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OSHA Hazard Communication
Standard
Occupational Safety and Health Standards
for theConstruction Industry
Violations Cited - FY 99
(e)(1)(h)
(h)(1)
(f)(5)(I)
(g)(1)
Written HCP Employee Training
Employee Training
Labeling
Material Safety Data Sheets
CPL 2-2.38D
March 30, 1998
Inspection Procedures for the Hazard Communication Standard
CONTENTS
(a) Purpose (b) Scope and application (c) Definitions (d) Hazard determination (e) Written program (f) Labeling (g) Material safety data sheets
(MSDSs)
CONTENTS
(h) Training (i) Trade secrets Appendix A - Health Hazard Definitions Appendix B - Hazard Determination Appendix C - Information Sources Appendix D -”Trade Secret” Appendix E - Guidelines for Employers
(a) Purpose
To insure that the hazards of all chemical produced in or imported into the U.S. are evaluated
Hazards transmitted toemployers employees
(b) Scope and Application
Applies to any chemical which is known to be present in the workplaceemployee may be exposed
actual or potential exposure
consumer products
laboratory coverage sealed containers
Who’s Covered
Chemical manufacturesImporters and distributorsEmployers that use chemicals
use means to package, handle, react, or transfer.
(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
Basic Program Elements
(d) Hazard Determination(e) Written Program (f) Labeling(g) MSDSs(h) Employee Traininghazardous chemical inventory
(d) Hazard Determination
Required forchemical manufacturersimporters
Procedures must bewrittenavailable upon request (5 working
days)Appendix C - Information Sources
(d) Hazard Determination
Accuracy and adequacy of information on labels and MSDSs
Do not have to address each chemical listed individually
Must includephysical hazardshealth hazards
(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
(e) Written Hazard Communication
Program Labeling
designated person in-plant containers shipped containers
description of labeling systemwritten alternatives to labeling of in-
plant containersProcedures to review
(e) Written Hazard Communication
Program MSDSs
designated person to obtain MSDSsmaintenance of MSDSs
notebooks, electronic, back-up system, access
procedures to follow to obtain MSDSsprocedures for updating MSDS
chemical manufacturers and importers
(e) Written Hazard Communication
Program Training
designated person
when to train
who to train
hazards introduced by other employers
(e) Written Hazard Communication
Program Other topics
list of hazardous chemicals non-routine tasksunlabeled pipesmulti-employer worksites
MSDS access
availability of written program
(f) Labels
Must includeidentity of the hazardous chemicalhazard warning
target organ effects
name and address of chemical manufacturer, importer, or responsible party
if shipped
(f) Labels
Legible Prominently displayed English
additional languages Cross referenced with
MSDSshazardous chemical inventory list
(f) Labels
Alternate labeling Effectiveness
Appendix A (effective labeling)hazardous effects
target organs
Evaluate in-plant labeling systemstrainingMSDS procedures
(g) Material Safety Data Sheets
Chemical manufacturers and importers
develop or obtain MSDSs
Review a representative number
Appendixes C and D
(g) Material Safety Data Sheets
MSDSs or each hazardous chemical
Are each of the 12 elements addressed?
Are all sections completed? Missing MSDSs/labels Multi-employer worksites Referral procedures
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
(h) Training
Required for all employees
exposed to hazardous chemicals
potential for exposure to hazardous chemicals
Substance specific training requirements take precedence
(h) Training
Review training program with management
Provided for new employeesupon initial assignment
Employee interviews Training records Contract training
Things all employees should know about their
HCP:
Location of the written HCPName of designated hazcom
coordinatorLocation of MSDSs and how to
obtain a copy
Labeling requirementsType of labeling systemLocation(s) or operation(s)
utilizing hazardous chemicals
Things all employees should know about their
HCP:
Physical and health hazards of chemicals
Protective measures
Methods/observations used to detect presence or release
Things all employees should know about their
HCP:
(i) Trade Secrets
Evaluating MSDSs and hazard determination
Emergencies
Non-emergencies
Exempt
Hazardous waste
Consumer products
Articles
tables, upholstery,tires, adhesive tape, etc.
Exempt
Wood and wood products
not wood dust
not with chemical additives
PNOR
particulates not otherwise regulated
February 9, 1994 Changes:
Definitions:
Mobile worksites
Multi-employer worksites
informing other employers of the hazards making MSDSs available informing other employers of labeling
system
Checklist for Compliance
Obtain a copy of the rule.
Read and understood the requirements.
Assigned responsibility for tasks.
Prepared an inventory of chemicals.
Ensured containers are labeled.
Obtained MSDS for each chemical.
Prepared written program.
Made MSDSs available to workers.
Checklist for Compliance
Conducted training of workers.
Established procedures to maintain
current program.
Established procedures to evaluate
effectiveness.
Checklist for Compliance