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primarily be concerned 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) of this section). In terms of labeling systems, you can simply 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 purchased materials are checked for labels prior to use.
B. 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 this section.
There is no specified format for the MSDS under the rule, although there are specific information requirements. OSHA
has developed a non-mandatory format, OSHA Form 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.
The role of MSDSs under the rule is to provide detailed information on each hazardous chemical, including its potential
hazardous effects, its physical and chemical characteristics, and recommendations for appropriate protective measures.
This information should be 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 be helpful in this regard. Generally speaking, most employers using
hazardous chemicals will primarily be 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 pick-up truck on a construction 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 only permitted under the mobile worksite provision, paragraph (g)(9) of this section, when employees must
travel between workplaces during the shift. In this situation, 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 chemical in the plant as required, and that employee access is
provided, the compliance officers will be looking for the following types of information in your written program:
1. Designation of person(s) responsible for obtaining and maintaining the MSDSs;
2. 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 work shift;
3. Procedures to follow when the MSDS is not received at the time of the first shipment;
4. For producers, procedures to update the MSDS when new and significant health information is found; and
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