OSHA
Hazard
Communication
Standard
Occupational Safety and Health
Standards
MSDS
for the
LABEL
General Industry
OTI 501
1
General Industry
Hazard Communication
29
CFR
1910.1200
_____________________________________
2
Violations Cited - FY 2000
(h)
– Written HCP
– Employee Training
(h)(1)
– Employee Training
(g)(1)
– Material Safety Data Sheets
(f)(5)(i)
– Labeling
(e)(1)
4
3
CPL 2-2.38D
 March 30, 1998
 Inspection Procedures for the
Hazard Communication Standard
4
CONTENTS
 (a) Purpose
 (b) Scope and application
 (c) Definitions
 (d) Hazard determination
 (e) Written program
 (f) Labeling
 (g) Material safety data sheets (MSDSs)
5
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
6
(a) Purpose
 To
insure that the hazards of all
chemical produced in or imported into
the U.S. are evaluated
 Hazards transmitted to
employers
employees
7
(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
8
Who’s Covered
 Chemical
manufactures
 Importers and distributors
 Employers that use chemicals
use  means to package,
handle, react, or transfer.
9
?
(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
10
Basic Program Elements
 (d) Hazard Determination
 (e) Written Program
 (f) Labeling
 (g) MSDSs
 (h) Employee Training
11
(d) Hazard Determination
 Required for
– chemical manufacturers
– importers
 Procedures must be
– written
– available upon request (5 working days)
– Appendix C - Information Sources
12
(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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14
15
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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
17
(e) Written Hazard
Communication Program
 (f) Labeling
 (g) Material safety data sheets (MSDSs)
 (h) Training
 List of hazardous chemicals
 Non-routine tasks
 Multi-employer worksites
18
(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
19
(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
20
(e) Written Hazard
Communication Program
 Training
– designated person
– when to train
– who to train
– hazards introduced by other employers
21
(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
22
(f) Labeling
LABEL
 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
23
LABEL
(f) Labeling
 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.
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25
LABEL
(f) Labeling
 Minimally labels must include
– identity of the hazardous chemical
– hazard warning
– name and address of chemical
manufacturer, importer, or responsible
party
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27
(f) Labeling
LABEL
 Stationary containers
– identity of the hazardous chemical
– hazard warning
• physical and/or health
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29
30
LABEL
(f) Labeling
 Legible
 Prominently displayed
 English
– additional languages
 Cross referenced with
– MSDS
– hazardous chemical
inventory list
31
(f) Labeling
LABEL
 Alternate labeling
 Effectiveness
– Appendix A (effective labeling)
– hazardous effects
• target organs
 Evaluate in-plant labeling systems
– training
– MSDS procedures
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MSDS
(g) Material Safety
Data Sheets
 Chemical manufacturers and importers
– develop or obtain MSDSs
– Review a representative number
• Appendixes C and D
33
34
MSDS
(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
35
MSDS
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
36
(h) Training
 Required for all employees
– exposed to hazardous chemicals
– potential for exposure to hazardous
chemicals
 Substance specific training
requirements take precedence
37
38
(h) Training
 Review training program with
management
 Provided
– for new employees
– upon initial assignment
 Frequency
 Training records
 Contract training
39
Things all employees
should know about their HCP
 Labeling
 Type
requirements
of labeling system
 Location(s)
or operation(s) utilizing
hazardous chemicals
40
Things all employees
should know about their HCP
 Physical
and health hazards of
chemicals
 Methods/observations
used to detect
presence or release
41
Things all employees
should know about their HCP
 What’s
in the drum or bag?
 What is the safest way to handle the
material?
 What if it spills, leaks, or ignites?
42
Things all employees
should know about their HCP
 Protective
 Location
measures
of the written HCP
 Name
of designated hazard
communication coordinator
 Location
of MSDSs and how to obtain
a copy
43
MSDS
(i) Trade Secrets
 Emergencies
 Non-emergencies
– written request
– exposure levels
44
45
Exempt
 Hazardous waste
 Consumer products
 Articles
– tables, upholstery,tires, adhesive tape,
etc.
46
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.
49
Checklist for Compliance

Conduct training of workers.

Established procedures to maintain
current program.

Established procedures to evaluate
effectiveness.
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OSHA Hazard Communication Standard