Self-Check: OSHA Hazard Communication (29 CFR 1910.1200) This checklist is designed to assist in the evaluation of a federal OSHA Hazard Communication program. Only the major compliance requirements for employers are covered; hazard determination (for preparers of Material Safety Data Sheets) and other issues related to manufacturers/importers/distributors of hazardous chemicals are not covered by this self-check list. Overview The OSHA Hazard Communication standard applies to all U.S. workplaces that use hazardous chemicals, regardless of chemical quantity or number of employees. Its purpose is to ensure that employees have access to information about the chemicals in their workplace. The full text of the standard is linked from http://www.osha.gov. Click on "Standards", then on "PART 1910 Occupational Safety and Health Standards" and, finally, "1910.1200 - Hazard Communication," at the bottom of the page. “Hazardous chemicals” are defined those with a physical or health hazard. Flammable and reactive are examples of physical hazards; health hazards include toxic, corrosive or carcinogenic effects, among others. See paragraph (c) for more detailed definitions. There are several types of chemicals exempt from the rules, including hazardous waste, food and alcohol products, tobacco, drugs or cosmetics. A full list of exemptions is found in paragraph (b)(6); chemicals exempt from labeling requirements are listed in (b)(5). Laboratories and workplaces that deal only with sealed containers also have reduced obligations under the rule (see paragraphs (b)(3) and (b)(4)). While “consumer products” are listed as exempt from the standard, there is often confusion about how this exemption applies. Consumer products like Windex, White-Out, and WD-40 are exempt from hazard communication requirements only if they are used like a typical home consumer would use them. For example, if you use Windex occasionally to clean the copier glass, it’s exempt from these rules. If an employee uses WD-40 multiple times per day as part of their regular work routine, WD-40 must be included in your program. The self-check on the following pages addresses most of the major requirements of the Hazard Communication standard. Consult the standard references listed for further details and specific regulatory text. All references (e.g., (e)(2)(i)) refer to paragraphs from 29 CFR 1910.1200 unless otherwise noted. (e) Written Program General Requirement: A written program that describes how the elements of the hazard communication program will be accomplished. Does Your Written Program Contain: Descriptions of how labeling, MSDS and employee training will be carried out and maintained. (e)(1) A list of all hazardous chemicals present in the facility. (e)(1)(i) The hazards of any non-routine tasks employees may undertake and how employees will be informed. (e)(2) Hazards associated with chemicals in unlabeled pipes. (e)(2) For multi-employer workplaces (like construction sites), methods to provide other employer’s employees access to MSDS and information on hazards and the labeling system in use. (e)(2)(i-iii) Documentation that the program has been reviewed on a regular basis and updated as necessary? (f) Labels and Other Warnings For chemical manufacturers, importers or distributors, each container leaving the workplace must be labeled with: (f)(1)-(3) ___ Name of the chemical ___ Hazard warnings that provide specific information about the physical and health hazards of the chemical ___ Name and address of the manufacturer For employers, each container of hazardous chemicals in the workplace is identified with labels/signs/other warnings containing: (f)(5)(i-ii), (f)(6); (f)(9) ___ Name of the chemical ___ Hazard warnings that provide specific information about the physical and health hazards of the chemical ___ Information in English and prominently displayed/readily available * Exception: where chemicals are transferred from labeled containers to portable containers for immediate use by the employee making the transfer, the portable container need not be labeled. (f)(7) The labels on incoming containers must be maintained, or re-labeled with the required information. (f)(8) (g) Material Safety Data Sheets Employers must obtain a Material Safety Data Sheet (MSDS) for each hazardous chemical they use. There is no required format for MSDS’s, but they must meet the following requirements: Be written in English. (g)(2) Contain the identity (name) used on the container label for the chemical. (g)(2)(i) Contain all information required in this section including, but not limited to, ingredients, physical and chemical characteristics, physical and health hazards, routes of entry, exposure limits, control measures, emergency information and manufacturer’s information. (g)(2)(i-xii) Employees must have ready access to MSDS for the chemicals in their work area at all times. Electronic systems or other alternatives to paper copies are acceptable as long as they create no barriers to immediate employee access. (g)(8) Employees who travel between work sites during their shift must be able to immediately access MSDS information in an emergency. (g)(9) Keep the MSDS on file, or at least a record of chemicals used, for 30 years after the chemical is no longer used in the facility. (1910.1020 (d)(1)(ii)(B)). These records do not need to be part of the active MSDS inventory. (h) Employee Information and Training Effective training on hazardous chemicals must be provided: (h)(1) ___ At the time of initial assignment ___ whenever a new physical or health hazard is introduced Information/Training must include: An overview of the OSHA Hazard Communication standard. (h)(2)(i) Details of your hazard communication program, including understanding the MSDS and labeling systems. (h)(3)(iv) Location and availability of the written program, list of chemicals, and MSDS. (h)(2)(iii) Operations in their work area where hazardous chemicals may be present. (h)(2)(ii) Methods to detect presence or release of hazardous chemicals. (h)(3)(i) Physical and health hazards of chemicals present in the work area (training may be designed to cover hazard categories (e.g., flammables) rather than specific chemicals). (h)(3)(ii); (h)(1) Exposure control and personal protection measures; emergency procedures. (h)(3)(iii) There are no requirements in 1910.1200 for annual refresher training or documentation of training, but the following is recommended: Provide training on a regular basis to maintain employee understanding of the hazard communication program. Document employee understanding through quizzes, worksheets or exercises. Maintain documentation of all training, including name of presenter, materials used and topics covered, and employee understanding. Administration Ensure that all incoming hazardous chemicals are checked for proper labels and the availability of an MSDS sheet. Develop a system to evaluate new chemicals for the presence of new hazards that may require additional training. Check preparation dates on incoming MSDS’s to verify that you have the most current version of the MSDS in your inventory. For more information, training resources or compliance assistance on Hazard Communication issues, contact the South Dakota Safety Council at 605-361-7785 or 800-952-5539.

Contact the South Dakota Safety Council at
sdsc@southdakotasafetycouncil.org
or phone 605-361-7785 or 1-800-952-5539.