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5. Description of alternatives to actual data sheets in the workplace, if used.
For employers using hazardous chemicals, the most important aspect of the written program in terms of MSDSs is to
ensure that someone is responsible for obtaining and maintaining the MSDSs for every hazardous chemical in the
workplace. The list of hazardous chemicals required to be maintained as part of the written program will serve as an
inventory. As new chemicals are purchased, the list should be updated. Many companies have found it convenient to
include on their purchase orders the name and address of the person designated in their company to receive MSDSs.
FIGURE 7-4-1: Appendix E—Guidelines for Employer Compliance (continued)
Emergency Aid and Safety Hazard Communication and Material Safety Data Sheets
OSHA Requirements
10/2002-04 Treatment Manual 7-4-7
PPQ
C. Employee Information and Training
Each employee who may be “exposed” to hazardous chemicals when working must be provided information and trained
prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes. “Exposure” or
“exposed” under the rule means that “an employee is subjected to a hazardous chemical in the course of employment
through any route of entry (inhalation, ingestion, skin contact or absorption, etc.) and includes potential (e.g., accidental
or possible) exposure.” See paragraph (h) of this section for specific requirements. Information and training may be done
either by individual chemical, or by categories of hazards (such as flammability or carcinogenicity). If there are only a few
chemicals in the workplace, then you may want to discuss each one individually. Where there are large numbers of
chemicals, or the chemicals change frequently, you will probably want to train generally based on the hazard categories
(e.g., flammable liquids, corrosive materials, carcinogens). Employees will have access to the substance-specific
information on the labels and MSDSs.
Information and training is a critical part of the hazard communication program. Information regarding hazards and
protective measures are provided to workers through written labels and material safety data sheets. However, through
effective information and training, workers will learn to read and understand such information, determine how it can be
obtained and used in their own workplaces, and understand the risks of exposure to the chemicals in their workplaces as
well as the ways to protect themselves. A properly conducted training program will ensure comprehension and
understanding. It is not sufficient to either just read material to the workers, or simply hand them material to read. You
want to create a climate where workers feel free to ask questions. This will help you to ensure that the information is
understood. You must always remember that the underlying purpose of the HCS is to reduce the incidence of chemical
source illnesses and injuries. This will be accomplished by modifying behavior through the provision of hazard information
and information about protective measures. If your program works, you and your workers will better understand the
chemical hazards within the workplace. The procedures you establish regarding, for example, purchasing, storage, and
handling of these chemicals will improve, and thereby reduce the risks posed to employees exposed to the chemical
hazards involved. Furthermore, your workers’ comprehension will also be increased, and proper work practices will be
followed to your workplace.
If you are going to do the training yourself, you will have to understand the material and be prepared to motivate the
workers to learn. This is not always an easy task, but the benefits are worth the effort. More information regarding
appropriate training can be found in OSHA Publication No. 2254 which contains voluntary training guidelines prepared by
OSHA’s Training Institute. A copy of this document is available from OSHA’s Publications Office at (202) 219-4667.
In reviewing your written program with regard to information and training, the following items need to be considered:
1. Designation of person(s) responsible for conducting training;
2. Format of the program to be used (audiovisuals, classroom instruction, etc.);
3. Elements of the training program (should be consistent with the elements in paragraph (h) of this section); and
4. Procedure to train new employees at the time of their initial assignment to work with a hazardous chemical, and to train employees
when a new hazard is introduced into the workplace.
The written program should provide enough details about the employer’s plans in this area to assess whether or not a
good faith effort is being made to train employees. OSHA does not expect that every worker will be able to recite all of
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