• The written program should include six elements for SDSs and should address six points for labeling

Safety data sheets

The written program should include the following elements for safety data sheets (SDSs):

1. The person responsible for obtaining/maintaining the SDSs;
2. Where the SDSs are kept in the facility, and how employees can obtain access to them;
3. The procedure for reporting a missing SDS;
4. The procedure to be followed when the SDS is not received at time of first shipment;
5. A list of those chemicals without SDSs and copies of request letters sent to manufacturer or supplier;
6. If SDSs are generated, the procedure for updating the SDS when new and significant health information is found.

Any written requests from employees for copies of SDSs and dated responses may be kept in this file.

Labels and labeling

The written program should address the following points for labels:

1. Designation of the person responsible for ensuring labeling of in-plant containers;
2. Designation of the person responsible for ensuring labeling of shipped containers;
3. A complete description of any workplace labeling system used which is different from the HazCom labeling at 1910.1200(f)(1) (include samples of labels used);
4. Description of written alternatives to labeling of in–plant containers, if used (for example, putting the label information on batch tickets for stationary process tanks, using posters for air emissions);
5. Procedures to review and update label information when necessary, to ensure that labels that fall off or become unreadable are immediately replaced;
6. A copy of posters used (if any) to inform employees about the law, or where HazCom standard information is located.