors to comply, beware and exercise caution, perhaps along these lines – “We love our customers and visitors and would hate that anything happened to them whilst in our care, please be aware of both mandatory and statutory requirements of entry to our premises.”

k.       Finally, I am aware that indemnity law is not practiced and enforced, however, all good communicators will post an indemnity notice at entrances to their premises, it has an effect of compelling visitors to practice caution.

When researching the legal requirements with regard to Hazard Communication, it was and remains frustrating and extremely vague both in USA and South Africa, the USA and OSHA have the 1900.1200 series of STANDARDS these pertain more to Hazardous Substances. There is a standard for my brief mentioned above; however, finding it is a hassle.

In South Africa we have Section 13. Of Act 85 of 1993, “Duty to Inform” , then we have General Safety Regulation 2B which relates to signage for emergency purposes. Once again the much maligned Section 8 of Act 85 of 1993 could be construed as a “Duty of the Employer” to provide a safe and hazard free work environment, section 8 and section 10 are in my opinion too broadly defined and are loaded with a myriad of references and requirements perhaps over-loaded.