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regarding applicable requirements.
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 that 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 (MSDS).
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 which they ship the chemicals. The information is to be
provided automatically. Every container of hazardous chemicals you receive must be labeled, tagged, or marked with the
required information. Your suppliers must also send you a properly completed material safety data sheet (MSDS) at the
time of the first shipment of the chemical, 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 conditions of use or in
a foreseeable emergency.
The requirements of the rule that deal specifically with the hazard communication program are found in this section in
paragraph (e), written hazard communication program; (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 the 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) of this section, 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 operations addresses the obligation of an employer to the
workers in the 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 responsibilities 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.
FIGURE 7-4-1: Appendix E—Guidelines for Employer Compliance (continued)
Emergency Aid and Safety Hazard Communication and Material Safety Data Sheets
OSHA Requirements
7-4-4 Treatment Manual 10/2002-04
PPQ
2. Identify Responsible Staff
Hazard communication is going to be a continuing program in your facility. Compliance with the HCS is not a “one shot
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