4.4 Non-routine tasks, pipes and other employers

1 Non-routine tasks

Paragraph (e)(1)(ii) requires the written program to include the methods the employer will use to inform employees of the hazards of non-routine tasks. The standard's own parenthetical example is the cleaning of reactor vessels.

The reason this element exists is structural. Routine work is covered by routine communication: the label on the can, the briefing at the start of the shift, the training that happened when the product arrived. A non-routine task is by definition outside all of that — it is the annual tank clean, the line break, the catalyst change-out, the demolition of a wall nobody has opened since 1978, the first time anyone has used a product for a purpose the supplier did not anticipate.

A method has two parts: a trigger and a document. A workable trigger is “any task not on the standard work list”. A workable document is a written task authorization or pre-task plan that names the chemicals involved, the hazards from their sheets, the controls, the PPE and the emergency steps — and that is briefed to everyone doing the work before it starts.

2 Unlabeled pipes

The second half of (e)(1)(ii) requires the methods used to inform employees of the hazards associated with chemicals contained in unlabeled pipes in their work areas.

This element exists because the definition of container in paragraph (c) expressly excludes pipes and piping systems. Every labeling paragraph in (f) therefore misses them entirely. Without (e)(1)(ii) a plant could be full of lines carrying hazardous chemicals with no communication duty attached at all.

Methods that work in practice: a posted piping schedule at the panel or in the control room; a line-marking convention with a legend that is taught, not just painted; a rule that no line is opened until the operator confirms the contents against the schedule; and, for maintenance, a permit that carries the line contents onto the paperwork. Voluntary pipe-marking schemes are good practice and widely used — but painting a pipe is not by itself a method of informing employees, which is what the paragraph asks for. The method is what tells people how to read the paint.

3 Multi-employer sites, in practice

Paragraph (e)(2) applies whenever you produce, use or store hazardous chemicals in such a way that another employer's employees may be exposed — and the standard gives employees of a construction contractor working on-site as its own example. Three methods must be in the program: SDS access for the chemicals their people may be exposed to (e)(2)(i); precautionary measures for normal operating conditions and foreseeable emergencies (e)(2)(ii); and the labeling system used in the workplace (e)(2)(iii).

The reverse direction matters just as much and is not in (e)(2): chemicals brought onto your site by other employers. Their products are present in your workplace, in a manner that may expose your employees under normal use or in a foreseeable emergency — which is the scope test at (b)(2). The practical answer is a mobilization requirement: every contractor supplies a list and sheets for what they bring, and those either merge into the site list or are held alongside it.

4 HazCom as the hub for the substance-specific standards

This is the part of the standard that most changes how you should think about your program. Several of OSHA's health standards do not build their own communication scheme — they fold into this one, and they name the hazards that must be addressed.

Two consequences follow. First, if your site does silica work, lead renovation or asbestos work, your HazCom program has named content it must carry — not general awareness, but those specific health effects. Second, each of those standards then adds its own training duty on top: six demonstrable knowledge items for silica at 1926.1153(i)(2)(i)(A)-(F); the list at 1926.62(l)(2) for lead; the awareness content of 1926.1101(k)(9)(viii) for asbestos. HazCom is the floor, and the substance standards build on it.

5 Keeping the program alive

1910.1200 sets no review interval for the written program. That is a gap you have to fill yourself, and the way to fill it is to attach maintenance to events rather than to a date.

1. 1
   At receiving: is there a sheet, is the product on the list under the identifier from that sheet, does anyone need training on a new hazard class before it goes into service?
2. 2
   At mobilization: what is a new contractor bringing, and have they been told your labeling system?
3. 3
   On the weekly walk: does every container have an identifier and hazard information?
4. 4
   On a revised sheet: reissue any one-page briefs built from it — and remember (g)(5) gave the supplier three months, and (f)(11) gave the label six.
5. 5
   Once a year, by choice: reconcile the list against a store room walk, and re-read the non-routine task and pipes methods to see whether they still describe reality.

A program maintained that way passes an inspection as a side effect of being true. A program maintained by an annual document review passes only if nothing changed, which on a live site it never does.

6 Putting the course back together

Four deliverables, and you have now seen all of them from both ends.

The written program (Chapter 1.3) is not a document about the standard — it is a description of your methods, your list, and your answers for non-routine tasks and pipes. The labels (Part 2) are six elements from a supplier and a product identifier plus hazard information from you. The safety data sheets (Part 3) are sixteen sections in a fixed order, readily accessible on every shift, with a three-month update clock. The training (Chapter 1.4) is triggered by assignment and by new hazards, has three information items and four training items, and has to be effective.

Everything else in this course — pictograms, precedence rules, vapor density, segregation, the incidental release line — exists to make those four things useful to the person holding the container. That is the whole standard: not a filing system, but a chain of information that has to still be intact at the moment somebody needs it.

A free template for the written program itself is at the HazCom written program generator, built on the elements of (e)(1). The HazCom and GHS practice test will tell you which parts of this course stuck.