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include, but not be limited to, the following:
◆ Developing and maintaining a written hazard communication
program for the workplace, including lists of hazardous
chemicals present at the workplace.
◆ Labeling of containers of chemicals in the workplace, as well as
containers of chemicals being shipped to other workplaces.
◆ Preparation and distribution of MSDS to employees and
downstream employers.
◆ Development and implementation of employee training programs
regarding hazards of chemicals and protective measures.
Employers who do not produce or import chemicals need only focus on
those parts of 29CFR 1910.1200 that deal with establishing a
workplace program and communicating information to their workers.
Emergency Aid and Safety Hazard Communication and Material Safety Data Sheets
OSHA Requirements
7-4-2 Treatment Manual 10/2002-04
PPQ
Appendix E of 29CFR 1910.1200 is a general guide for such employers
to help them determine the compliance obligations under this rule,
and includes the following topics:
◆ Becoming Familiar With the Rule
◆ Identify Responsible Staff
◆ Identify Hazardous Chemicals in the Workplace
◆ Preparing and Implementing a Hazard Communication Program
❖ Labels and Other Forms of Warning
❖ Material Safety Data Sheets (MSDS’s)
❖ Employee Information and Training
❖ Other Requirements
◆ Checklist for Compliance
◆ Further Assistance
A copy of Appendix E is included in Figure 7-4-1—Guidelines for
Employer Compliance.
The 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. The HCS is designed to provide employees
with the information they need.
Knowledge acquired under the HCS will help employers provide safer workplaces for their employees. When employers
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 hazards 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
producers and importers of the materials. Producers and importers of chemicals are then required to provide the hazard
information to employers that purchase their products.
Employers that don’t produce or import chemicals need only focus on those parts of the rule that deal with establishing
a workplace program and communicating information to their workers. This appendix is a general guide for such
employers to help them determine what’s required under the rule. 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.
1. Becoming Familiar With the Rule
OSHA has provided a simple summary of the HCS in a pamphlet entitled “Chemical Hazard Communication.” OSHA
Publication Number 3084. Some employers prefer to begin to become familiar with the rule’s requirements by reading
this pamphlet. A copy may be obtained from your local OSHA Area Office, or by contacting the OSHA Publications Office
at (202) 523-9667.
FIGURE 7-4-1: Appendix E—Guidelines for Employer Compliance
Emergency Aid and Safety Hazard Communication and Material Safety Data Sheets
OSHA Requirements
10/2002-04 Treatment Manual 7-4-3
PPQ
The standard is long, and some parts of it 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 are already largely in compliance with
many of the provisions, and will simply have to modify your existing programs somewhat. If you are operating 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 communication 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
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