Skip to main content

Full text of "DTIC ADA400369: Hazard Communication Guidelines for Compliance"

See other formats


Hazard Communication 
Guideiines for Compiiance 


U.S. Department of Labor 

Occupational Safety and Health Administration 



OSHA3111 
2000 (Reprinted) 



Report Documentation Page 


Report Date Report Type 

00002000 N/A 

Dates Covered (from... to) 

Title and Subtitle 

Contract Number 

Hazard Communication Guidelines for Compliance 

Grant Number 


Program Element Number 

Author(s) 

Project Number 


Task Number 


Work Unit Number 

Performing Organization Name(s) and Address(es) Performing Organization Report Number 

U.S. Department of Labor Occupational Safety & Health OSHA 3111 
Administration 200 Constitution Avenue Washington, 

DC 20210 

Sponsoring/Monitoring Agency Name(s) and Sponsor/Monitor’s Acronym(s) 

Address(es) 

Sponsor/Monitor’s Report Number(s) 

Distribution/Availability Statement 

Approved for public release, distribution unlimited 

Supplementary Notes 
Abstract 

OSHAs Hazard Communication Standard (HCS) is based on a simple conceptthat employees have both a 
need and a right to know the hazards and identities of the chemicals they are exposed to when working. 
They also need to know what protective measures are available to prevent adverse effects from occurring. 
OSHA designed the HCS to provide employees with the information they need to know. Knowledge 
acquired under the HCS will help employers provide safer workplaces for their employees. When 
employees have information about the chemicals being used, they can take steps to reduce exposures, 
substitute less hazardous materials, and establish proper work practices. These efforts will help prevent the 
occurrence of work-related illnesses and injuries caused by chemicals. The HCS addresses the issues of 
evaluating and communicating chemical hazard information to workers. Evaluation of chemical hazards 
involves a number of technical concepts, and is a process that requires the professional judgment of 
experienced experts. Thats why the HCS is designed so that employers who simply use chemicalsrather 
than produce or import themare not required to evaluate the hazards of those chemicals. Hazard 
determination is the responsibility of the manufacturers and importers of the chemicals, who then must 
provide the hazard information to employers that purchase their products. 

Subject Terms 






Report Classification 

Classification of this page 

unclassified 

unclassified 

Classification of Abstract 

Limitation of Abstract 

unclassified 

UU 

Number of Pages 

33 




This informational booklet is 
intended to provide a generic, 
non-exhaustive overview of a 
particular standards-related topic. 
This publication does not itself 
alter or determine compliance 
responsibilities, which are set 
forth in OSHA standards them¬ 
selves and the Occupational 
Safety and Health Act. Moreover, 
because interpretations and 
enforcement policy may change 
over time, for additional guidance 
on OSHA compliance require¬ 
ments, the reader should consult 
current and administrative inter¬ 
pretations and decisions by 
the Occupational Safety and 
Health Review Commission 
and the Courts. 

Material contained in this publica¬ 
tion is in the public domain and 
may be reproduced, fully or 
partially, without permission 
of the Federal Government. 

Source credit is requested but 
not required. 


This information will be made 
available to sensory impaired 
individuals upon request. 

Voice phone: (202) 693-1999 


For sale by the U.S. Government Printing Office 
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328 

ISBN 0-16-049730-2 




Hazard Communication 
Guideiines for Compiiance 



U.S. Department of Labor 
Alexis M. Herman, Seeretary 

Oeeupational Safety and Health Administration 
Charles N. Jeffress, Assistant Seeretary 

OSHA3111 
2000 (Reprinted) 



Contents 


Introduction. 1 

Becoming Famiiiar with the Ruie. 2 

Identifying Responsibie Staff. 5 

Identifying Hazardous Chemicais in the Workpiace. 6 

Preparing and Impiementing a Hazard 
Communication Program. 8 

Labels and Other Forms of Warning.9 

Material Safety Data Sheets.10 

Employee Information and Training.12 

Other Requirements. 15 

Checkiistfor Compiiance. 16 

Further Assistance. 17 

Other Sources of OSHA Assistance. 18 

Safety and Health Program Management.18 

State Programs.18 

Consultation Serviees.19 

Voluntary Proteetion Programs.19 

Training and Edueation.19 

OSHA Reiated Pubiications. 21 

States with Approved Pians. 22 

OSHA Consuitation Project Directory. 25 

OSHA Area Offices. 27 


Contents 



























Introduction 


1 


OSHA’s Hazard Communication Standard (HCS) is based on a 
simple concept—that employees have both a need and a right to 
know the hazards and identities of the chemicals they are exposed to 
when working. They also need to know what protective measures 
are available to prevent adverse effects from occurring. OSHA 
designed the HCS to provide employees with the information they 
need to know. 

Knowledge acquired under the HCS will help employers provide 
safer workplaces for their employees. When employees have infor¬ 
mation about the chemicals being used, they can take steps to reduce 
exposures, substitute less hazardous materials, and establish proper 
work practices. These efforts will help prevent the occurrence of 
work-related illnesses and injuries caused by chemicals. 

The HCS addresses the issues of evaluating and communicating 
chemical hazard information to workers. Evaluation of chemical 
hazards involves a number of technical concepts, and is a process 
that requires the professional judgment of experienced experts. 

That’s why the HCS is designed so that employers who simply use 
chemicals—rather than produce or import them—are not required to 
evaluate the hazards of those chemicals. Hazard determination is the 
responsibility of the manufacturers and importers of the chemicals, 
who then must provide the hazard information to employers that 
purchase their products 

Employers that do not produce or import chemicals need only 
focus on those parts of the rule that deal with establishing a work¬ 
place program and communicating information to their workers. 

This publication is a general guide for such employers to help them 
determine what the HCS requires. It does not supplant or substitute 
for the regulatory provisions, but rather provides a simplified outline 
of the steps an average employer would follow to meet those 
requirements. 


Introduction 







2 


Becoming Familiar with the Rule 


OSHA has provided a simple summary of the HCS in a pamphlet 
entitled Chemical Hazard Communication (OSHA 3084). Some 
employers prefer to familiarize themselves with the rule’s require¬ 
ments hy reading this pamphlet. A single, free copy may he obtained 
from your local OSHA Area Office, or hy contacting the OSHA 
Publications Office at (202) 693-1888. 

The standard itself is long and some parts are technical, but the 
basic concepts are simple. In fact, the requirements reflect what 
many employers have been doing for years. You may find that you 
already largely comply with many of the provisions and will simply 
have to modify your existing programs somewhat. If you are operat¬ 
ing in an OSHA-approved State Plan State, you must comply with 
the State’s requirements, which may be different than those of the 
Federal rule. Many of the State Plan States had hazard communica¬ 
tion or “right-to-know” laws prior to promulgation of the federal 
rule. Employers in State Plan States should contact their State 
OSHA Offices for more information regarding applicable require¬ 
ments. (See the list of contacts in “States with Approved Plans” at 
the back of this booklet.) 

The HCS requires information to be prepared and transmitted 
regarding all hazardous chemicals. The HCS covers both physical 
hazards (such as flammability) and health hazards (such as irritation, 
lung damage, and cancer.) Most chemicals used in the workplace 
have some hazard potential, and thus will be covered by the rule. 

One difference between this rule and many others adopted by 
OSHA is that this one is performance-oriented. That means you 
have the flexibility to adapt the rule to the needs of your workplace, 
rather than having to follow specific rigid requirements. It also 
means that you have to exercise more judgment to implement an 
appropriate and effective program. 

The standard’s design is simple. Chemical manufacturers and 
importers must evaluate the hazards of the chemicals they produce or 
import. Using that information, they must then prepare labels for 
containers and more detailed technical bulletins called material 
safety data sheets (MSDSs). 

Chemical manufacturers, importers, and distributors of hazardous 
chemicals are all required to provide the appropriate labels and 
material safety data sheets to the employers to whom they ship the 


Hazard Communication Guideiines for Compiiance 








3 


chemicals. The information must he provided automatically. Every 
container of hazardous chemicals you receive must he labeled, 
tagged, or marked with the required information. Your suppliers also 
must send you a properly completed MSDS at the time of the first 
shipment of the chemicals, and with the next shipment after the 
MSDS is updated with new and significant information about the 
hazards. 

You can rely on the information received from your suppliers. 

You have no independent duty to analyze the chemical or evaluate 
the hazards of it. 

Employers that “use” hazardous chemicals must have a program 
to ensure the information is provided to exposed employees. “Use” 
means to package, handle, react, or transfer. This is an intentionally 
broad scope, and includes any situation where a chemical is present 
in such a way that employees may be exposed under normal condi¬ 
tions of use or in a foreseeable emergency. 

The requirements of the rule that deal specifically with the hazard 
communication program are found in the standard in paragraphs (e), 
written hazard communication programs; (f), labels and other forms 
of warning; (g), material safety data sheets; and (h), employee 
information and training. The requirements of these paragraphs 
should be the focus of your attention. Concentrate on becoming 
familiar with them, using paragraphs (b), scope and application, and 
(c), definitions, as references when needed to help explain the 
provisions. 

There are two types of work operations where coverage of the rule 
is limited. These are laboratories and operations where chemicals 
are only handled in sealed containers (e.g., a warehouse). The 
limited provisions for these workplaces can be found in paragraph 
(b), scope and application. Basically, employers having these types 
of work operations need only keep labels on containers as they are 
received, maintain material safety data sheets that are received and 
give employees access to them, and provide information and training 
for employees. Employers do not have to have written hazard 
communication programs and lists of chemicals for these types of 
operations. 

The limited coverage of laboratories and sealed container opera¬ 
tions addresses the obligation of an employer to the workers in the 


Becoming Familiar with the Rule 







operations involved, and does not affect the employer’s duties as a 
distributor of chemicals. For example, a distributor may have 
warehouse operations where employees would be protected under the 
limited sealed container provisions. In this situation, requirements 
for obtaining and maintaining MSDSs are limited to providing access 
to those received with containers while the substance is in the 
workplace, and requesting MSDSs when employees request access 
for those not received with the containers. However, as a distributor 
of hazardous chemicals, that employer will still have responsibility 
for providing MSDSs to downstream customers at the time of the 
first shipment and when the MSDS is updated. Therefore, although 
they may not be required for the employees in the work operation, 
the distributor may, nevertheless, have to have MSDSs to satisfy 
other requirements of the rule. 


Hazard Communication Guideiines for Compiiance 





Identifying Responsible Staff 


5 


Hazard communication will be a continuing program in your 
facility. Compliance with HCS is not a “one shot deal.” In order to 
have a successful program, you must assign responsibility for both 
the initial and ongoing activities that have to be undertaken to 
comply with the rule. In some cases, these activities may be part of 
current job assignments. For example. Site Supervisors are fre¬ 
quently responsible for on-the-job training sessions. Early identifica¬ 
tion of the responsible employees and their involvement in develop¬ 
ing your action plan will result in a more effective program design. 
Involving affected employees also will enhance the evaluation of the 
effectiveness of your program. 

For any safety and health program, success depends on commit¬ 
ment at every level of the organization. This is particularly true for 
hazard communication, where success requires a change in behavior. 
This will occur only if employers understand the program and are 
committed to its success, and if the people presenting the information 
motivate employees. 


Identifying Responsibie Staff 







Identifying Hazardous Chemicals in the Workplace 


The standard requires a list of hazardous chemicals in the work¬ 
place as part of the written hazard communication program. The list 
will eventually serve as an inventory of everything for which you 
must maintain an MSDS. At this point, however, preparing the list 
will help you complete the rest of the program since it will give you 
some idea of the scope of the program required for compliance in 
your facility. 

The best way to prepare a comprehensive list is to survey the 
workplace. Purchasing records also may help, and certainly employ¬ 
ers should establish procedures to ensure that in the future purchas¬ 
ing procedures result in MSDSs being received before using a 
material in the workplace. 

The broadest possible perspective should be taken when doing the 
survey. Sometimes people think of “chemicals” as being only liquids 
in containers. The HCS covers chemicals in all physical forms— 
liquids, solids, gases, vapors, fumes, and mists—whether they are 
“contained” or not. The hazardous nature of the chemical and the 
potential for exposure are the factors that determine whether a 
chemical is covered. If it’s not hazardous, it’s not covered. If there 
is no potential for exposure, (e.g., the chemical is inextricably bound 
and cannot be released), the rule does not cover the chemical. 

Look around. Identify the chemicals in containers, including 
pipes, but also think about chemicals generated in the work opera¬ 
tions. For example, welding fumes, dusts, and exhaust fumes are all 
sources of chemical exposures. Read labels provided by the suppli¬ 
ers on hazard information. Make a list of all chemicals in the 
workplace that are potentially hazardous. For your own information 
and planning, you also may want to note on the list the location(s) of 
the products within the workplace, and an indication of the hazards 
as found on the label. This will help you as you prepare the rest of 
your program. 

Paragraph (b), scope and application, includes exemptions for 
various chemicals or workplace situations. After compiling the 
complete list of chemicals, you should review paragraph (b) to 
determine if any of the items can be eliminated from the list because 
they are exempted materials. For example, food, drugs, and cosmet¬ 
ics brought into the workplace for employee consumption are 
exempt; rubbing alcohol in the first aid kit would not be covered. 


Hazard Communication Guideiines for Compiiance 





Once you have compiled as complete a list as possible of the 
potentially hazardous chemicals in the workplace, the next step is to 
determine if you have received material safety data sheets for all of 
them. Check your files against the inventory you have just compiled. 
If any are missing, contact your supplier and request one. It is a 
good idea to document these requests, either by copy of a letter or a 
note regarding telephone conversations. If you have MSDSs for 
chemicals that are not on your list, figure out why. Maybe you don’t 
use the chemical anymore. Or maybe you missed it in your survey. 
Some suppliers do provide MSDSs for products that are not hazard¬ 
ous. These do not have to be maintained by you. If you have 
questions regarding the hazard status of a chemical, contact the 
manufacturer, distributor, or importer. 

You should not allow employees to use any chemicals for which 
you have not received an MSDS. The MSDS provides information 
you need to ensure you have implemented proper protective mea¬ 
sures for exposure. 


Identifying Hazardous Chemicais in the Workpiace 





8 


Preparing and Implementing a Hazard Communication Program 


The HCS requires all workplaces where employees are exposed to 
hazardous chemicals to have a written plan that descrihes how that 
facility will implement the standard. Preparation of the plan is not 
just a paper exercise—all of the elements must he implemented in 
the workplace to comply with the rule. See paragraph (e) of the 
standard for the specific requirements regarding written hazard 
communication programs. The only work operations that do not 
have to comply with the written plan requirements are laboratories 
and work operations where employees only handle chemicals in 
sealed containers. See paragraph (h), scope and application, for the 
specific requirements for these two types of workplaces. 

The plan does not have to he lengthy or complicated. It is in¬ 
tended to he a blueprint for implementing your program—an assur¬ 
ance that all aspects of the requirements have been addressed. 

Many trade associations and other professional groups have 
provided sample programs and other assistance materials to affect 
employers. These have been very helpful to many employers since 
they tend to be tailored to the particular industry involved. You may 
wish to investigate whether your industry trade groups have devel¬ 
oped such materials. 

Although such general guidance may be helpful, you must remem¬ 
ber that the written program has to reflect what you are doing in your 
workplace. Therefore, if you use a generic program, you must adapt 
it to address the facility it covers. 

For example, the written plan must list the chemicals present at 
the site and indicate where written materials will be made available 
to employees. It also may indicate who is responsible for the various 
aspects of the program in your facility. 

If OSHA inspects your workplace for compliance with the HCS, 
the OSHA compliance officer will ask to see your written plan at the 
outset of the inspection. In general, the following items will be 
considered in evaluating your program. 

The written program must describe how the requirements for labels 
and other forms of warning, materials safety data sheets, and em¬ 
ployee information and training, are going to be met in your facility. 
The following discussion provides the type of information compli¬ 
ance officers will be looking for to decide whether you have properly 
addressed these elements of the hazard communication program. 


Hazard Communication Guideiines for Compiiance 






Labels and Other Forms of Warning 

In-plant containers of hazardous chemicals must he labeled, 
tagged, or marked with the identity of the material and appropriate 
hazard warnings. Chemical manufacturers, importers, and distribu¬ 
tors must ensure that every container of hazardous chemicals they 
ship is appropriately labeled with such information and with the 
name and address of the producer or other responsible party. Em¬ 
ployers purchasing chemicals can rely on the labels provided by their 
suppliers. If the material is subsequently transferred by the employer 
from a labeled container to another container, the employer will have 
to label that container, unless it is subject to the portable container 
exemption. See paragraph (f) for specific labeling requirements. 

The primary information to be obtained from an OSHA-required 
label is the identity for the material and appropriate hazard warnings. 
The identity is any term which appears on the label, the MSDS, and 
the list of chemicals, and thus links these three sources of informa¬ 
tion. The identity used by the supplier may be a common or trade 
name (“Black Magic Formula”), or a chemical name (1, 1, 1 - 
trichloroethane). The hazard warning is a brief statement of the 
hazardous effects of the chemical (“flammable,” “causes lung 
damage”). Labels frequently contain other information, such as 
precautionary measures (“do not use near open flame”) but this 
information is provided voluntarily and is not required by the rule. 
Labels must be legible and prominently displayed. There are no 
specific requirements for size or color or any specified test. 

With these requirements in mind, the compliance officer will be 
looking for the following types of information to ensure that labeling 
is properly implemented in your facility: 

• Designation of person(s) responsible for ensuring labeling of 
in-plant containers; 

• Designation of person(s) responsible for ensuring labeling of 
any shipped container; 

• Description of labeling system(s) used; 

• Description of written alternatives to labeling of in-plant 
containers (if used); and, 

• Procedures to review and update label information when 
necessary. 


Preparing and Implementing a Hazard Communication Program 





10 


Employers that are purchasing and using hazardous chemicals— 
rather than producing or distributing them—will primarily he con¬ 
cerned with ensuring that every purchased container is labeled. If 
materials are transferred into other containers, the employer must 
ensure that these are labeled as well, unless they fall under the 
portable container exemption (paragraph f(7)). In terms of labeling 
systems, you can choose to use the labels provided by your suppliers 
on the containers. These will generally be verbal text labels, and do 
not usually include numerical rating systems or symbols that require 
special training. The most important thing to remember is that this is 
a continuing duty—all in-plant containers of hazardous chemicals 
must always be labeled. Therefore, it is important to designate 
someone to be responsible for ensuring that the labels are maintained 
as required on the containers in your facility and that newly pur¬ 
chased materials are checked for labels prior to use. 

Material Safety Data Sheets 

Chemical manufacturers and importers are required to obtain or 
develop a material safety data sheet for each hazardous chemical they 
produce or import. Distributors are responsible for ensuring that 
their customers are provided a copy of these MSDSs. Employers 
must have an MSDS for each hazardous chemical which they use. 
Employers may rely on the information received from their suppliers. 
The specific requirements for material safety data sheets are in 
paragraph (g) of the standard. 

There is no specific format for the MSDS under the rule, although 
there are specific information requirements. OSHA has developed a 
nonmandatory format, OSHA Eorm 174, which may be used by 
chemical manufacturers and importers to comply with the rule. The 
MSDS must be in English. You are entitled to receive from your 
supplier a data sheet which includes all of the information required 
under the rule. If you do not receive one automatically, you should 
request one. If you receive one that is obviously inadequate, with, 
for example, blank spaces that are not completed, you should request 
an appropriately completed one. If your request for a data sheet or 
for a corrected data sheet does not produce the information needed, 
you should contact your local OSHA Area Office for assistance in 
obtaining the MSDS. 


Hazard Communication Guideiines for Compiiance 






11 


Under the rule, the role of MSDSs is to provide detailed informa¬ 
tion on each hazardous chemical, including its potential hazardous 
effects, its physical and chemical characteristics, and recommenda¬ 
tions for appropriate protective measures. This information should 
he useful to you as the employer responsible for designing protective 
programs, as well as to the workers. If you are not familiar with 
material safety data sheets and with chemical terminology, you may 
need to learn to use them yourself. A glossary of MSDS terms may 
he helpful in this regard. Generally speaking, most employers using 
hazardous chemicals will primarily he concerned with MSDS 
information regarding hazardous effects and recommended protective 
measures. Focus on the sections of the MSDS that are applicable to 
your situation. 

MSDSs must be readily accessible to employees when they are in 
their work areas during their workshifts. This may be accomplished 
in many different ways. You must decide what is appropriate for 
your particular workplace. Some employers keep the MSDSs in a 
binder in a central location (e.g., in the pickup truck on a construc¬ 
tion site.) Others, particularly in workplaces with large numbers of 
chemicals, computerize the information and provide access through 
terminals. As long as employees can get the information when they 
need it, any approach may be used. The employees must have access 
to the MSDSs themselves—simply having a system where the 
information can be read to them over the phone is permitted only 
under the mobile worksite provision, paragraph (g)(9), when employ¬ 
ees must travel between workplaces during the shift. In this situa¬ 
tion, they have access to the MSDSs prior to leaving the primary 
worksite, and when they return, so the telephone system is simply an 
emergency arrangement. 

In order to ensure that you have a current MSDS for each chemi¬ 
cal in the plant as required, and that you provide employee access, 
the compliance officers will be looking for the following types of 
information in your written program: 

• Designation of person(s) responsible for obtaining and main¬ 
taining the MSDSs; 

• How such sheets are to be maintained in the workplace (e.g., in 
notebooks in the work area(s) or in a computer with terminal 
access), and how employees can obtain access to them when 
they are in their work area during the workshift; 


Preparing and Implementing a Hazard Communication Program 






12 


• Procedures to follow when the MSDS is not received at the 
time of the first shipment; 

• For producers, procedures to update the MSDS when new and 
significant health information is found; and, 

• Description of alternatives to actual data sheets in the work¬ 
place, if used. 

For employers using hazardous chemicals, the most important 
aspect of the written program in terms of MSDSs is to ensure that 
someone is responsible for obtaining and maintaining the MSDSs for 
every hazardous chemical in the workplace. The list of hazardous 
chemicals required to be maintained as part of the written program 
will serve as an inventory. As new chemicals are purchased, the list 
should be updated. Many companies have found it convenient to 
include on their purchase order the name and address of the person 
designated in their company to receive MSDSs. 

Employee Information and Training 

Each employee who may be “exposed” to hazardous chemicals 
when working must be provided information and be trained prior to 
initial assignment to work with a hazardous chemical, and whenever 
the hazard changes. “Exposure” or “exposed” under the rule means 
that an employee is subjected to a hazardous chemical in the course 
of employment through any route of entry (inhalation, ingestion, skin 
contact, or absorption) and includes potential (e.g., accidental or 
possible) exposure. See paragraph (h) of the standard for specific 
requirements. Information and training may be done either by 
individual chemical, or by categories of hazards (such as flammabil¬ 
ity or carcinogenicity). If there are only a few chemicals in the 
workplace, then you may want to discuss each one individually. 
Where there are a large number of chemicals, or the chemicals 
change frequently, you will probably want to train generally based on 
the hazard categories (e.g., flammable liquids, corrosive materials, 
carcinogens). Employees will have access to the substance-specific 
information on the labels and MSDSs. Employers must ensure, 
however, that employees are made aware of which hazard category a 
chemical falls within. 

Information and training are a critical part of the hazard communi¬ 
cation program. Workers obtain information regarding hazards and 


Hazard Communication Guideiines for Compiiance 






13 


protective measures through written labels and material safety data 
sheets. It is through effective information and training, however, that 
workers will learn to read and understand such information, deter¬ 
mine how to acquire and use it in their own workplace, and under¬ 
stand the risks of exposure to the chemical in their workplaces as 
well as the ways to protect themselves. A properly conducted 
training program will ensure comprehension and understanding. It is 
not sufficient to either just read material to the workers or simply 
hand them material to read. You want to create a climate where 
workers feel free to ask questions. This will help you to ensure that 
the information is understood. You must always rememher that the 
underlying purpose of the HCS is to reduce the incidence of chemi¬ 
cal source illnesses and injuries. This will he accomplished hy 
modifying behavior through the provision of hazard information and 
information about protective measures. If your program works, you 
and your workers will better understand the chemical hazards within 
the workplace. The procedures you establish, regarding, for ex¬ 
ample, purchasing, storage, and handling of these chemicals will 
improve, and thereby reduce the risks posed to employees exposed to 
the chemical hazards involved. Furthermore, your workers’ compre¬ 
hension also will be increased, and proper work practices will be 
followed in your workplace. 

If you are going to do the training yourself, you will have to 
understand the material and be prepared to motivate the workers to 
learn. This is not always an easy task, but the benefits are worth the 
effort. More information regarding appropriate training can be found 
in Training Requirements in OSHA Standards and Training Guide¬ 
lines (OSHA 2254), which contains voluntary training guidelines 
prepared by OSHA’s Training Institute. A copy of this document is 
available from the Superintendent of Documents, Government 
Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-7954; (202) 
512-1800. 

When reviewing your written program regarding information and 
training, consider the following items: 

• Designation of person(s) responsible for conducting training; 

• Format of the program used (audiovisuals, class room 
instruction); 

• Elements of the training programs (should be consistent with 
the elements in paragraph (h) of the FIGS); and. 


Preparing and Implementing a Hazard Communication Program 






14 


• Procedure to train new employees at the time of their initial 
assignment to work with a hazardous chemical, and to train 
employees when introducing a new hazard into the workplace. 

The written program should provide enough details about the 
employer’s plans in this area to assess whether or not a good faith 
effort is being made to train employees. OSHA does not expect that 
every workers will be able to recite all the information about each 
chemical in the workplace. In general, the most important aspects of 
training under the HCS are to ensure that employees are aware that 
they are exposed to hazardous chemicals, that they know how to read 
and use labels and material safety data sheets, and that, as a conse¬ 
quence of learning this information, they are following the appropri¬ 
ate protective measures established by the employer. OSHA compli¬ 
ance officers will be talking to employees to determine if they have 
received training, if they know they are exposed to hazardous chemi¬ 
cals, and if they know where to obtain substance specific information 
on labels and MSDSs. 

The rule does not require employers to maintain records of 
employee training, but many employers choose to do so. This may 
help you monitor your own program to ensure that you have trained 
all employees appropriately. If you already have a training program, 
you may simply have to supplement it with whatever additional 
information is required under the HCS. For example, construction 
employers that are already in compliance with the construction 
training standard (29 CFR 1926.21 ) will have little extra training to 
do. 

An employer can provide employees information and training 
through whatever means found appropriate and protective. Although 
there would always have to be some training on site (such as inform¬ 
ing employees of the location and availability of the written program 
and MSDSs), employee training may be satisfied in part by general 
training about the requirements of the HCS which is provided by, for 
example, trade associations, unions, colleges, and professional 
schools. In addition, previous training, education, and experience of 
a worker may relieve the employer of some of the burdens of infor¬ 
mation and training that worker. Regardless of the method relied 
upon, however, the employer is always ultimately responsible for 
ensuring that employees are adequately trained. If the compliance 


Hazard Communication Guideiines for Compiiance 






15 


officer finds that the training is deficient, the employer will he cited 
for the deficiency regardless of who actually provided the training on 
hehalf of the employer. 

In addition to these specific items, compliance officers also will he 
asking the following questions in assessing the adequacy of the 
program: 

• Does a list of the hazardous chemicals exist in each work area 
or at a central location? 

• Are methods the employer will use to inform employees of the 
hazards of non-routine tasks outlined? 

• Are employees informed of the hazards associated with chemi¬ 
cals contained in unlaheled pipes in their work areas? 

• On multi-employer worksites, has the employer provided other 
employers with information about labeling systems and precau¬ 
tionary measures where the other employers have employees 
exposed to the initial employer’s chemicals? 

• Is the written program made available to employees and their 
designated representatives? 

If your program adequately addresses the means of communicat¬ 
ing information to employees in your workplace and provides 
answers to the basic questions outlined above, it will comply with the 
rule. 


Preparing and Implementing a Hazard Communication Program 






The following checklist will help to ensure you comply with the 
rule: 

• Obtained a copy of the rule. 

• Read and understood the requirements. 

• Assigned responsibility for tasks. 

• Prepared an inventory of chemicals. 

• Ensured containers are labeled. 

• Obtained MSDS for each chemical. 

• Prepared written program. 

• Made MSDSs available to workers. 

• Conducted training of workers. 

• Established procedures to maintain current program. 

• Established procedures to evaluate effectiveness. 


Hazard Communication Guideiines for Compiiance 









Further Assistance 


17 


If you have a question regarding compliance with HCS, you 
should contact your local OSHA Area Office for assistance. In 
addition, each OSHA Regional Office has a Hazard Communication 
Coordinator who can answer your questions. Free consultation 
services also are available to assist employers, and information 
regarding these services can he obtained through the OSHA Area and 
Regional Offices as well (see lists at the end of this booklet). 


Further Assistance 








Safety and Health Program Management 

Effective management of worker safety and health protection is a 
decisive factor in reducing the extent and severity of work-related 
injuries and illnesses and their related costs. To assist employers and 
employees in developing effective safety and health programs, OSHA 
published recommended Safety and Health Program Management 
Guidelines (Federal Register 54(18):3908-3916, January 26, 1989). 
These voluntary guidelines apply to all places of employment covered 
hy OSHA. 

The guidelines identify four general elements that are critical to the 
development of a successful safety and health management program: 

• management commitment and employee involvement; 

• worksite analysis; 

• hazard prevention and control; and 

• safety and health training. 

The guidelines recommend specific actions under each of these 
general elements to achieve an effective safety and health program. A 
single, free copy of the guidelines can he obtained from the U.S. 
Department of Labor, OSHA Publications, P.O. Box 37535, Washing¬ 
ton, DC 20013-7535, by sending a self-addressed mailing label with 
your request. 


State Programs 

The Occupational Safety and Health Act of 1970 encourages states 
to develop and operate their own job safety and health plans. States 
with plans approved under section 18(b) of the OSH Act must adopt 
standards and enforce requirements that are at least as effective as 
federal requirements. There are currently 25 state plan states: 23 of 
these states administer plans covering both private and public (state 
and local public government) employees; the other two states, Con¬ 
necticut and New York, cover public employees only. Plan states 
must adopt standards comparable to federal requirements within six 
months of a federal standard’s promulgation. Until such time as a 
state standard is promulgated. Federal OSHA provides interim 
enforcement assistance, as appropriate, in these states. A listing of 
approved state plans appear at the end of this publication. 


Hazard Communication Guideiines for Compiiance 









19 


Consultation Services 

Consultation assistance is available on request to employers who 
want help in establishing and maintaining a safe and healthful 
workplace. Largely funded by OSHA, the service is provided at no 
cost to the employer. Primarily developed for smaller employers 
with more hazardous operations, the consultation service is delivered 
by state government agencies or universities employing professional 
safety consultants and health consultants. Comprehensive assistance 
includes an appraisal of ah work practices and environmental hazards 
of the workplace and ah aspects of the employer’s present job safety 
and health program. 

The program is separate from OSHA’s inspection efforts. No 
penalties are proposed or citations issued for any safety or health 
problems identified by the consultant. The service is confidential. 

For more information concerning consultation assistance, see the 
list of consultation projects at the end of this publication. 


Voluntary Protection Programs (VPP) 

Voluntary Protection Programs (VPP) and onsite consultation 
services, when coupled with an effective enforcement program, 
expand worker protection to help meet the goals of the OSFI Act. 

The three VPPs—Star, Merit, and Demonstration—are designed to 
recognize outstanding achievement by companies that have success¬ 
fully incorporated comprehensive safety and health programs into 
their total management system. They motivate others to achieve 
excellent safety and health results in the same outstanding way as 
they establish a cooperative relationship among employers, employ¬ 
ees, and OSFIA. 

For additional information on VPP and how to apply, contact your 
nearest OSHA area or regional office listed at the end of this 
publication. 

Training and Education 

OSHA Area Offices offer a variety of information services, such 
as publications, audiovisual aids, technical advice, and speakers for 
special engagements. The OSHA Training Institute in Des Plaines, 


Other Sources of OSHA Assistance 







20 


IL, provides basic and advanced courses in safety and health for 
federal and state compliance officers, state consultants, federal 
agency personnel, and private sector employers, employees, and their 
representatives. 

OSHA also provides funds to nonprofit organizations, through 
grants to conduct workplace training and education in subjects where 
OSHA believes there is a lack of workplace training. Grants are 
awarded annually and grant recipients arc expected to contribute 20 
percent of the total grant cost. 

For more information on grants, training, and education, contact 
the OSHA Training Institute, Office of Training and Education, 1555 
Times Drive, Des Plaines, IL 60018, (847) 297-4810; (847) 
297-4874 fax. 


Electronic Information 

Intemet-OSHA standards, interpretations, directives, and addi¬ 
tional information are now on the World Wide Web at 
http://www.osha.gov/ and http://www.osha-slc.gov/. 

CD-ROM—A wide variety of OSHA materials, including stan¬ 
dards, interpretations, directives, and more can be purchased on 
CD-ROM from the U.S. Government Printing Office. To order, 
write to the Superintendent of Documents, PO. Box 371954, 
Pittsburgh, PA 15250-7954, or phone (202) 512-1800. Specify 
OSHA Regulations, Documents, and Technical Information on 
CD-ROM (ORDT), GPO Order NO. S/N 729-013-00000-5. The 
price is $48 per year ($57.50 foreign); $17 per single copy ($21.25 
foreign). 


Emergencies 

For life-threatening situations, call (800) 32 1 -OSHA. Com¬ 
plaints will go immediately to the nearest OSHA area or state office 
for help. 

For further information on any OSHA program, contact your 
nearest OSHA area or regional office listed at the end of this 
publication. 


Hazard Communication Guideiines for Compiiance 








OSHA Related Publications 


21 


Single free copies of the following publications can be obtained 
from the OSHA Publications Office, P.O. Box 37535, Washington, 
DC 20013-7535. Send a self-addressed mailing label with your 
request. 

All About OSHA - OSHA 2056 

Chemical Hazard Communication - OSHA 3084 

Consultation Services for the Employer - OSHA 3074 

Employee Workplace Rights - OSHA 3021 

Employer Rights and Responsibilities Eollowing an OSHA 

Inspection - OSHA 3000 

How to Prepare for Workplace Emergencies - OSHA 3088 
OSHA Inspections - OSHA 2098 
Personal Protective Equipment - OSHA 3077 
Respiratory Protection - OSHA 3079 

The following publications may be ordered at cost, from the 
Superintendent of Documents, U.S. Government Printing Office, 
Washington DC 20402, (202) 512-1800. Include GPO Order No. 
and make checks payable to Superintendent of Documents. 

Code of Eederal Regulations - Title 29, Part 1926 
Construction (OSHA) ($30) 

Order No. S/N 869-038-00107-1 

OSHA Safety and Health Standards (29 CFR 1910.1000 to End) 
($28) Order No. S/N 869-038-00105-5. 

Handbook for Small Business - OSHA 2209 ($7.50) 

Order No. 029-016-00176-0. 


OSHA Related Publications 







Commissioner 

Alaska Department of Labor 
1111 West 8th Street 
Room 304 

Juneau, AK 99801-1149 
(907) 465-2700 

Director 

Industrial Commission of Arizona 
800 W. Washington 
Phoenix, AZ 85007-2922 
(602) 542-5795 

Director 

California Department 
of Industrial Relations 
455 Golden Gate Avenue - 
10th Floor 

San Francisco, CA 94102 
(415) 703-5050 

Commissioner 

Connecticut Department of Labor 
200 Folly Brook Boulevard 
Wethersfield, CT 06109 
(860) 566-5123 

Director 

Hawaii Department of Labor 
and Industrial Relations 
830 Punchbowl Street 
Honolulu, HI 96813 
(808)586-8844 


Commissioner 

Indiana Department of Labor 
State Office Building 
402 West Washington Street 
Room W195 

Indianapolis, IN 46204-2751 
(317) 232-2378 

Commissioner 

Iowa Division of Labor Services 
1000 E. Grand Avenue 
Des Moines, lA 50319-0209 
(515) 281-3447 

Secretary 

Kentucky Labor Cabinet 
1047 U.S. Highway, 127 South, 
Suite 4 

Frankfort, KY 40601 
(502) 564-3070 

Commissioner 

Maryland Division of Labor 
and Industry 

Department of Labor, Licensing, 
and Regulation 
1100 N. Eutaw Street, 

Room 613 

Baltimore, MD 21201-2206 
(410) 767-2215 


Hazard Communication Guideiines for Compiiance 








23 


Director 

Michigan Department 
of Consumer and Industry 
Services 
RO. Box 30643 
Lansing, MI 48909-8143 
(517) 322-I8I4 

Commissioner 

Minnesota Department of Labor 
and Industry 
443 Lafayette Road 
St. Paul, MN 55155-4307 
(651)296-2342 

Administrator 

Nevada Division of Industrial 
Relations 

400 West King Street 
Carson City, NV 89710 
(775) 687-3032 

Secretary 

New Mexico Environment 
Department 
1190 St. Francis Drive 
P.O. Box 26110 
Santa Fe, NM 87502 
(505) 827-2850 


Commissioner 

New York Department of Fabor 
W. Averell Harriman State Office 
Building - 12, Room 500 
Albany, NY 12240 
(518)457-2741 

Commissioner 

North Carolina Department 
of Fabor 

4 West Edenton Street 
Raleigh, NC 27601-1092 
(919) 807-7166 

Administrator 

Department of Consumer 
and Business Services 
Occupational Safety and Health 
Division (OR-OSHA) 

350 Winter Street, NE, 

Room 430 

Salem, OR 97310-0220 
(503)378-3272 

Secretary 

Puerto Rico Department 
of Fabor and Human Resources 
Prudencio Rivera Martinez 
Building 

505 Munoz Rivera Avenue 
Hato Rey, PR 00918 
(787) 754-2119 


States with Approved Plans 






24 


Director 

South Carolina Department 
of Labor, Licensing, and 
Regulation 
Roger Office Park, 

Kingstree Building 
110 Centerview Drive 
RO. Box 11329 
Columbia, SC 29210 
(803) 896-4300 

Commissioner 

Tennessee Department of Labor 
Attention: Robert Taylor 
710 James Robertson Parkway 
Nashville, TN 37243-0659 
(615)741-2582 

Commissioner 

Labor Commission of Utah 
160 East 300 South, 3rd Floor 
PO. Box 146650 
Salt Lake City, UT 84114-6650 

(801) 530-6898 

Commissioner 

Vermont Department 
of Labor and Industry 
National Life Building - 
Drawer 20 
National Life Drive 
Montpelier, VT 05620-3401 

(802) 828-5098 


Commissioner 

Virginia Department of Labor 
and Industry 
Powers-Taylor Building 
13 South 13th Street 
Richmond, VA 23219 
(804) 786-2377 

Commissioner 

Virgin Islands Department 
of Labor 

2203 Church Street 

Christiansted 

St. Croix, VI00820-4660 

(340) 773-1994 

Director 

Washington Department 
of Labor and Industries 
PO. Box 44001 
Olympia, WA 98504-4001 
(360) 902-4200 

Administrator 

Worker’s Safety and 
Compensation Division (WSC) 
Wyoming Department 
of Employment 
Herschler Building, 

2nd Floor East 
122 West 25th Street 
Cheyenne, WY 82002 
(307) 777-7786 


Hazard Communication Guideiines for Compiiance 






OSHA Consultation Project Directory 


25 


State 


Telephone 


Alabama. 

Alaska. 

Arizona. 

Arkansas. 

California. 

Colorado. 

Connecticut. 

Delaware. 

District of Columbia 

Florida. 

Georgia. 

Guam. 

Hawaii. 

Idaho. 

Illinois. 

Indiana. 

Iowa. 

Kansas. 

Kentucky. 

Louisiana. 

Maine. 

Maryland. 

Massachusetts. 

Michigan. 


Minnesota. 

Mississippi. 

Missouri. 

Montana. 

Nebraska. 

Nevada. 

New Hampshire 

New Jersey. 

New Mexico. 

New York. 

North Carolina 
North Dakota .... 

Ohio. 

Oklahoma. 


.(205) 348-3033 

.(907) 269-4957 

.(602) 542-1695 

.(501) 682-4522 

.(415) 703-5270 

.(970) 491-6151 

.(860) 566-4550 

.(302) 761-8219 

.(202) 576-6339 

.(850) 922-8955 

.(404) 894-2643 

011(671)475-0136 

.(808)586-9100 

.(208) 426-3283 

.(312) 814-2337 

.(317) 232-2688 

.(515) 281-7162 

.(785) 296-7476 

.(502) 564-6895 

.(504) 342-9601 

.(207) 624-6460 

.(410) 880-4970 

.(617) 727-3982 

.(517) 322-6823(H) 

.(517) 322-1809(S) 

.(612) 297-2393 

.(601)987-3981 

.(573) 751-3403 

.(406)444-6418 

.(402) 471-4717 

.(702) 486-9140 

.(603)271-2024 

.(609) 292-3923 

.(505) 827-4230 

.(518) 457-2238 

.(919) 807-2905 

.(701) 328-5188 

.(614) 644-2246 

.(405) 528-1500 


OSHA Consultation Project Directory 















































26 


Oregon. 

Pennsylvania... 

Puerto Rico. 

Rhode Island... 
South Carolina 
South Dakota .. 

Tennessee . 

Texas . 

Utah. 

Vermont. 

Virginia . 

Virgin Islands.. 

Washington. 

West Virginia .. 
Wisconsin. 


Wyoming 


(503) 378-3272 
(724) 357-2396 
(787) 754-2171 
(401) 222-2438 

(803) 734-9614 
(605) 688-4101 
(615) 741-7036 
(512) 804-4640 

(801) 530-6901 

(802) 828-2765 

(804) 786-6359 
(340)772-1315 
(360) 902-5638 
(304) 558-7890 
(608) 266-8579(H) 
(262) 523-3040(S) 
(307) 777-7786 


(H) - Health 
(S) - Safety 


Hazard Communication Guideiines for Compiiance 























OSHA Area Offices 


I 


Area 


Telephone 


Albany, NY. 

Albuquerque, NM. 

Allentown, PA. 

Anchorage, AK. 

Appleton, WI. 

Austin, TX. 

Avenel, NJ . 

Bangor, ME. 

Baton Rouge, LA. 

Bayside, NY. 

Bellevue, WA. 

Billings, MT. 

Birmingham, AL. 

Bismarck, ND. 

Boise, ID. 

Bowmansville, NY. 

Braintree, MA. 

Bridgeport, CT. 

Calumet City, IL. 

Carson City, NV. 

Charleston, WV. 

Cincinnati, OH. 

Cleveland, OH. 

Columbia, SC . 

Columbus, OH. 

Concord, NH. 

Corpus Christi, TX. 

Dallas, TX. 

Denver, CO. 

Des Plaines, IL. 

Des Moines, lA. 

Eau Claire, WI. 

El Paso, TX. 

Englewood, CO . 

Erie, PA. 

Eairview Heights, IL.... 

Eort Lauderdale, EL. 

Eort Worth, TX . 

Erankfort, KY. 

Guaynabo, PR. 

Harrisburg, PA. 

Hartford, CT. 

Hasbrouck Heights, NJ 

Honolulu, HI. 

Houston, TX. 


(518) 464-4338 
(505) 248-5302 
(610) 776-0592 

(907) 271-5152 
(920) 734-4521 

(512) 916-5783 

(908) 750-3270 

(207) 941-8179 
(225) 389-0474 
(718) 279-9060 
(206) 553-7520 
(406) 247-7494 
(205) 73I-I534 

(701) 250-4521 

(208) 321-2960 

(716) 684-3891 

(617) 565-6924 
(203) 579-5516 
(708) 891-3800 

(702) 885-6963 
(304) 347-5937 

(513) 84I-4I32 
(216) 522-3818 
(803) 765-5904 
(614) 469-5582 
(603) 225-1629 
(512) 888-3420 
(214) 320-2400 
(303) 844-5285 
(847) 803-4800 
(515) 284-4794 
(715) 832-9019 
(915)534-6251 
(303) 843-4500 
(814) 833-5758 

(618) 632-8612 
(954) 424-0242 
(817) 428-2470 
(502) 227-7024 
(787) 277-1560 

(717) 782-3902 
(860) 240-3152 
(201)288-1700 
(808) 541-2685 
(281)286-0583 


OSHA Area Offices 





















































28 


Houston, TX. 

Indianapolis, IN. 

Jackson, MS. 

Jacksonville, FL. 

Kansas City, MO .... 

Linthicum, MD. 

Little Rock, AR. 

Lubbock, TX. 

Madison, WI. 

Marlton, NJ. 

Methuen, MA. 

Milwaukee, WI. 

Minneapolis, MN.... 

Mobile, AL. 

Nashville, TN. 

New York, NY. 

Norfolk, VA. 

North Aurora, IL. 

Oklahoma City, OK 

Omaha, NE. 

Parsippany, NJ. 

Peoria, IL. 

Philadelphia, PA. 

Phoenix, AZ. 

Pittsburgh, PA. 

Portland, ME. 

Portland, OR. 

Providence, RI. 

Raleigh, NC. 

Sacramento, CA. 

Salt Lake City, UT .. 

San Diego, CA. 

Savannah, GA. 

Smyrna, GA. 

Springfield, MA. 

St. Louis, MO. 

Syracuse, NY. 

Tampa, PL. 

Tarrytown, NY. 

Toledo, OH. 

Tucker, GA. 

Westbury, NY. 

Wichita, KS . 

Wilkes-Barre, PA.... 
Wilmington, DE. 


(281)591-2438 
(317) 226-7290 

(601) 965-4606 
(904) 232-2895 
(816) 483-9531 
(410) 865-2055 
(501) 324-6291 
(806) 472-7681 

(608) 441-5388 

(609) 757-5181 
(617) 565-8110 
(414) 297-3315 
(612) 664-5460 
(334)441-6131 
(615) 781-5423 
(212) 466-2482 
(757) 441-3820 
(630) 896-8700 
(405) 231-5351 
(402) 221-3182 
(201) 263-1003 
(309) 671-7033 
(215) 597-4955 

(602) 640-2007 

(412) 395-4903 
(207) 780-3178 
(503) 326-2251 
(401) 528-4663 
(919) 856-4770 
(916) 566-7470 
(801) 487-0680 
(619) 557-2909 
(912) 652-4393 
(770) 984-8700 

(413) 785-0123 

(314) 425-4249 

(315) 451-0808 
(813)626-1177 
(914) 524-7510 
(419) 259-7542 
(770) 493-6644 
(516)334-3344 

(316) 269-6644 
(717) 826-6538 
(302) 573-6115 


Hazard Communication Guideiines for Compiiance 



















































OSHA Regional Offices 


Region I 

(CT,* MA, ME, NH, RI, VT*) 
JFK Federal Building 
Room E-340 
Boston, MA 02203 
Telephone: (617) 565-9860 

Region II 

(NJ, NY,* PR,* VI*) 

201 Varick Street 
Room 670 

New York, NY 10014 
Telephone: (212) 337-2378 

Region III 

(DC, DE, MD,* PA, VA,* WV) 
The Curtis Center - Suite 740 West 
170 S. Independence Mall West 
Philadelphia, PA 19106-3309 
Telephone: (215) 861-4900 

Region IV 

(AL, EL, GA, KY,* MS, NC,* 
SC,* TN*) 

Atlanta Federal Center 
61 Forsyth Street, SW, Room 6T50 
Atlanta, GA 30303 
Telephone: (404) 562-2300 

Region V 

(IL, IN,* MI,* MN,* OH, WI) 
230 South Dearborn Street 
Room 3244 
Chicago, IL 60604 
Telephone: (312) 353-2220 


Region VI 

(AR, LA, MN,* OK, TX) 

525 Griffin Street 
Room 602 
Dallas, TX 75202 
Telephone: (214) 767-4731 

Region VII 
(lA,* KS, MO, NE) 

City Center Square 
1100 Main Street, Suite 800 
Kansas City, MO 64105 
Telephone: (816) 426-5861 

Region VIII 

(CO, MT, ND, SD, UT,* WY*) 
1999 Broadway 
Suite 1690 

Denver, CO 80802-5716 
Telephone: (303) 844-1600 

Region IX 

(American Samoa, AZ,* CA,* 
Guam, HI,* NV,* Trust 
Territories of the Pacific) 

71 Stevenson Street 
4th Floor 

San Francisco, CA 94105 
Telephone: (415) 975-4310 

Region X 

(AK,* ID, OR,* WA*) 

1111 Third Avenue 
Suite 715 

Seattle, WA 98101-3212 
Telephone: (206) 553-5930 


*These states and territories operate their own OSHA-approved job safety 
and health programs (Connecticut and New York plans cover public employees 
only). States with approved programs must have a standard that is identical to, 
or at least as effective as, the federal standard. 


OSHA Regional Offices