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Articles

• Articles are exempt from the HazCom standard requirements.
• If a hazardous chemical can be expected to be released only when the item is repaired, that is not considered part of its normal condition of use.

“Articles” are exempt from the requirements of the HazCom standard (HCS). An article is defined as a manufactured item other than a fluid or particle which:

• Is formed to a specific shape or design during manufacture,
• Has end use function(s) dependent in whole or in part upon its shape or design during end use, and
• Must not release more than very small quantities (e.g., minute or trace amounts) of a hazardous chemical, or pose a physical hazard or health risk to employees under normal conditions of use.

It may be difficult to define what is considered “normal conditions of use.” An employer may have a manufactured item that meets the definition of an article, but if it is burned, it produces a hazardous byproduct. The question then becomes, is burning “normal use” for the product? If burning occurs during its normal use, then it cannot be exempted as an article.

Normal use does not include incidental exposure.

If a hazardous chemical can be expected to be released only when the item is repaired, that is not considered part of its normal condition of use. The item would be considered an article under the HCS, and thus exempted. Stainless steel tables, vinyl upholstery, and tires are such articles.

Basically, if the product will be processed in some way after leaving the manufacturing site — heated, welded, glued, sawed, etc. — and a hazardous chemical could be emitted, it probably will not qualify for the article exemption.

Items that are covered by HCS include (this is not an exhaustive list):

• Bricks,
• Metal ingots,
• Wood products where the hazard is not just combustion (e.g., wood that is cut is covered since the sawdust created during the cut creates a respiratory hazard),
• Hazardous drugs not in final form or a solid (e.g., drugs that are crushed or dissolved prior to administration),
• Combustible dusts,
• Simple asphyxiants,
• Welding rods/wire,
• Acid batteries,
• Switches with mercury in them when a certain percentage break under normal conditions of use,
• Fabric treated with formaldehyde where downstream garment manufacturing employees will be exposed when making clothing,
• Consumer products not used in the quantities and the manner that a consumer would use them, and
• Oil and gas products.

Laboratories and handling chemicals in sealed containers

• Laboratories do not need to have a written HazCom program and list of chemicals.
• Certain actions must be done in work operations where employees only handle chemicals in sealed containers.

Laboratories

In laboratories, employers do not have to have a written HazCom program and list of chemicals. They do have to:

• Make sure that labels on incoming containers of hazardous chemicals are not removed or defaced,
• Maintain any safety data sheets (SDSs) that are received with incoming shipments of hazardous chemicals,
• Make SDSs readily accessible during each work shift to laboratory employees when they are in their work areas, and
• Provide laboratory employees with information and training on the chemical hazards in the work area, methods to detect exposures, ways to protect themselves, and so on.

Handling chemicals in sealed containers

In work operations like warehouses, where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, employers must:

• Make sure container labels on incoming containers of hazardous chemicals are not removed or defaced,
• Maintain copies of any safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals,
• Obtain an SDS as soon as possible for sealed containers of hazardous chemicals received without a safety data sheet if an employee requests it,
• Make SDSs available during each work shift to employees when they are in their work area(s), and
• Provide employees with information and training in accordance with 1910.1200(h) as needed to protect them in the event of a spill or leak of a hazardous chemical from a sealed container.

Mixtures and by-products

• It is recommended to use the test data for the complete mixture, if available.
• During hazard determination or hazard classification, account for any hazardous by-products.

Chemical manufacturers and importers evaluating chemical mixtures must follow the procedures described in Appendices A and B to 1910.1200. Under the HazCom standard, it is recommended to use the test data for the complete mixture, if available. If not, then there are other options for classifying the mixture using “bridging principles” based on ingredients and data.

Hazard determination or hazard classification must anticipate the full range of downstream uses of products and account for any hazardous by-products which may be formed. Decomposition products produced during normal conditions of use or in foreseeable emergencies for the product are covered. For example, a manufacturer of gasoline must inform downstream users of the hazards of carbon monoxide, since carbon monoxide is a hazardous chemical and is “known to be present” as a by-product resulting from the use of gasoline.

Testing is not required

• Testing, unlike collection and analysis of data, is not required for the HazCom standard.

The standard does not require the testing of chemicals — only the collection and analysis of currently available data. Nevertheless, if no data is available or it is questionable, testing should be considered when hazardous properties are suspected.

Tests conducted according to internationally recognized scientific principles can be used for purposes of hazard classification. In the case of health hazards, for example, this includes the results of valid in vitro tests, relevant animal data, and human experience, such as epidemiological and clinical studies, and well-documented case reports and observations.

If no hazards are found, the manufacturer, importer, or employer is not required to take further action pertaining to the evaluated chemical.

Hazard class and category

• Classify substances by “Hazard Classes” and assign a “Category” for severity.
• Hazard classes are further sub-divided into hazard categories.
• Low hazard categories mean higher severity in a class.

OSHA requires that these parties evaluate and classify each substance using pre-determined “Hazard Classes” (e.g., “flammable gas”). After that has been done, the manufacturer or importer must then assign a “Category” to show severity of the hazard. OSHA uses “hazard class” and “hazard category” to break down the hazardous effects of chemicals or mixtures into levels of severity. OSHA does not classify nor approve of classification of chemicals.

OSHA says the breakdown of hazard classes into categories that reflect different severities or levels of effect provide employers and employees with more precise information to:

• Understand the hazards,
• Determine the risks in the workplace, and
• Respond to exposure incidents.

A “hazard class” is defined as “the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity.” Most hazard classes are further sub-divided into categories of hazard.

The definitions of the physical or health hazard classes are specific and detailed. Each hazard or endpoint (e.g., explosives, carcinogenicity) is a hazard class.

The definition of “hazard category” is the division of criteria within each hazard class that compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally. The lower the category number, the higher the severity within that class (for example, a Category 1 flammable gas is more flammable than a Category 2). Depending on the class, there can be up to five categories.

The HazCom standard includes the classification criteria for 11 health hazard classes. In many cases, a chemical may pose more than one type of health hazard. OSHA’s guidance on determining health hazards can be viewed in Appendix A to 1910.1200, Health Hazard Criteria.

OSHA’s guidance on determining physical hazards can be viewed in Appendix B to 1910.1200, Physical Hazard Criteria.

OSHA defined hazards and HNOC

• Defined hazards include simple asphyxiants and combustible dust.
• HNOC is also mentioned in the definition of the term hazardous chemical.

OSHA has added two “defined hazards” into the HazCom standard to address known hazards that have no corresponding Globally Harmonized System (GHS) classification. These OSHA defined hazards are:

• Simple asphyxiant — A substance or mixture that displaces oxygen in the ambient atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to unconsciousness and death.
• Combustible dust — Finely divided solid particulates of a substance or mixture that pose a flash-fire hazard or explosion hazard when dispersed in air or other oxidizing media.

You will also find the term “hazard not otherwise classified” (HNOC) mentioned in the definition of hazardous chemical. HNOC is an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health hazard classes addressed in 1910.1200. This does not extend coverage to adverse physical and health effects for which there is a hazard class addressed in 1910.1200, but the effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not been adopted by OSHA (e.g., acute toxicity Category 5).

Hazardous wastes

• Many wastes not covered by RCRA do not fall under the scope of the HazCom standard.

The HazCom rule does not apply to “hazardous waste as such term is defined by the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976, as amended (42 U.S.C. 6901 et seq.), when subject to regulations issued under that Act by the Environmental Protection Agency.”

A vast majority of wastes that are not covered by the Resource Conservation and Recovery Act (RCRA) do not exhibit any hazardous properties, and therefore do not fall under the scope of the HazCom standard. However, a small subset of these waste materials exhibit some level of hazard (such as toxicity) if ingested, injected, absorbed, or inhaled in significant quantities. Examples of hazardous wastes that are not covered by RCRA include:

• Non-RCRA regulated commercial solid waste.
• Electronic wastes (recycled computers, cell phones, electronic devices).
• Household hazardous wastes.
• Waste products that are clearly non-RCRA hazardous wastes, but may require a Department of Transportation (DOT) hazard label because of chemical properties.

When waste does not meet the definition of “hazardous waste” under the RCRA regulations, it is covered by the HazCom standard if it meets the standard’s definition of “hazardous chemical” AND it does not fall under any of the exemptions listed under 1910.1200(b)(6).

For a non-RCRA waste product, the HazCom standard does not require that the waste generator to create its own label or safety data sheet (SDS); however, any chemical hazard information, including available labels and SDSs, received by the waste generator from upstream must be passed downstream with the non-RCRA waste product. For mixtures of non-RCRA wastes, it is acceptable to provide multiple SDSs downstream. This would also apply to disposal of mixtures of non-RCRA waste product from laboratories, manufacturers, importers, and distributors.

Required pictograms under HazCom

• Pictograms are required on labels of shipped containers and help identify physical and health hazards.

Pictograms are one of the required elements on labels of shipped containers and help identify physical and health hazards.

On shipped containers, pictograms consist of a red square frame set at a point with a black hazard symbol on a white background, sufficiently wide to be clearly visible. On workplace (or in-plant) labels only, pictograms may have a black border, rather than a red border.

The Globally Harmonized System (GHS) uses nine pictograms, but the Occupational Safety and Health Administration (OSHA) did not adopt the environmental pictogram. It may be seen on labels and safety data sheets (SDSs) to convey environmental hazards, and it may provide useful information to use in managing chemicals, but its use is not required by the HazCom standard.

Label design and in-house labeling

• Labels must be legible and pictograms, signal words, and hazard statements should be together on the label.
• Maintain the labels of any containers received already labeled from the supplier.

The label format or layout is not specified by the Occupational Safety and Health Administration (OSHA), except to require that the pictograms, signal word, and hazard statements should be located together on the label. OSHA states that the three elements should appear in “the same field of view.”

There are also no guidelines or requirements on label size. However, OSHA says that labels must be legible without the use of any aid except corrective lenses if the person reading the label normally must wear glasses. If the label is not legible, it is not in compliance.

In-house labeling

For those containers that are received already labeled from the supplier, simply maintaining the label on the container is the best and easiest option. If materials are transferred in the workplace from labeled containers into other containers, the employer must ensure that these are labeled as well, unless they fall under the portable container exemption.

In-house containers of hazardous chemicals must be labeled, tagged, or marked with either:

• The same label information required on shipped containers (apart from the supplier identification), or
• A product identifier and words, pictures, symbols, or some combination that provides general hazard information regarding the physical and health hazards of the hazardous chemical.

The employer shall ensure that workplace labels or other forms of warning are:

• Legible,
• In English, and
• Prominently displayed on the container, or readily available in the work area throughout each work shift.

For in-house purposes, the employer can re-label using the label elements found on the original, shipped container, or use an alternative labeling system, such as the National Fire Protection Association (NFPA) or the Hazardous Materials Identification System (HMIS).

Employer responsibilities

• Safety data sheets are required for each hazardous chemical used in the workplace.

Employers must have a safety data sheet (SDS) for each hazardous chemical which they use. Do not allow employees to use a chemical if the SDS for that chemical has not been received. Employers assume no responsibility for the content and accuracy of the SDS provided to them by the manufacturer, importer, or distributor, unless the employer changes the SDS.

The Occupational Safety and Health Administration (OSHA) requires that the SDS be written in English. However, this should not prevent an employer with employees who speak English as a second language from providing data sheets in other languages.

For workplaces such as warehouses or retail sales where employees do not normally open sealed containers of hazardous chemicals, that employer need only maintain the SDSs that are sent with incoming shipments. If an employee requests an SDS and it is not available, the employer must contact the manufacturer and request one. The primary difference is that the warehouse or hardware store does not have to maintain a complete file of data sheets. This simplifies the paperwork for operations where hundreds of different chemicals pass through but are never opened or worked with.

If you’re required to have SDSs for hazardous chemicals, you may be subject to EPA SDS reporting and Tier II reporting at 40 CFR 370. This applies to ANY facility owner/operator that is:

• Required to prepare or have available an SDS or material safety data sheet (MSDS) for a hazardous chemical under 29 CFR 1910.1200; AND
• That hazardous chemical is not exempt under 1910.1200(b)(6) or 40 CFR 370.13; AND
• That hazardous chemical is present at any one time at or above its threshold level during the previous year. Under EPA’s regulations at 40 CFR 370 this means:
  • A hazardous chemical that is an extremely hazardous substance (EHS) is present at the facility at any one time in an amount equal to or greater than 500 pounds (227 kg — approximately 55 gallons) or the threshold planning quantity (TPQ), whichever is lower.
  • A hazardous chemical that is not an EHS is present at the facility at any one time in an amount equal to or greater than the threshold level for that hazardous chemical. Threshold levels for such hazardous chemicals are described below:
    1. For any hazardous chemical that does not meet the criteria in (2) or (3) below, the threshold level is 10,000 pounds (or 4,540 kg).
    2. For gasoline at a retail gas station, the threshold level is 75,000 gallons (approximately 283,900 liters) (all grades combined), but only under conditions listed at 40 CFR 370.10(a)(2)(ii).
    3. For diesel fuel at a retail gas station, the threshold level is 100,000 gallons (approximately 378,500 liters) (all grades combined), but only under conditions listed at 40 CFR 370.10(a)(2)(iii).

Readily accessible

• Safety data sheets must be readily accessible to all workers during each shift.
• Hard copies of safety data sheets must be available in case of medical emergency.

The Occupational Safety and Health Administration (OSHA) requires that safety data sheets (SDSs) be “readily accessible” to all affected workers during each work shift when they are in their work area. If any barriers to immediate access to SDSs exist, then the employer is not complying with the HazCom standard. Factors to consider include:

• Must employees ask a supervisor or other management representative for the SDS?
• Can the employees access the SDSs during each work shift and in each work area?
• Have employees been trained on how to access SDSs and where they are kept?
• Do employees know who they can go to if they have questions?

If the employer is maintaining the SDSs on a company website or with an off-site/web-based SDS service provider that provides them electronically, they must ensure that:

• All employees have adequate access, with no restrictions;
• There is a backup procedure or system in place in case the system is not functioning;
• Employees are trained on how to access the SDSs both on the computer and the backup system, and;
• Employees can receive a hard copy if desired and in cases of emergency. It is not acceptable to only transmit the information verbally.

In the event of a medical emergency, hard copy SDSs must be immediately available to medical personnel. There must be an adequate back-up system for rapid access to SDSs in the event of power outages, equipment failures, or other system failure.

Multi-employer worksites

• The employer bringing a hazardous chemical onto a multi-employer worksite must inform the other employers of the presence of the hazardous chemical.
• A label or SDS does not need to be created for a non-RCRA waste product.

The employer bringing a hazardous chemical onto a multi-employer worksite must inform the other employers of the presence of the hazardous chemical and the availability of the safety data sheet (SDS). If an intermediary employer, such as a general contractor, holds and provides access to the SDSs, the intermediate employer is responsible for ensuring the availability of the SDS(s).

If SDSs are not available because a subcontractor or immediate employer failed to make them readily accessible, that employer will be cited.

Air emissions

• Employee exposure to any air emissions that are being created in the facility must be accounted for.

Hazardous materials can also be created as a by-product of a process or procedure in a facility, such as from:

• Welding operations,
• Gasoline-powered forklift vehicles,
• Power tools with internal combustion motors, and
• Vehicle bay exhaust.

Employee exposure to any air emissions that are being created in the facility must be accounted for. An employer may need to contact the supplier of the welding rods for help in tracking down the appropriate SDS.

Also, do not overlook gasoline and carbon monoxide. An SDS is required for the fuels used by vehicles such as lift trucks, tractors, or automobiles. Employees should be aware of the potential for exposure to carbon monoxide and associated physical hazards of petroleum fuel products such as fire and explosion.

SDS format and content

• Safety data sheets must follow a standardized, 16-section format.
• Information within each section isn't required to be in any particular order.

The Occupational Safety and Health Administration (OSHA) requires that safety data sheets (SDSs) use a standardized, 16-section format. The sections have generally been organized so that the information of most use to exposed workers, emergency responders, and others who do not need extensive technical detail is in the beginning of the SDS, while the more technical information most commonly read by health and safety professionals is located in the later sections. While each section of the SDS must contain all the specified information, it’s not required to be in any particular order within each section.

Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., firefighting). This should be helpful to those that need to get the information quickly.

Sections 9 through 11 and Section 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision.

The SDS must contain headings for Sections 12 through 15, but OSHA will not enforce the content of these sections because they concern matters handled by other agencies such as the Environmental Protection Agency (EPA) and the Department of Transportation (DOT).

Refer to Appendix D of 29 CFR 1910.1200 to see an all-in-one list of the mandatory and nonmandatory sections and subsections of an SDS.

Conducting training

• Training needs to be provided at no cost to the employees, and employees must be paid for the time they spend in training.
• After the training, workers should understand how to read labels and SDSs, understand what information is in these documents, and understand how to access them.
• Training must be provided prior to the initial job assignment.

Information and training may be done either by individual chemical, or by categories of hazards, such as flammability or carcinogenicity. If there are only a few chemicals in the workplace, then an employer may want to discuss each one individually. Where there are large numbers of chemicals, or the chemicals change frequently, training based on the hazard categories such as flammable liquids, corrosive materials, or carcinogens may make more sense.

Training must be provided at no cost to the employees, and employees must be paid for the time they spend in training.

Focus on the specific chemical hazards in the workplace. Explain:

• How to detect the presence or release of the chemical;
• The visual appearance or odor when the chemical is being released;
• How any monitoring devices work and what they indicate;
• The physical and health effects of the chemicals;
• What first aid measures should be used in the event of exposure or overexposure, and
• Where on the safety data sheet (SDS) this information can be found.

The Occupational Safety and Health Administration (OSHA) does not expect that workers will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools.

When to train

Prior to the initial job assignment, each employee who has exposure risks to hazardous chemicals must be provided information and training. Additional training must be done whenever a new physical or health hazard is introduced into their work area.

Training temporary workers/contract employees

The responsibility for training temporary or contract employees is shared between the employment agency and the host employer. The employment agency has the primary responsibility to provide generic HazCom information and training to their employees. This should include information on labels and other forms of warning, the format and content of SDSs, and other employee information and training required by the HazCom Standard.

The contracting employer is responsible for providing site-specific training and has the primary responsibility to control potential exposure conditions. This training should include identifying and communicating information about site-specific chemical hazards, ensuring appropriate labeling of chemical containers, providing access to SDSs, and providing appropriate personal protective equipment (PPE). The HazCom training provided to temporary workers should be identical or equivalent to the training given to the host employers’ own employees.

As a recommended practice, the employment agency and contracting employer should discuss responsibility for each aspect of HazCom training and inform the other employer when the training is completed. The details of the particular training to be performed can be clearly stated in the language of the contract between the employers and in the host employer’s written HazCom program.

Effective training and refresher training

• Training must accommodate employees who typically speak a language other than English and those who have limited vocabularies.
• Refresher training is not required annually.

Effective training

The Occupational Safety and Health Administration (OSHA) requires that employers provide “effective” training, that is, in a manner and language that their employees can understand. For information and training to be effective, the workers in the training must comprehend the hazards in the workplace and ways to protect themselves.

If employers customarily need to communicate work instructions or other workplace information to employees in a language other than English, they will also need to provide safety and health training to employees in the same manner.

If the employee’s vocabulary is limited, the training must account for that limitation. If employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation. It is not sufficient to either just read material to the workers, or simply hand them material to read.

The employees must carry the knowledge from the training into their daily jobs. For example, if asked, they should know where hazardous chemicals are present in their work area and should also know how to protect themselves. Employees must be aware that they are exposed to hazardous chemicals, know how to read and use labels and safety data sheets (SDSs), and follow the protective measures established by the employer.

Refresher training

Training must be provided to affected employees when new hazards are introduced into the workplace (not necessarily new chemicals). Refresher training is not required on a routine basis, such as annually. However, receiving a new SDS or chemical compels the employer to evaluate the information provided in the SDS and to decide whether the new product represents a new health or physical hazard to employees.

Who can train?

• If an employee has not received training or is not adequately trained, the employer who provides the day-to-day supervision of the employee will be held responsible.
• No formal certification is required to conduct HazCom training.
• Records of employee training are not required by the HazCom standard but are recommended.

The controlling employer is responsible

The employer who provides the day-to-day supervision of the employee is ultimately responsible for ensuring that workers are adequately trained.

The experience provided by a previous employer or other entity may relieve an employer of some of the burdens of training that worker. So long as training is adequate, general training may be provided by:

• The current employer
• A past employer
• An employee union
• Any other entity

If an employee has not received training or is not adequately trained, the current employer will be held responsible regardless of who trained that particular employee.

The Occupational Safety and Health Administration (OSHA) does not specify who can conduct HazCom training, nor is any formal certification required to do so.

The trainer must be familiar with:

• The requirements of the standard that apply to the workplace;
• The hazardous chemicals in the workplace to which workers are potentially exposed, as well as the types of hazards they pose;
• The hazard communication program implemented in the workplace; and
• The protective measures being employed in the workplace to prevent adverse effects from occurring.

In addition to being thoroughly familiar with the material to be covered in the training, the trainer should be aware of the facilities available for the training, including the physical location, the type of equipment (e.g., a PowerPoint projector, computer), and plan the training session accordingly based on the conditions.

The employer may determine who is qualified to do training. Whoever does the chemical-specific training should be familiar with the safe handling requirements of those chemicals.

Documentation

It is an industry best practice to maintain records of HazCom training, although the standard does not require it. By keeping training records the employer can ensure that all employees have received appropriate and timely training as needed. Companies can also demonstrate to the Occupational Safety and Health Administration (OSHA) that they are complying with the training requirement.

Summary of program requirements and exempt workplaces

• The written hazard communication program must include information on labels and other forms of warning, SDSs, and training.
• In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, a written hazard communication program is not required, although these operations have other responsibilities under 1910.1200(b)(4).

Summary of requirements

All employers with employees who are exposed or potentially exposed to hazardous chemicals known to be present in their workplaces, must develop, implement, and maintain at each workplace a written hazard communication program that includes labeling and other forms of warning, safety data sheets (SDSs), and training.

Employers on multi-employer worksites who do not use hazardous chemicals, but whose employees are exposed to the chemicals used by other employers on the worksite, are required to have a program and train their employees on the hazards of the chemicals in the work areas.

The Occupational Safety and Health Administration (OSHA) will be looking for the following elements in a written program to ensure compliance with the HazCom standard:

• A list of the hazardous chemicals known to be present in the workplace that matches the identifier on the container label and the SDS.
• Designation of person(s) responsible for ensuring labeling of in-plant containers.
• Designation of person(s) responsible for ensuring labeling of shipped containers (if any).
• Description of any in-plant labeling system(s) (if used).
• Description of any labeling alternatives used in the facility (if any).
• Description of HazCom training provided to employees.
• Procedures to review and update label information when necessary.
• Methods used to inform employees of the hazards of non-routine tasks.
• Methods used to inform employees of the hazards of unlabeled pipes in their work areas.
• How the employer will comply on multi-employer worksites.

Exempt workplaces

In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, such as in warehouses or consumer outlets, a written hazard communication program is not required. However, these operations have other obligations under the standard at 1910.1200(b)(4).

Laboratories, whether completely or partially exempt from the HazCom standard, do not need to complete a written program, even if other portions of the standard apply. See 1910.1200(b)(3).

Chemical inventory and assessing workplace hazards

• The written HazCom program must include a list/inventory of the hazardous chemicals known to be present in the workplace.
• The inventory must use the “product identifier” for each chemical that aligns with the SDS and label.
• Identify any chemicals generated in the work operations.

Chemical inventory/list

The written HazCom program must include a list of the hazardous chemicals known to be present in the workplace. The list must include all hazardous chemicals present, even if the chemicals are stored or are not in use. The list can be maintained by work area or for the workplace as a whole.

Compiling the list for the entire workplace may be most suitable for very small facilities, while for larger workplaces, it may be more convenient to compile lists of hazardous chemicals by work area and then assemble them together as the list for the workplace. As new chemicals are purchased, the list should be updated.

The inventory must use the “product identifier” for each chemical that aligns with the safety data sheet (SDS) and label. It may be kept by product name, common name, or chemical name, as long as the identity used on the list matches that used on both the SDS and the label so that these documents can be cross-referenced.

The Occupational Safety and Health Administration (OSHA) does not specifically require that the list contain any other information.

Assess for workplace hazards

To prepare a comprehensive chemical list perform a department-by-department search for every chemical present. Include:

• Cleaning supplies, such as bathroom and window cleaners;
• Grounds maintenance chemicals, such as weed killers and fertilizer;
• Vendor samples being used on a trial basis;
• Fuels;
• Paints; and
• All chemicals used in daily operations.

Identify any chemicals generated in the work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Some other suggestions include:

• Read labels provided by suppliers for hazard information,
• Make a list of all chemicals that are potentially hazardous,
• Note the storage and use location(s) of the products, and
• Note the hazards as found on the label.

Purchasing records may also help, and employers should establish procedures to ensure that purchasing procedures result in receiving safety data sheets (SDSs) before a material is used in the workplace. Prior to purchasing chemicals, review the hazards of the chemicals and evaluate if less hazardous chemicals can be used instead.

What to look for

While compiling this inventory, consider listing the substances separately by department. Employers will find that it makes it easier to conduct employee training to know which chemicals are used in which departments.

Program elements for SDSs and labeling

• 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.

Program element for employee information and training

• The written program should provide details on six different main points regarding employee information and training.
• Describe how employees will be informed of the hazards of non-routine tasks and of chemicals contained in unlabeled pipes in their work areas.

The written program should provide details on six different main points regarding employee information and training:

1. The person responsible for conducting training.
2. Which employees will receive training (if training all employees, state this).
3. The format of the training program that is used (audiovisual, classroom instruction, etc.). If any handouts are given to employees, include copies of them.
4. Procedure to train new employees at the time of their initial assignment.
5. Procedure to retrain all employees when a new hazard is introduced. For example, will safety department personnel track the training and retraining, or will area supervisors?
6. How training is documented (such as a copy of a training attendance sheet signed by employees upon completion of their training, if applicable).

Hazards of non-routine tasks and unlabeled pipes

To cover all situations of employee exposure, the written program must include:

1. The methods used to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels). What procedures are in place to ensure that those jobs that are not part of the weekly or monthly facility functioning fall under the employee training system?
2. How employees will be informed of the hazards of chemicals contained in unlabeled pipes in their work areas.

Multi-employer worksites and need for periodic program review

• Include how on-site access to safety data sheets will be provided if there is more than one employer operating on a site.
• Include how employers will be informed of precautionary measures and on-site labeling system differences.

Multi-employer worksites

Where there is more than one employer operating on a site, and employees may be exposed to the chemicals used by each employer, the employer’s written hazard communication program must address:

• How on-site access to safety data sheets (SDSs) will be provided to the other employer(s).
• How such employers will be informed of needed precautionary measures.
• How such employers will be informed of the on-site labeling system if it is different from the labels specified for shipped containers under the standard.

Employers in multi-employer worksites who do not use hazardous chemicals, but whose employees are exposed to the chemicals used by other employers, are required to have a program and train their employees on the hazards of the chemicals in the work areas.

Need for periodic review

Because the hazard communication program must remain up to date, it will be necessary to periodically evaluate and reassess it. The information in the written program must be accurate.

Review and revise the program as appropriate to address changing conditions in the workplace, such as the addition of new chemicals, updated hazards from chemicals currently used, changes in processes that affect exposures, required changes to personal protective equipment (PPE) or training, and so on.

Assigned responsibilities

• Assign someone to coordinate the implementation of hazard communication.
• Include HazCom in your emergency action plan because these plans will result in fewer and less severe employee injuries and less structural damage during emergencies.

To ensure an effective hazard communication program, and address all the necessary components, responsibility for implementation of hazard communication should be assigned to someone to coordinate. The person designated for overall program coordination should then identify staff to be responsible for particular activities, such as training.

Those people designated as responsible for the different parts of the program should also be current, and those people should be carrying out their responsibilities under the program.

Many companies have found it convenient to include on their purchase orders the name and address of the person designated in their company to receive safety data sheets (SDSs) to help maintain a complete set.

Program coordinators should routinely walk around the workplace to check that containers are labeled as required and that workers are following established work practices to protect themselves from chemical exposure. Proactive monitoring of the workplace is critical to ensuring compliance with the HazCom standard.

Include HazCom in EAP

An emergency action plan (EAP) is a written document required by certain Occupational Safety and Health Administration (OSHA) standards which directs employer and employee actions during workplace emergencies. Well-developed emergency plans and proper employee training (such that employees understand their roles and responsibilities within the plan) will result in fewer and less severe employee injuries and less structural damage to the facility during emergencies.

Portions of the HazCom plan may be included in the EAP, or portions of the EAP may be included in the HazCom training as it relates to workplace emergencies and spills.