1 OSHA Hazard Communication Standard Occupational Safety and Health Standards for the General Industry OTI 501 LABEL MSDS HCP.

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OSHA Hazard

CommunicationStandard

Occupational Safety and Health Standards

for theGeneral Industry

OTI 501LABEL

MSDS

HCP

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General IndustryHazard Communication

_____________________________________29 CFR 1910.1200

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Violations Cited - FY 2000

(e)(1)(h)

(h)(1)

(g)(1)

(f)(5)(i)

– Written HCP

– Employee Training

– Employee Training

– Material Safety Data Sheets

– Labeling

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CPL 2-2.38D

March 30, 1998

Inspection Procedures for the Hazard Communication Standard

CPL 2-2.38D3/30/98

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CONTENTS

(a) Purpose (b) Scope and application (c) Definitions (d) Hazard determination (e) Written program (f) Labeling (g) Material safety data sheets (MSDSs)

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CONTENTS

(h) Training (i) Trade secretsAppendix A - Health Hazard DefinitionsAppendix B - Hazard DeterminationAppendix C - Information SourcesAppendix D -“Trade Secret”Appendix E - Guidelines for Employers

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(a) Purpose

To insure that the hazards of all chemical produced in or imported into the U.S. are evaluated

Hazards transmitted toemployers employees

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(b) Scope and Application

Applies to any chemical which is known to be present in the workplace

– employee may be exposed

– actual or potential exposure

– consumer products

– laboratory coverage

– sealed containers

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Who’s Covered

Chemical manufactures Importers and distributorsEmployers that use chemicals

use means to package, handle, react, or transfer.

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(c) Definitions

Chemical - any element, chemical compound, or mixture of elements and/or compounds

Hazardous chemical - any chemical which is a physical or health hazard

?

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Basic Program Elements

(d) Hazard Determination

(e) Written Program

(f) Labeling

(g) MSDSs

(h) Employee Training

HCP

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Required for– chemical manufacturers– importers

Procedures must be– written– available upon request (5 working days)– Appendix C - Information Sources

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Accuracy and adequacy of information on labels and MSDSs

Do not have to address each chemical listed individually

Must include– physical hazards– health hazards

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(e) Written Hazard Communication Program

Required for all employers and

multi-employer worksites – when potential for exposure exists

• for employees

• for employers

Review prior to implementation

HCP

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(f) Labeling

(g) Material safety data sheets (MSDSs)

(h) Training

List of hazardous chemicals

Non-routine tasks

Multi-employer worksites


HCP

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Labeling– designated person

• in-plant containers• shipped containers

– description of labeling system– written alternatives to labeling of in-plant

containers– Procedures to review

HCP

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MSDSs– designated person to obtain

MSDSs– maintenance of MSDSs

• notebooks, electronic, back-up system, access

– procedures to follow to obtain MSDSs– procedures for updating MSDS

• chemical manufacturers and importers

HCP

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Training

– designated person

– when to train

– who to train

– hazards introduced by other employers

HCP

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Other topics– list of hazardous chemicals – non-routine tasks– unlabeled pipes– multi-employer worksites

• MSDS access

– availability of written program

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(f) Labeling

Must include– identity of the hazardous chemical– hazard warning

• physical and/or health

– name and address of chemical manufacturer, importer, or responsible party

• if shipped

LABEL

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Labeling Exception:

– Portable Containers

• Portable containers which are intended on for immediate use by the employee who performs the transfer of hazardous chemical from a labeled container are EXEMPT from labeling requirements.

(f) LabelingLABEL

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(f) Labeling

Minimally labels must include

– identity of the hazardous chemical

– hazard warning

– name and address of chemical manufacturer, importer, or responsible party

LABEL

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(f) Labeling

Stationary containers

– identity of the hazardous chemical

– hazard warning

• physical and/or health

LABEL

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(f) Labeling

LegibleProminently displayedEnglish

– additional languages

Cross referenced with – MSDS– hazardous chemical

inventory list

LABEL

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(f) Labeling

Alternate labelingEffectiveness

– Appendix A (effective labeling)– hazardous effects

• target organs

Evaluate in-plant labeling systems– training– MSDS procedures

LABEL

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(g) Material Safety Data Sheets

Chemical manufacturers and importers

– develop or obtain MSDSs

– Review a representative number

• Appendixes C and D

MSDS

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(g) Material Safety Data Sheets

MSDSs or each hazardous chemicalAre each of the 12 elements addressed?Are all sections completed?Missing MSDSs/labelsMulti-employer worksitesReferral procedures

MSDS

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Material Safety Data Sheets

Applicable ANSI Documents (212) 642-4900

Material Safety Data Sheets (1993)• ANSI/SAE AMS 2825A• $ 24.00 + S&H

Preparation of MSDSs (1993)• Z 400.1• $ 75.00 + S&H

MSDS

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(h) Training

Required for all employees

– exposed to hazardous chemicals

– potential for exposure to hazardous chemicals

Substance specific training requirements take precedence

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(h) Training

Review training program with management

Provided – for new employees– upon initial assignment

FrequencyTraining recordsContract training

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Things all employees should know about their HCP

Labeling requirements

Type of labeling system

Location(s) or operation(s) utilizing hazardous chemicals

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Physical and health hazards of chemicals

Methods/observations used to detect presence or release


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What’s in the drum or bag?

What is the safest way to handle the material?

What if it spills, leaks, or ignites?


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Protective measures

Location of the written HCP

Name of designated hazard communication coordinator

Location of MSDSs and how to obtain a copy


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(i) Trade Secrets

Emergencies

Non-emergencies

– written request

– exposure levels

MSDS

CONFIDENTIAL

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Exempt

Hazardous waste

Consumer products

Articles

– tables, upholstery,tires, adhesive tape, etc.

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Exempt

Wood and wood products

– not wood dust

– not with chemical additives

PNOR

– particulates not otherwise regulated

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Checklist for Compliance

Obtain a copy of the rule.

Read and understood the requirements.

Assigned responsibility for tasks.

Prepared an inventory of chemicals.

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Ensured containers are labeled.

Obtained MSDS for each chemical.

Prepared written program.

Made MSDSs available to workers.

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Conduct training of workers.

Established procedures to maintain

current program.

Established procedures to evaluate

effectiveness.

1 OSHA Hazard Communication Standard Occupational Safety and Health Standards for the General Industry OTI 501 LABEL MSDS HCP.

Documents

employers slide

employers hcp slide

importers hcp slide

implementation hcp slide

label msds hcp slide

msdss procedures

c definitions chemical

chemical compound