The Most Common Violations of §5194 Hazard Communication in Waste Management

When it comes to managing waste safely, understanding and complying with the Hazard Communication standard (§5194) isn't just a regulatory checkbox—it's a cornerstone of workplace safety. Let me walk you through the most common pitfalls we see in waste management operations.

Inadequate Training

One of the most frequent violations we encounter is inadequate employee training. Under §5194, all employees must be trained on the hazards of chemicals they work with or are exposed to. In waste management, this means everyone from the folks sorting recyclables to those handling hazardous waste needs comprehensive training. From my experience, many organizations fall short here, either by not providing training at all or by offering training that's too generic to be effective.

Missing or Incomplete Safety Data Sheets (SDS)

Another common issue is the lack of Safety Data Sheets (SDS) for all chemicals on site. The law requires that an SDS be readily available for each hazardous chemical. In waste management, where you're dealing with a variety of substances, it's critical to keep these documents up-to-date and accessible. I've seen facilities where SDSs were missing for half the chemicals in use, which not only violates §5194 but puts workers at risk.

Improper Labeling

Improper labeling is another frequent violation. Every container of hazardous chemicals must be labeled with the identity of the substance and appropriate hazard warnings. In waste management, where containers are constantly being moved and repurposed, maintaining accurate labels can be a challenge. We often find containers without labels or with labels that don't reflect the current contents, leading to potential safety hazards and regulatory non-compliance.

Failure to Maintain a Written Hazard Communication Program

Lastly, many waste management facilities fail to maintain a written Hazard Communication Program. §5194 mandates that employers develop, implement, and maintain at the workplace a written program which describes how the criteria specified in this section for labels and other forms of warning, safety data sheets, and employee information and training will be met. In my visits, I've seen programs that are outdated or simply don't exist, which is a clear violation of the standard.

By addressing these common violations, waste management operations can significantly improve their compliance with §5194 and, more importantly, enhance the safety of their workforce. Remember, while these insights are based on my extensive experience in the field, individual results may vary depending on the specific conditions at your facility.