A Case Study in Applied Social 

Marketing: Developing 

an Occupational Safety 

and Health Product 

BY DOUGLAS F. SCOTT 

ABSTRACT 

This case study provides an example of how social marketing was applied to meet 

the needs of business customers. Federal regulations require that all companies 

develop a written program to track hazardous chemicals at their sites. The 

HazComWriter, created by the National Institute for Occupational Safety and 

Health (NIOSH), is a software tool designed to help companies prepare their 

required Hazard Communications (HazCom) written plan and list all hazardous 

chemicals at the company's worksite. The social marketing goal was to provide a 

product for small- to medium-sized companies to use for federal HazCom rule 

compliance. The HazComWriter is a direct NIOSH response to customer and 

stakeholder needs (including the Mine Safety and Health Administration, the 

mining community, and Occupational Safety and Health Administrationregulated companies). 

The identification and labeling of hazardous chemicals in the work place is an 

important step in protecting workers. The Mine Safety and Health Administrations (MSHA) Rule 30 CFR Part 47 and the Occupational Safety and Health 

Administration (OSHA) Rule 29 CFR 1910.1200 (also known as the HazCom 

rules) require all companies to develop a written program to track hazardous 
chemicals at their sites. More specifically, the rule requires that companies list 

all chemicals and determine which are hazardous; develop a written hazard 

communication program; label all containers used to store hazardous chemicals; 

obtain or develop Material Safety Data Sheets (MSDS) for all chemicals stored 

or produced; provide workers with training in working around hazardous chemicals; 

and make information about hazardous chemicals available to all workers. 

Social marketing is defined as "the planning and implementation of programs 

designed to bring about social change using concepts from commercial marketing" (SMI 2008). Social marketing relies on the 4 Ps of marketing: product, place, 

price, and promotion (Schroer 2008). This article describes how social marketingbased research was effectively used to develop, test, and market a new compliance 

tool, the HazComWriter. 

Formative Research 

By March 21, 2003, all mines in the United States were required to be in compliance with MSHA Rule, 30 CFR, Part 47. This new rule required mines to list 

all chemicals and determine which are hazardous, develop a written Hazard Communication Program, label all containers used to store hazardous chemicals, obtain 

or develop Material Safety Data Sheets (MSDSs) for all chemicals stored or produced, provide workers with training in working around hazardous chemicals, and 

make information about hazardous chemicals available to all workers. Prior to that 

deadline, NIOSH personnel met with representatives from several mining companies and MSHA to discuss what could be done to help companies comply. Their 

findings indicated that small- to medium-sized mining companies would have 

more difficulty with the new rule because they lacked the expertise and resources 

to prepare a compliant written HazCom document. As a result, the HazCom 

Helper-MSHA-version (Scott, Drake, and Brady 2003a, b) was developed. 

One of the roles of social marketing research is to identifY how the consumer 

perceives the problem and the product. NIOSH compiled a list of all the companies that either downloaded or requested CDs of the HazCom Helper-MSHAversion. The results showed that about 40% of all requests were from nonmining 

companies. Therefore, NIOSH developed the HazCom Helper-OSHA version 

(Scott, Drake, and Brandy 200Sa, b) to meet this need. In 2006, the OSHA 

version was recognized by NIOSH as the best "educational materials product" 

and received an Alice Hamilton Award, one of the most prestigious awards given 

by the agency. 

Additional social marketing data were gathered via one-page evaluations 

(Appendix) that were included with requests for CD versions of both products. 
Customers were given an opportunity to evaluate the user friendliness, whether or 

not they had a HazCom plan prior to obtaining the HazCom Helper, how they 

found out about the product, and the usefulness of the product. Based on this customer feedback, NIOSH personnel determined that improvements were needed 

for overall design and appearance, functionality (e.g., need for sorting routines), 

added utilities (e.g., button-driven menus), user-friendliness, and product packaging. NIOSH personnel added these improvements and combined both versions 

into one final product, a user-friendly software tool, the HazComWriter (Scott 

2007a, b), which satisfies both OSHA and MSHA rule requirements. 

Feedback from the HazCom Helper (both versions) also included the 

following testimonials: 

III "Good product. We had a program, but used the HazCom Helper to enhance what we 

already had." 

III "Very useful and beneficial to operators." 

III "I am glad I found your program, it has made this step much easier for me." 

III "I have looked at the NIOSH HazCom Helper. It is slick and helpful for the in-plant 

hazard communications program, especially for small businesses." 

Product Development and Description 

Three levels of the. final product were identified. The core product (benefit) 

helps companies avoid costly MSHA or OSHA fines and penalties from 

noncompliance. The actual product (behavior) allows companies to use appropriate software to develop a HazCom plan. Finally, the augmented product (tangible 

object or service) is the HazComWriter software. 

An attractive name and logo were needed for the final product. The name had 

to be similar to the HazCom Helper to maintain continuity and name recognition 

within the customer. base, yet distinctly different. NIOSH personnel decided on 

HazComWriter because the software allowed the user to actually write a HazCom 

document. The red, orange, and brown logo (Figure 1) was created to provide 

marketing appeal by making it easy to recognize since no logo had been created 

for the earlier versions of the HazCom Helper. 

The HazComWriter helps the preparer understand what information needs to 

be included in his or her HazCom plan and helps the individual(s) identifY which 

chemicals are considered hazardous. The software includes prompts, suggestions, 

and help menus to lead the preparer step-by-step through the process of creating 

a HazCom plan. A list of all hazardous chemicals required by both MSHA and 
OSHA rules at a site can be entered (Figure 2), and the list can be saved and 

edited when necessary. This list is important to worker safety because it identifies 

and lists all hazardQus chemicals at a worksite. 

Some of the HazComWriter features added as a result of customer feedback 

included: 

HazComWriter logo 

Appendix A (list of Hazardous Chemicals) 

Entry 

Name: 

CAS No.: 

Manufacturer. 

Location: 

Amount Used: 

Edit 

~ 

~ 

1. The list of hazardous chemicals can be stored in a spreadsheet. 

2. User friendliness (i.e., the format is easier understand). 

3. Support for both print preview and print utilities. 
4. Easy navigational utilities. 

5. A sort utility to rearrange the chemical list created by the user, Chemical Abstract 

Service (CAS) number, manufacturer, or location. 

6. Functions to add/delete/ edit data in either the hazardous chemicals list or the main 

part of the written program. 

Figure 3 shows the HazComWriter Main Menu, and Figure 4 is an example of 

one of the input screens. 

HazComWriter Main Menu 

The document produced by this NIOSH HazComWriter is accepted by 

either MSHA or OSHA as the ·required written HazCom plan.· 

! Produce MSHA Report I I Produce OSHA Report I I Exit HazComWriter I 

The following HazComWriter input parameters are included in the software 

and are important because they can be customized, based on MSHA and OSHA 

requirements, and can provide space for detailed information. 

l1li General infonnation (organization name, location of written plan, program coordinator, inventory, adding chemicals). 

l1li Labeling infonnation (labeling containers, secondary containers, help with labeling, 

labeling system, in-house labeling, reviewing labeling procedures, review how often, 

responsible for chemical pipes). 

l1li MSDS infonnation (review MSDSs, new chemical procedure, where MSDSs are 

kept, no MSDS on file, alternate location, replace outdated MSDSs). 

l1li Training infonnation (training format, nonroutine tasks, initial training). 

l1li Other infonnation (informing contractors, information to contractors). 

l1li Appendix A (list of hazardous chemicals) (chemical name, chemical manufacturer's 

name, CAS number, location of chemical, amount of chemical used per time period). 
HazComWriter Input Screen 

OSHA Report 

.~~••••iI The Company name is: i~ I ------------

I 

02. MSDSs 

o 3. Labeling 

o 4. Training 

o 5. Other 

Example: XiZ Manufacturing Corp. 

!6. Chemical list I 

Navigate 

~ 

~ 

I «First I 

~ 

The primary benefit of this product is to assist companies in developing a 

HazCom written plan. In turn, this benefit helps companies avoid costly fines 

and penalties resulting from noncompliance with MSHA or OSHA regulations 

and ultimately protecting the health and safety of workers. Other benefits of 

using the NIOSH HazComWriter, include: 

II1II Reduced administrative burden in preparation of the written document. 

II1II Improved quality of the written document. 

II1II Increased worker awareness of hazardous chemicals in the workplace. 

II1II Assurance that the written plan will meet either MSHA or OSHA standards. 

Dissemination and Feedback 

The HazComWriter has been promoted at major health and safety conferences 

and demonstrated at several regional workshops organized by professional associations including the Society of Petroleum Engineers (SPE), the Society for 

Mining, Metallurgy, and Exploration, (SME), and MSHA. In addition, three 

separate NIOSH Technology News bulletins (numbers 503, 510, and 524) were 

mailed to hundreds of companies. Each of these bulletins is available at NIOSH 
mmmg program's 'website as well (http://www.cdc.gov/niosh/mining/pubs/ 

technewspubs.htm). Figure 5 is the NIOSH poster created for promotion of 

the HazComWriter at conferences and workshops. 

HazComWriter Poster 

Introducing the Haz(omWriter, NIOSH's first dually-compliant 

hazard communications software package, 

The document produced by this NIOSH HazComWriter is accepted

by either MSHA or OSHA as the ~required written HazCom plan." 

available in November 2007 

fOf more :nrorrno:lon" 

Doug Scott 

509,354,8056 

dus3@cdc.gov 

Users of the HazCom Helper (both versions) and the HazComWriter include: 

companies (mining, pharmaceutical, and environmental), MSHA trainers, contractors (landscaping and safety training), consultants (risk management), universities, hospitals, and forensic pathologists. More than 4,000 HazCom Helper CDs 
(both versions combined) have been requested and distributed and more than 

1,000 copies downloaded from the NIOSH website. More than 500 copies of 

the HazComWriter have been distributed as CDs at conferences, requested from 

NIOSH, or downloaded in the last quarter of 2007. 

NIOSH received both solicited and unsolicited feedback on the HazCom 

Helper (both versions) and found that: 1) all companies that requested the 

HazCom Helper already had a written HazCom plan; 2) most responders used 

the HazCom Helper to develop a new written HazCom plan; 3) most responders 

rated the HazCom Helper as easy to use; and 4) most responders rated the 

HazCom Helper very- useful as a tool to comply with the HazCom compliance 

regulations. 

Because the HazComWriter was developed with federal funds, the product is 

free to the consumer. Customers may order a copy of the HazComWriter CD 

from NIOSH or download the product from the NIOSH mining program's 

website: http://www.cdc.gov/nioshlmining/products/product153.htm 

Summary 

Based on feedback from customers and stakeholders, the MSHA and OSHA 

versions of NIOSH's HazCom Helper were combined into one easy-to-use 

software tool, the HazComWriter. While the new version includes all applications 

of the earlier HazCom Helper, several new features are now available in the 

HazCom Writer, most notably, the ability to generate and store chemical lists in 

a spreadsheet format, as well as a sorting function for the chemical list. 

The social marketing goal of this project was to provide a product for smallto medium-sized companies to meet federal HazCom rule compliance requirements and ultimately protect workers from hazardous chemicals. The success of 

the HazComWriter is a result of NIOSH effectively using a social marketing 

approach to identify a gap in the industry, work with government agencies and 

customers to recognize the need for a product, develop a product, and market 

the product to targeted consumers. 
References 

SCOTT, D. F. 2007a. HazComWriter CD. NIOSH Publication 2007-121c. 

SCOTT, D. F. 2007b. HazComWriter-Compliance tool for MSHA Rule 30 CFR Part 47 and 

OSHA Rule 29 CFR 1910.1200. NIOSH Technology News Publication 524. 

SCOTT, D. F., P. DRAKE, and T. BRADY. 2005a. HazCom Helper CD. NIOSH Publication 

2005-135. 

SCOTT, D. F., P. DRAKE, and T. BRADY. 2005b. HazCom Helper-OSHA VersionCompliance Tool for OSHA Rule 29 CFR 1910.1200. NIOSH Technology News Publication 510. 

SCOTT, D. F., P. DRAKE, and T. BRADY. 2003a. HazCom Helper CD. NIOSH Publication 

2003-118. 

SCOTT, D. F., P. DRAKE, and T. BRADY. 2003b. HazCom Helper-Compliance tool for 

MSHA Rule 30 CFR Part 47. NIOSH Technology News Publication 503. 

SCHROER, W. J. 2008. Marketing-the 4 P's. http://www.socialmarketing.org/newsletter! 

issues/4ps.htm (accessed August 4, 2008). 

SMI. 2008. Social Marketing. http://www.social-marketing.org/sm.html (accessed August 4, 2008). 

Appendix 

Evaluation of HazCom Helper-MSHA Version 

1. Did you have a written HazCom plan before you used the HazCom Helper? 

1 YES 2 NO 

2. Did you use the HazCom Helper to develop a written HazCom plan? 

1 YES 2 NO 

3. Why or why not? 

4. What commodity do you mine? 

1 SAND/GRAVEL 

2 COAL 

3 METAL 

4 STONE 

5 OTHER: _____ 
5. Rate the "user friendliness" of the HazCom Helper. 

1 EASY 

2 MODERATE 

3 DIFFICULT 

6. How did you find out about the HazCom Helper? 

1 MSHA WORKSHOP 

2 CONFERENCE 

3 NIOSH WEBSITE 

4 MSHA WEBSITE 

5 COLLEAGUE 

6 OTHER: 

7. How useful was the HazCom Helper in helping your mine comply with the MSHA 

Rule 30 CFR Part 47? 

1 NOT AT ALL 

2 SOMEWHAT 

3 MODERATELY 

4 VERY 

8. Is there anything else you would like to tell us about the HazCom Helper? 

Please Return to: 

Douglas Scott 

NIOSH-Spokane Research Lab 

315 E. Montgomery Ave. 

Spokane, W A 99207 

Tel: 509.354.8056 

Fax: 509.354.8099