MSDS

Hazard Communication Program, Frequently Asked Questions (FAQs)

07/01/2010 View more Tips

Can MSDSs be stored on a computer to meet the accessibility requirements of HAZCOM?

If the employee\'s work area includes the area where the MSDSs can be obtained, then

maintaining MSDSs on a computer would be in compliance. If the MSDSs can be accessed only

out of the employee\'s work area(s), then the employer would be out of compliance with

paragraphs (g)(8) or (g)(9) [of the Hazard Communication Standard].

What are the container labeling requirements under HAZCOM?

Under HCS, the manufacturer, importer, or distributor is required to label each container of

hazardous chemicals. If the hazardous chemicals are transferred into unmarked containers, these

containers must be labeled with the required information, unless the container into which the

chemical is transferred is intended for the immediate use of the employee who performed the

transfer.

When is the chemical manufacturer required to distribute MSDSs?

Hazard information must be transmitted on Material Safety Data Sheets (MSDSs) that must be

distributed to the customer at the time of first shipment of the product. The Hazard

Communication Standard also requires that MSDSs be updated by the chemical manufacturer or

importer within three months of learning of "new or significant information" regarding the

chemical\'s hazard potential.

What is considered proper training under the HAZCOM standard?

Employees are to be trained at the time they are assigned to work with a hazardous chemical.

The intent of this provision (1910.1200(h)) is to have information prior to exposure to prevent the

occurrence of adverse health effects. This purpose cannot be met if training is delayed until a

later date.

The training provisions of the HCS are not satisfied solely by giving employee the data sheets to

read. An employer\'s training program is to be a forum for explaining to employees not only the

hazards of the chemicals in their work area, but also how to use the information generated in the

hazard communication program. This can be accomplished in many ways (audiovisuals,

classroom instruction, interactive video), and should include an opportunity for employees to ask

questions to ensure that they understand the information presented to them.

Training need not be conducted on each specific chemical found in the workplace, but may be

conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents) that are

or may be encountered by an employee during the course of his duties.

Furthermore, the training must be comprehensible. If the employees receive job instructions in a

language other than English, then the training and information to be conveyed under the HCS will

also need to be conducted in a foreign language.

What are the requirements for refresher training or retraining a new hire?

Additional training is to be done whenever a new physical or health hazard is introduced into the

work area, not a new chemical. For example, if a new solvent is brought into the workplace, and it

has hazards similar to existing chemicals for which training has already been conducted, then no

new training is required. As with initial training, and in keeping with the intent of the standard, the

employer must make employees specifically aware which hazard category (i.e., corrosive, irritant,

etc.) the solvent falls within. The substance-specific data sheet must still be available, and the

product must be properly labeled. If the newly introduced solvent is a suspect carcinogen, and

there has never been a carcinogenic hazard in the workplace before, then new training for

carcinogenic hazards must be conducted for employees in those work areas where employees

will be exposed.

Do you need to keep MSDSs for commercial products such as "Windex" and "White-Out"?

OSHA does not require that MSDSs be provided to purchasers of household consumer products

when the products are used in the workplace in the same manner that a consumer would use

them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than

what the typical consumer would experience. This exemption in OSHA\'s regulation is based,

however, not upon the chemical manufacturer\'s intended use of his product, but upon how it

actually is used in the workplace. Employees who are required to work with hazardous chemicals

in a manner that results in a duration and frequency of exposure greater than what a normal

consumer would experience have a right to know about the properties of those hazardous

chemicals.

What are the requirements and limits to using generic MSDSs?

... [Regarding] the suitability of a generic material safety data sheet (MSDS). As you are probably

aware, the requirements for MSDSs are found in paragraph (g) of 29 CFR 1910.1200. MSDSs

must be developed for hazardous chemicals used in the workplace, and must list the hazardous

chemicals that are found in a product in quantities of 1% or greater, or 0.1% or greater if the

chemical is a carcinogen. The MSDS does not have to list the amount that the hazardous

chemical occurs in the product.

Therefore, a single MSDS can be developed for the various combinations of ... [chemicals], as

long as the hazards of the various... mixtures are the same. This "generic" MSDS must meet all

of the minimum requirements found in 29 CFR 1910.1200(g), including the name, address and

telephone number of the responsible party preparing or distributing the MSDS who can provide

additional information.

The above information comes from the OSHA website found at this link:

http://www.osha.gov/html/faq-hazcom.html

OSHA gives links to actual Letters of Interpretation and other references for each of the questions

and explanations given above.