['Medical and Exposure Records', 'Hazard Communication']
['Hazard Communication', 'Medical and Exposure Records']
09/03/2024
Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
...
For the purposes of 29 CFR 1910.1200(e) whenever hazardous chemicals in the workplace are obsoleted, the employer must:
- Update the hazardous chemical inventory list, which is part of the written Hazard Communication Program; and
- Update the Hazard Communication Program as necessary.
The employer should also remove the safety data sheet (SDS) for the obsoleted chemical from its employee SDS stations.
For the purposes of a different regulation, 29 CFR 1910.1020(d), an employer must preserve and maintain employee exposure records for 30 years. SDSs indicating that the material may pose a hazard to human health are considered employee exposure records. In the absence of SDSs, a chemical inventory or any other record which reveals where and when a toxic substance or harmful physical agent was used and its identity is also an employee exposure record. SDSs must be kept for those chemicals currently in use that are affected by 1910.1200(g).
However, once a hazardous chemical in the workplace is obsoleted, the employer has the choice of preserving and maintaining for 30 more years:
- The obsolete SDS, or
- A record concerning the identity of the hazardous chemical, where it was used, and when it was used.
While OSHA does not “specifically” require the employer to document the removal date, it may be helpful to record that date so that an employer knows when the obsolete SDS may be disposed of after 30 years, if that option is taken. If the employer chooses to record the chemical identity and where and when the chemical was used, the employer will indirectly document the removal date because it will be included in the timeframe the chemical was used.
Note that if an employer just keeps the SDS without the other information, the SDSs don’t really meet the original “intent” of 1910.1020. That’s why OSHA “recommends” that if you opt to keep SDSs you also include the when and where information, even though it is not mandated when the SDS option is taken.
READ MORESHOW LESS
['Medical and Exposure Records', 'Hazard Communication']
['Hazard Communication', 'Medical and Exposure Records']
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 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.