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standard will be implemented in the facility. Preparation of a plan is not just a paper exercise—all of the elements must
be implemented in the workplace in order to be in compliance with the rule. See paragraph (e) of this section for the
specific requirements regarding written hazard communication programs. The only work operations which 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 (b) of this section, scope and application, for the specific requirements for these
two types of workplaces.
The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your
program—an assurance 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 affected 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 developed such materials.
Although such general guidance may be helpful, you must remember that the written program has to reflect what you are
doing in your workplace. Therefore, if you use a generic program it must be adapted to address the facility it covers. For
example, the written plan must list the chemicals present at the site, indicate who is to be responsible for the various
aspects of the program in your facility, and indicate where written materials will be made available to employees.
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, material safety data
sheets, and employee information and training, are going to be met in your facility. The following discussion provides the
type of information compliance officers will be looking for to decide whether these elements of the hazard communication
program have been properly addressed.
A. Labels and Other Forms of Warning
In-plant containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and
appropriate hazard warnings. Chemical manufacturers, importers, and distributors are required to assure 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. Employers 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)
of this section for specific labeling requirements.
The primary information to be obtained from an OSHA-required label is an 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 information. 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 text.
With these requirements in mind, the compliance officer will be looking for the following types of information to ensure
that labeling will be properly implemented in your facility.
1. Designation of person(s) responsible for ensuring
labeling of in-plant containers;
2. Designation of person(s) responsible for ensuring labeling of any shipped containers;
3. Description of labeling system(s) used;
4. Description of written alternatives to labeling of in-plant containers (is used); and
5. Procedures to review and update label information when necessary.
FIGURE 7-4-1: Appendix E—Guidelines for Employer Compliance (continued)
Emergency Aid and Safety Hazard Communication and Material Safety Data Sheets
OSHA Requirements
7-4-6 Treatment Manual 10/2002-04
PPQ
Employers that are purchasing and using hazardous chemicals—rather than producing or distributing them—will
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