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OSHA Hazard

CommunicationStandard

Occupational Safety and Health Standards

for theGeneral Industry

OTI 501LABEL

MSDS

HCP

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General IndustryHazard Communication

_____________________________________29 CFR 1910.1200

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Violations Cited - FY 2000

(e)(1)(h)

(h)(1)

(g)(1)

(f)(5)(i)

– Written HCP

– Employee Training

– Employee Training

– Material Safety Data Sheets

– Labeling

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CPL 2-2.38D

March 30, 1998

Inspection Procedures for the Hazard Communication Standard

CPL 2-2.38D3/30/98

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CONTENTS

(a) Purpose (b) Scope and application (c) Definitions (d) Hazard determination (e) Written program (f) Labeling (g) Material safety data sheets (MSDSs)

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CONTENTS

(h) Training (i) Trade secretsAppendix A - Health Hazard DefinitionsAppendix B - Hazard DeterminationAppendix C - Information SourcesAppendix D -“Trade Secret”Appendix E - Guidelines for Employers

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(a) Purpose

To insure that the hazards of all chemical produced in or imported into the U.S. are evaluated

Hazards transmitted toemployers employees

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(b) Scope and Application

Applies to any chemical which is known to be present in the workplace

– employee may be exposed

– actual or potential exposure

– consumer products

– laboratory coverage

– sealed containers

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Who’s Covered

Chemical manufactures Importers and distributorsEmployers that use chemicals

use means to package, handle, react, or transfer.

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(c) Definitions

Chemical - any element, chemical compound, or mixture of elements and/or compounds

Hazardous chemical - any chemical which is a physical or health hazard

?

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Basic Program Elements

(d) Hazard Determination

(e) Written Program

(f) Labeling

(g) MSDSs

(h) Employee Training

HCP

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(d) Hazard Determination

Required for– chemical manufacturers– importers

Procedures must be– written– available upon request (5 working days)– Appendix C - Information Sources

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(d) Hazard Determination

Accuracy and adequacy of information on labels and MSDSs

Do not have to address each chemical listed individually

Must include– physical hazards– health hazards

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(e) Written Hazard Communication Program

Required for all employers and

multi-employer worksites – when potential for exposure exists

• for employees

• for employers

Review prior to implementation

HCP

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(f) Labeling

(g) Material safety data sheets (MSDSs)

(h) Training

List of hazardous chemicals

Non-routine tasks

Multi-employer worksites

(e) Written Hazard Communication Program

HCP

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(e) Written Hazard Communication Program

Labeling– designated person

• in-plant containers• shipped containers

– description of labeling system– written alternatives to labeling of in-plant

containers– Procedures to review

HCP

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(e) Written Hazard Communication Program

MSDSs– designated person to obtain

MSDSs– maintenance of MSDSs

• notebooks, electronic, back-up system, access

– procedures to follow to obtain MSDSs– procedures for updating MSDS

• chemical manufacturers and importers

HCP

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(e) Written Hazard Communication Program

Training

– designated person

– when to train

– who to train

– hazards introduced by other employers

HCP

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(e) Written Hazard Communication Program

Other topics– list of hazardous chemicals – non-routine tasks– unlabeled pipes– multi-employer worksites

• MSDS access

– availability of written program

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(f) Labeling

Must include– identity of the hazardous chemical– hazard warning

• physical and/or health

– name and address of chemical manufacturer, importer, or responsible party

• if shipped

LABEL

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Labeling Exception:

– Portable Containers

• Portable containers which are intended on for immediate use by the employee who performs the transfer of hazardous chemical from a labeled container are EXEMPT from labeling requirements.

(f) LabelingLABEL

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(f) Labeling

Minimally labels must include

– identity of the hazardous chemical

– hazard warning

– name and address of chemical manufacturer, importer, or responsible party

LABEL

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(f) Labeling

Stationary containers

– identity of the hazardous chemical

– hazard warning

• physical and/or health

LABEL

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(f) Labeling

LegibleProminently displayedEnglish

– additional languages

Cross referenced with – MSDS– hazardous chemical

inventory list

LABEL

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(f) Labeling

Alternate labelingEffectiveness

– Appendix A (effective labeling)– hazardous effects

• target organs

Evaluate in-plant labeling systems– training– MSDS procedures

LABEL

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(g) Material Safety Data Sheets

Chemical manufacturers and importers

– develop or obtain MSDSs

– Review a representative number

• Appendixes C and D

MSDS

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(g) Material Safety Data Sheets

MSDSs or each hazardous chemicalAre each of the 12 elements addressed?Are all sections completed?Missing MSDSs/labelsMulti-employer worksitesReferral procedures

MSDS

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Material Safety Data Sheets

Applicable ANSI Documents (212) 642-4900

Material Safety Data Sheets (1993)• ANSI/SAE AMS 2825A• $ 24.00 + S&H

Preparation of MSDSs (1993)• Z 400.1• $ 75.00 + S&H

MSDS

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(h) Training

Required for all employees

– exposed to hazardous chemicals

– potential for exposure to hazardous chemicals

Substance specific training requirements take precedence

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(h) Training

Review training program with management

Provided – for new employees– upon initial assignment

FrequencyTraining recordsContract training

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Things all employees should know about their HCP

Labeling requirements

Type of labeling system

Location(s) or operation(s) utilizing hazardous chemicals

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Physical and health hazards of chemicals

Methods/observations used to detect presence or release

Things all employees should know about their HCP

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What’s in the drum or bag?

What is the safest way to handle the material?

What if it spills, leaks, or ignites?

Things all employees should know about their HCP

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Protective measures

Location of the written HCP

Name of designated hazard communication coordinator

Location of MSDSs and how to obtain a copy

Things all employees should know about their HCP

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(i) Trade Secrets

Emergencies

Non-emergencies

– written request

– exposure levels

MSDS

CONFIDENTIAL

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Exempt

Hazardous waste

Consumer products

Articles

– tables, upholstery,tires, adhesive tape, etc.

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Exempt

Wood and wood products

– not wood dust

– not with chemical additives

PNOR

– particulates not otherwise regulated

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Checklist for Compliance

Obtain a copy of the rule.

Read and understood the requirements.

Assigned responsibility for tasks.

Prepared an inventory of chemicals.

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Checklist for Compliance

Ensured containers are labeled.

Obtained MSDS for each chemical.

Prepared written program.

Made MSDSs available to workers.

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Checklist for Compliance

Conduct training of workers.

Established procedures to maintain

current program.

Established procedures to evaluate

effectiveness.