['Medical and Exposure Records', 'Hazard Communication']
['HazCom Written Program']
05/09/2022
...
Standard Number: 1910.1020; 1910.1200
July 31, 1989
Dr. Lynn A. Corson
Civil Engineering Building
Purdue University
West Lafayette, Indiana 47907
Dear Dr Corson:
This is in response to your letter of May 5, regarding the relationship between the Hazard Communication (HCS), 29 CFR 1910.1200, and Access to Employee Medical Records, 29 CFR 1910.1020, as they relate to maintenance of material safety data sheets (MSDS) and the written hazard communication program.
The HCS requires the employer to make available the written hazard communication program in accordance with the access to records provisions of 29 CFR 1910.1020. A copy of the written hazard communication program is, therefore, required to be made available upon request to employees, or their designated representative within fifteen working days at no cost to the employee or the representative. The HCS neither requires nor prohibits the printing of pocket-size copies of the program for employees.
Apart from the requirements of the HCS regarding the availability of the written hazard communication program, the Access to Employee Medical Records Standard has specific requirements for maintaining MSDSs as employee exposure records. MSDSs, when they indicate a hazard to human health, are specifically defined as employee exposure records in 29 CFR 1910.1020 and are also subject to the access to records provisions of this standard.
We hope this information is helpful to you in clarifying the requirements of these two standards.
Sincerely,
Patricia K. Clark, Acting Director
Directorate of Compliance Programs
['Medical and Exposure Records', 'Hazard Communication']
['HazCom Written Program']
UPGRADE TO CONTINUE READING
Load More
J. J. Keller is the trusted source for DOT / Transportation, OSHA / Workplace Safety, Human Resources, Construction Safety and Hazmat / Hazardous Materials regulation compliance products and services. J. J. Keller helps you increase safety awareness, reduce risk, follow best practices, improve safety training, and stay current with changing regulations.
Copyright 2025 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.