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the information about each chemical in the workplace. In general, the most important aspects of training under the HCS
are to ensure that employees are aware that they are exposed to hazardous chemicals, that they know how to read and
use labels and material safety data sheets, and that, as a consequence of learning this information, they are following
the appropriate protective measures established by the employer. OSHA compliance officers will be talking to employees
to determine if they have received training. If they know they are exposed to hazardous chemicals, and if they know where
to obtain substance-specific information on labels and MSDSs.
The rule does not require employers to maintain records of employee training, but many employers choose to do so. This
may help employers choose to do so. This may help you monitor your own program to ensure that all employees are
appropriately trained. If you already have a training program, you may simply have to supplement it with whatever
additional information is required under the HCS. For example, construction employers that are already in compliance
with the construction training standard (29CFR 1926.21) will have little extra training to do.
FIGURE 7-4-1: Appendix E—Guidelines for Employer Compliance (continued)
Emergency Aid and Safety Hazard Communication and Material Safety Data Sheets
OSHA Requirements
7-4-8 Treatment Manual 10/2002-04
PPQ
An employer can provide employees information and training through whatever means are found appropriate and
protective. Although there would always have to be some training on-site (such as informing employees of the location
and availability of the written program and MSDSs), employee training may be satisfied in part by general training about
the requirements of the HCS and about chemical hazards on the job which is provided by, for example, trade
associations, unions, colleges, and professional schools. In addition, previous training, education and experience of a
worker may relieve the employer of some of the burdens of informing and training that worker. Regardless of the method
relied upon, however, the employer is always ultimately responsible for ensuring that employees are adequately trained.
If the compliance officer finds that the training is deficient, the employer will be cited for the deficiency regardless of who
actually provided the training on behalf of the employer.
D. Other Requirements
In addition to these specific items, compliance officers will also be asking the following questions in assessing the
adequacy of the program:
Does a list of the hazardous chemicals exist in each work area or at a central location?
Are methods the employer will use to inform employees of the hazards of non-routine tasks outlined?
Are employees informed of the hazards associated with chemicals contained in unlabeled pipes in their work areas?
On multi-employer worksites, has the employer provided other employers with information about labeling systems and
precautionary measures where the other employers have employees exposed to the initial employer’s chemicals?
Is the written program made available to employees and their designated representatives?
If your program adequately addresses the means of communicating information to employees in your workplace, and
provides answers to the basic questions outlined above, it will be found to be in compliance with the rule.
5. Checklist for Compliance
The following checklist will help to ensure you are in compliance with the rule:
Obtained a copy of the rule.
Read and understood the requirements.
Assigned responsibility for tasks.
Prepared an inventory of chemicals.
Ensured containers are labeled.
Obtained MSDS for each chemical.
Prepared written program.
Made MSDSs available to workers.
Conducted training of workers.
Established procedures to maintain current program.
Established procedures to evaluate effectiveness.
6. Further Assistance
If you have a question regarding compliance with the HCS, you should contact your local OSHA Area Office for
assistance. In addition, each OSHA Regional Office has a Hazard Communication Coordinator who can answer your
questions. Free consultation services are also available to assist employers, and information regarding these services
can be obtained through the Area and Regional offices as well.
The telephone number for the OSHA office closest to you should be listed in your local telephone directory. If you are not
able to obtain this information, you may contact OSHA’s Office of Information and Consumer Affairs at (202) 219-8151
for further assistance in identifying the appropriate contacts.
[59 FR 6170, Feb. 9, 1994, as amended at 59 FR 17479, Apr. 13, 1994; 59 FR 65948, Dec. 22, 1994; 61 FR 9245,
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