Common Mistakes in Complying with Title 8 CCR §5194 (Hazard Communication) in the Aerospace Industry

In the high-stakes world of aerospace, precision is key—not just in engineering but also in safety compliance. Title 8 CCR §5194, commonly known as the Hazard Communication standard or Prop 65, is a critical regulation designed to ensure employees are informed about hazardous chemicals in the workplace. Yet, even in an industry renowned for its attention to detail, mistakes can occur. Let's dive into some common pitfalls and how to avoid them.

Misunderstanding the Scope of Prop 65

One of the most frequent errors is a misunderstanding of what Prop 65 covers. Many assume it's limited to specific chemicals, but it actually applies to any substance that the State of California knows to cause cancer, birth defects, or other reproductive harm. In aerospace, this can include everything from cleaning solvents to composite materials.

Inadequate Training and Documentation

Proper training and documentation are the backbone of compliance. I've seen facilities where the training was outdated or not tailored to the specific hazards present. Remember, under Prop 65, you need to ensure all employees are aware of the hazards they might encounter. It's not just about having a program in place; it's about keeping it current and relevant.

Failure to Update Safety Data Sheets (SDS)

Safety Data Sheets are vital for hazard communication. A common mistake is not updating these documents when new information becomes available or when new chemicals are introduced. In aerospace, where innovation is constant, staying on top of SDS updates is crucial. Based on available research, individual results may vary, but maintaining accurate SDS can significantly reduce compliance risks.

Neglecting to Label Hazardous Materials

Another area where aerospace companies often slip up is in the labeling of hazardous materials. Every container, no matter how small, must be clearly labeled with the hazards it presents. I once consulted at a facility where temporary containers were overlooked, leading to potential exposure risks. Clear, consistent labeling is non-negotiable.

Ignoring the Importance of a Written Program

Finally, many companies fail to maintain a comprehensive written hazard communication program. This document should outline how the company complies with Prop 65, including how it identifies and communicates hazards. Without this, enforcement agencies may find you non-compliant, even if your practices are otherwise sound.

By understanding these common mistakes and actively working to avoid them, aerospace companies can better protect their employees and maintain compliance with Title 8 CCR §5194. For further guidance, consider resources from the California Department of Industrial Relations or the Occupational Safety and Health Administration (OSHA).