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