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Training Initially and at Introduction of New Hazard - (h)(1)
Training (h)(3)-1


HCS and the Paperwork Reduction Act I-1
OSHA Publications and Compliance Guidance I-3


In the February 9, 1994, Amendments to the Final Hazard Communication Rule, paragraph (h) has been modified. The initial discussion of when training is to be provided is now under (h)(1); please refer to the corresponding section of this document for the new wording. The information requirements are now listed under (h)(2), with no changes in wording. The training requirements are now listed under (h)(3), with no changes in wording.

MSDS information and training requirements for retailers

29 CFR 1910.1200(h)

For employees who may be exposed to hazardous chemicals in the workplace, paragraph (h) specifies the information and training requirements. For example, employers are required to inform employees of the location and availability of MSDSs.

The HCS does not apply to the general public. Normally, MSDS's are not required to be transmitted to retail consumers unless they request one. The purpose of OSHA's HCS is to reduce chemical source illnesses and injuries through acquisition of hazard information. This can only occur if employees receive the information on the hazardous substances they work with in usable form through appropriate training, which will enhance their ability to understand the sheets. In effect, employees at a worksite with hazardous chemicals must be trained on the hazardous materials they are exposed to, how to obtain and use information on labels and material safety data sheets (MSDSs), and how to follow appropriate work practices.

letter: JDuncan 09-28-94

Employer responsibilities to provide information and training to temporary employees.

29 CFR 1910.1200(h)

Question 1: Who is responsible for hazard communication training of [a] temporary employee. The [temp] agency or the client employer?

OSHA considers temporary employment agencies who send their own employees to work at other facilities to be employers whose employees may be exposed to hazards. Since it is [the temp agency], which maintains a continuing relationship with its employees, but another employer (the client) who creates and controls the hazards, there is a shared responsibility for assuring that [temporary] employees are protected from the workplace hazards. The client has the primary responsibility of such protection. The "lessor employer" likewise has a responsibility under the Occupational Safety and Health Act.

In meeting the requirements of OSHA's Hazard Communication standard the lessor employer would, for example, be expected to provide the training and information requirements specified by the HCS section (h)(1). Client employers would then be responsible for providing site-specific training and would have the primary responsibility to control potential exposure conditions. The client, of course, may specify what qualifications are required for supplied personnel, including training in specific chemicals or personal protective equipment (PPE). Contracts [between the lessor employer and the] client employer and [temporary] employees should clearly describe the responsibilities of both parties in order to ensure that all requirements of the regulation are met.

Question 2: Who is responsible for the provision and assured use of appropriate personal protective equipment by the temporary employees?

Client employers would be responsible for providing PPE for site-specific hazards to which employees may be exposed. However, again, the client may specify the services that it wants the lessor employer to supply, including provision of PPE for the placed employees. Contracts with the client employer should clearly describe the responsibilities of both parties in order to ensure that all requirements of OSHA's regulations are met.

Question 3: When medical surveillance or monitoring is indicated, who is responsible for conducting the monitoring and maintaining records?

The client employer must offer and perform the required medical surveillance or evaluations. The lessor employer must ensure that the records of the required medical surveillance or evaluations are maintained in accordance with the appropriate OSHA standards.

Question 4: Is the temporary help service required to maintain cumulative exposure data (e.g., 30 day lead exposure, 6 months noise exposure, etc.), when the employee works for several different companies during the year?

Yes, the temporary help service must maintain employee records in accordance with the appropriate OSHA standard (e.g., the Lead standard, the Occupational Noise Exposure standard, etc.). However, the client employer must perform the site characterization and monitoring of exposure to hazardous chemicals on the work site.

Question 5: If 29 CFR 1910.1200(h) requires training on hazardous chemicals in the work area at the time of the initial assignment and whenever a new hazard was introduced into their work place, when does the initial assignment begin and who is responsible for the initial training and the on-going training?

The lessor employer would be expected to provide some generic training and client employers would be responsible for providing site-specific training, or training to update employees on new hazards in the workplace. Please see the answer to question 1 for a further explanation.

letter: MMoreau 02-03-94

see also: DHays 06-16-88

OSHRC rules on training requirements

29 CFR 1910.1200(h)

In this case dealing with what constitutes "training" under the Hazard Communication Standard (HCS), the [OSHA Review] Commission reversed the judge's vacation of a 1910.1200(h) violation, where the judge had found that because employees had access to material safety data sheets (MSDSs) and labels, they were provided with the information intended by the standard. The Commission ruled that the multiple requirements of 1910.1200(h) went beyond merely informing employees of the location and availability of the written program and MSDS required by the first part of the standard. In upholding the 1910.1200(h) citation, the Commission noted that in addition to information conveyance, the standard's training requirements specifically required more of employers than informing employees what hazard information was generally available.

court: ARA 15 BNA OSHC 1417, Docket No. 89-1894, 1991

Training and information requirements and intent

29 CFR 1910.1200(h)

OSHA does not expect that every worker will be able to recite all of the information about each chemical in the workplace. The labels serve as an immediate reminder of the hazard information, while material safety data sheets (MSDSs) are a more detailed reference source ... the training is to ensure that employees are aware they are exposed to hazardous chemicals, and that they know how to obtain, read and use the written information on labels and MSDSs.

[Originally written for the distribution industry]

letter: EIsenberg 01-22-90

Determining compliance with information and training requirement

29 CFR 1910.1200(h)

The purpose of OSHA's Hazard Communication Standard (HCS) is to reduce chemical source illnesses and injuries through acquisition of hazard information. This can only occur if employees receive the information on the hazardous substances they work with in usable form through appropriate training. In order to determine if this has occurred, compliance officers conduct interviews with affected employees and responsible management officials. A review of the written hazard communication program, as required under paragraph (e) of the standard, provides the compliance officer with information on how the employer provides hazard information to his employees, the elements of the employer's program, and procedures he uses to train new employees.

Employees at a worksite with hazardous chemicals must be aware of the hazardous materials they are exposed to, how to obtain and use information on labels and material safety data sheets (MSDSs), and how to follow appropriate work practices. If, through a review of the written hazard communication program and employee/management interviews, the CSHO [Compliance Safety and Health Officer] detects a trend in employee responses that indicates training is not being conducted or is conducted in a cursory fashion that does not meet the intent of the standard, a closer review of the employer's training program is indicated which may result in the issuance of a citation.

[Originally written for the HVAC industry]

letters: DFox 07-24-89, KKrauska 07-24-89

Training to include information concerning another employer's worksite

29 CFR 1910.1200(h)

If [one's] employees are being placed in workplaces where they will be exposed to hazardous chemicals, then [the employer] is responsible for ensuring that they are provided proper training. [The employer] could accomplish this by providing the training herself, or ensuring that training is provided as part of the contracting arrangement with the [other] employer using the services of her employees. In any event, part of the training must deal with the location and availability of material safety data sheets (MSDSs). [The employer] could satisfy her duties in this regard by requesting access to the data sheets from the employer at the site, or by training her employees to request such information when they ascertain that their duties involve exposure to hazardous chemicals.

letter: JBunning 03-31-89 Congress


Exhaust emissions: obligations of manufacturer and employer

29 CFR 1910.1200(b)(1)

Diesel exhaust emissions per se are not covered by the HCS. Diesel fuel however is covered by the HCS and any known hazards associated with this fuel must be reported on the material safety data sheet, including the hazards associated with the combustion of the fuel.

All employers are required to develop and implement employee training programs regarding hazards of chemicals and protective measures for all employees exposed to hazardous chemicals in their work areas under normal operating conditions or in foreseeable emergencies. Employees in terminal operations exposed to hazardous chemicals would fall under these provisions. If employees in terminal operations are exposed to diesel fuel in their work areas, the hazards of diesel fuel must be incorporated in the training program. Trucks or other vehicles are not considered work areas for the purposes of the standard. Vehicle operators would not be covered while operating a motor vehicle, however operators would be covered while performing terminal operations.

letter: ASchaeffer 12-22-88

Training Initially and at Introduction of New Hazard - (h)(1)

Per the February 9, 1994, Amendments to the Final Hazard Communication Rule, the initial discussion of when training is to be provided is now under (h)(1), with changes in wording indicated in quotation marks:

(1) Employers shall provide employees with "effective" information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new "physical or health hazard the employees have not previously been trained about" is introduced into their work area. "Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets."


Training employees in new workplace hazards

29 CFR 1910.1200(h)

You requested clarification of 1910.1200(h), regarding the requirement for additional employee training whenever new hazards are identified. OSHA feels that the receipt of a new [Material Safety Data Sheet (MSDS)] or chemical compels the employer to evaluate the information provided in the MSDS to ascertain whether the new product represents a new health or physical hazard to employees. Training would have to be provided to affected employees when new hazards are introduced into the workplace (not necessarily new chemicals).

The intent of the [Hazard Communication Standard (HCS)] training is to provide information to employees on the hazards they encounter in the workplace. Retraining can be as simple as a weekly safety meeting that highlights new chemicals in the workplace. As long as the initial training covers categories of chemicals and hazards, and how to read and understand MSDSs, retraining would merely have to assure that new products and chemicals are identified to the employees and that the hazards, if any, are recognized.

letter: EWilson 09-07-93

Site-specific information and training requirements

29 CFR 1910.1200(h)

Training may be done on every chemical on the site, or it may be done on classes of chemicals, such as flammable hazards. In addition, it is not true that every employer has to re-train every employee when they know they have been trained elsewhere. There will always be some site-specific training required to ensure that workers know about the hazard communication program on that site.

[Originally written for the construction industry]

letter: RLugar 06-26-92 Congress

When training is to be conducted

29 CFR 1910.1200(h)

Employees are to be trained at the time they are assigned to work with a hazardous chemical. The intent of this provision 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.

Additional training is to be done whenever a new 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. Of course, the substance-specific data sheet must 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 carcinogen hazards must be conducted in the work areas where employees will be exposed to it.

CPL 2-2.38C: A-34 10-22-90

Training conducted for categories of hazards

29 CFR 1910.1200(h)(2)

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. This approach to training may be especially useful when training employees about the types of hazards they may encounter at another employer's worksite.

CPL 2-2.38C: A-35 10-22-90

Additional training when new hazards are introduced

29 CFR 1910.1200(h)

Since training has to be provided to affected employees when new hazards are introduced into the workplace (not necessarily new chemicals), the receipt of a new material safety data sheet (MSDS) compels the employer to scrutinize the data to ascertain if the new product represents a new health or physical hazard to his employees for which he would have to provide additional training.

letter: JDanforth 02-07-90 Congress

Records of employee training not required

29 CFR 1910.1200(h)

The Hazard Communication Standard (HCS) sets performance-oriented employee training requirements at section 1926.59 (h) in order to ensure that employees are provided with information and training about the hazardous chemicals they work with, both at the time of their initial assignment and whenever a new hazard is introduced into their work area. However, ..., there is no requirement that "employee training records" be maintained at each jobsite, in fact, there is no requirement in the HCS to maintain any records of employee training.

[Originally written about a contractor]

letter: MHancock 09-07-89

Training - (h)(3)

Per the February 9, 1994, Amendments to the Final Hazard Communication Rule, the training requirements are now listed under (h)(3), with no changes in wording.

Meeting the intent of training in the janitorial services industry

29 CFR 1910.1200(h)(3)

The literacy of the workforce in general is a problem, and is not limited to any specific type of industry. Workers' inability to access and effectively use written information requires more effort to be placed upon proper training. You indicated that you have no problem training people to do their tasks. This training should also include information about how to do those tasks safely, including how to protect themselves from hazardous chemicals. We believe that training under the Hazard Communication Standard (HCS) can be done effectively for workers with different kinds of educational backgrounds. The most important message to be conveyed during the training is that they are exposed to hazardous chemicals, and that proper protective measures are to be followed. They must also know where they can get more information, and to read and use labels and material safety data sheets (MSDS) when they can.

Your comments regarding inclusion of other employers' chemicals in your program suggest there may be some misunderstanding regarding the requirements of the HCS. Training is generally done on categories of hazards, rather than on individual chemicals or specific MSDSs. Appropriate hazard warnings must be on the labels and MSDSs of hazardous chemicals and employers are to train their employees about those hazards. Once you have trained workers about all possible types of hazards covered by the rule, you do not have to re-train for a new chemical that poses one or more of those hazards (e.g., is designated as being flammable and capable of causing skin irritation). Workers should be trained not to use chemicals unless they have the necessary information to protect themselves. If they must work around another employer's chemicals, then you should inquire as to any particular protective measures that would be necessary, and provide them with the information and equipment that they need. You need not have direct supplier control of the chemicals in order to provide protection for your workers.

While industry characteristics such as employee turnover may make compliance more difficult, they do not negate the need and responsibility to properly inform workers.

letter: LFriedman 05-23-91

Retraining of newly hired employees

29 CFR 1910.1200(h)(3)

Complete retraining of an employee does not automatically have to be conducted when an employer hires a new employee, if the employee has received prior training by a past employer, an employee union, or any other entity. It is highly unlikely that no additional training will be needed since employees will need to know the specifics of their new employers' programs such as where the material safety data sheets (MSDSs) are located and details of the employer's in-plant labeling system, if appropriate.

CPL 2-2.38C: A-34 10-22-90

Current employer responsible for employee's level of knowledge

29 CFR 1910.1200(h)(3)

If it is determined that an employee has not received training or is not adequately trained, the current employer will be held responsible regardless of who provided the training to the employee. An employer, therefore, has a responsibility to evaluate an employee's level of knowledge with regard to the training and information requirements of the standard, and the employer's own hazard communication program, including previous training the employee may have received. The training requirements also apply if the employer becomes aware via the multi-employer worksite provision [(29 CFR 1910.1200(e)(2))] of exposure of his employees to hazards for which they have not been previously trained.

CPL 2-2.38C: A-34&35 10-22-90

Providing employees with information and training

29 CFR 1910.1200(h)(3)

Giving an employee a data sheet to read does not satisfy the intent of the standard with regard to training. The training 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.

Furthermore, the training must be comprehensible. If the employees must receive job instructions in a language other than English, then training and information will probably also need to be conducted in a foreign language.

CPL 2-2.38C: A-36 10-22-90

Pre-packaged training programs

29 CFR 1910.1200(h)(3)

OSHA does not perform reviews of employer training materials to determine if their use will render the user in compliance with our standards. Further, OSHA does not approve nor does it endorse documents such as ... commercially available training program(s) ...

The Hazard Communication Standard (HCS) is a performance-based standard. This means that employees have the flexibility to adapt the rule to the needs of their workplace, rather than having to follow specific, rigid requirements. The HCS, at section (h), sets forth the elements that must be included in an employer's hazard communication training. According to the standard, employee training must consist of the following elements: There must be a discussion on how to read and to interpret information on the material safety data sheet (MSDS) and on the labels, how employees can obtain and use the hazard information that is available and how the hazard communication program is implemented in their workplace. The training course must also address the hazards of the chemicals in the work area and the measures that the employees can take to protect themselves from the hazards. The training course must further cover the specific procedures that the employer uses to provide protection such as engineering controls, work practices and the use of personal protective equipment. Finally, the training course must include the methods and observations that the workers can use to detect the presence of a hazardous chemical to which they may be exposed.

... many of the areas that must be addressed in hazard communication training are workplace specific - for example, training on the specific chemical hazards at your workplace. It is doubtful that these training requirements could be specifically addressed by [a] purchased or pre-packaged training program.

letter: RHeskamp 08-01-90

Certified technicians are required to complete hospital HCS training program

29 CFR 1910.1200(h)(3)

Trained, certified technicians [i.e., Radiology, Pharmacy, Laboratory, etc.] are required to complete the training program as outlined in 29 CFR 1910.1200 (h). If an employee has previously received training on hazardous chemicals during prior employment at a different facility, then the employee would still be required to be trained for current employment. Topics which are unique for current employment would be operations in the work area where hazardous chemicals are present, the location of material safety data sheets, and the procedures implemented to protect employees in the facility including availability of personal protective equipment. It must be noted that the current employer should reiterate specific chemical training as required by 29 CFR 1910.1200 since the level of training will vary among facilities.

[Originally written for the hospital industry]

letter: FRoth 09-01-89

Training requirements for contracted employees

29 CFR 1910.1200(h)(3)

As a minimum, generic training should be given to all your employees prior to job assignments where they will be or potentially could be exposed to hazardous chemicals. Since your employees are contracted to extended job assignments, directly working under the supervision of the other employer, you can possibly work out a contractual agreement for the other employer to provide the training specific to the hazardous materials used at that job site. It is our recommendation that you actively assure yourself that such training is being provided and is adequate to fulfill your employer responsibilities under the HCS. For your employees, the training program will most likely be the most important component of your hazard communication program because it can be individualized to your employees' abilities. Every effort must be made to train and effectively warn the employees of exposure to hazardous chemicals at the appropriate level of their understanding in view of their special educational requirements.

letter: DHays 06-16-88

see also: MMoreau 02-03-94

Previous training for union hall employees: responsibilities of current employer

29 CFR 1910.1200(h)(3)

You asked "whether a contractor's association can train union hall employees and qualify for training under the hazard communication rule," or "whether each contractor must train each employee coming to them from a union hall, irrespective of the associations." Each employer is responsible for training under the Hazard Communication Standard. The standard, however, does not require that each new employee be trained.

The HCS is a performance-oriented standard and the goal of the training provisions is to ensure that employees are trained according to those provisions. It is OSHA's position, therefore, that training can be provided by the current employer, a past employer, an employee union, or any other entity. From an enforcement standpoint OSHA field personnel will evaluate an employer's compliance with the training and information provisions of the HCS. If it is determined that an employee has not received training or is not adequately trained the current employer will be held responsible regardless of who trained that particular employee. An employer, therefore, has a responsibility when hiring a new employee, who has been previously trained by someone other than the current employer to evaluate the employee's level of knowledge against the training and information requirements of the standard.

letter: FPellegrini 05-11-88

HCP must address training on target organ effects and alternative labeling systems.

29 CFR 1910.1200(h)(3)(ii)

Paragraph (e)(1) of the Hazard Communication Standard (HCS) requires employers to include in their written hazard communication program a description of how the training requirements of paragraph (h) will be met, and subparagraph [(h)(3)(ii)] requires employees to be trained on the physical and health hazards of the chemicals they work with. OSHA has interpreted this to include being apprised of the target organ effects of the hazardous chemicals employees are or may be exposed to while working. The training program must therefore explicitly instruct employees on how to use and understand the plant's alternative labeling systems to ensure that employees are aware of the effects (including target organ effects) of the hazardous chemicals to which they are potentially exposed.

CPL 2-2.38C: A-19 10-22-90

Training and information must cover all hazards

29 CFR 1910.1200(h)(3)(ii)

The intent of the Hazard Communication Standard (HCS) is for the employer to provide information to employees on the hazards they encounter in the workplace. These hazards include those brought into the workplace by the employer as well as, ... hazards to which the employees are exposed even though the employer is not responsible for the existence of those hazards.

[Originally written for demolition industry]

letter: RBrooks 01-09-90

HCS interface with emergency plan and fire prevention standard

29 CFR 1910.1200(h)(3)(iii), 29 CFR 1910.120(q) and 29 CFR 1910.38(a)

The Hazard Communication Standard (HAZCOM), although it requires training in emergency procedures, does not require that emergency procedures be developed. The employer is required to develop emergency procedures in other standards such as 1910.120, 1910.38(a) where referenced, and health standards with emergency response provisions. The HAZCOM training must include information about emergency response procedures that have been developed. The next revision of the HAZCOM standard will clarify this position.

memorandum: PClark (DCP) to all Regional Administrators 5-08-92

Training and emergency procedures

29 CFR 1910.1200(h)(3)(iii)

A frequently overlooked portion of the training provisions is that dealing with emergency procedures. If the chemical is very hazardous, more information would be expected to be provided on the material safety data sheets (MSDSs) and, therefore, the training for emergency procedures, including information about the characteristics of the chemical and precautions to be taken would need to be more extensive. Section 1910.1200(h) requires training of employees on (among other things) the measures employees can take to protect themselves from hazards including emergency procedures and an explanation of the information on the MSDSs. Section (g)(2)(viii) of the Hazard Communication Standard (HCS) requires the MSDSs to address safe handling and use of chemicals which includes cleanup of spills and leaks. Section (g)(2)(x) requires the MSDSs to address emergency and first aid procedures.

CPL 2-2.38C: A-35 10-22-90

Training and information requirements for emergency procedures

29 CFR 1910.1200(h)(3)(iii) and 29 CFR 1910.120(q)(6)

Questions have arisen regarding the interface of 1910.120 training requirements for emergency procedures and those for the Hazard Communication Standard (HCS). The scope and extent of training regarding emergency procedures will necessarily be dependent upon the desired response of employees to an emergency. If the employer intends to merely evacuate the work area, the training in emergency procedures would be quite simple and limited but should include information on the emergency alarm system in use at the worksite and evacuation routes and areas where applicable. However, if the employees are expected to take appropriate action to moderate or control the impact of the emergency in a similar fashion as emergency responders would, then additional training will be required. At a minimum, training these responders on the "emergency procedures" required under section (h) should include, as applicable, leak and spill cleanup procedures, appropriate PPE, decontamination procedures, shut-down procedures, recognizing and reporting unusual circumstances (incidents), and where to go (evacuate to) in an emergency.

CPL 2-2.38C: A-35&36 10-22-90

Emergency protection

29 CFR 1910.1200(h)(3)(iii)

...[E]mployees should be following the appropriate protective and emergency measures which have been established by the employer to reduce the risks posed by exposure to the chemical hazards. In the unfortunate event of an injury or illness on the job, it is still the responsibility of the employer to provide appropriate first aid and medical services for the employee.

[Originally written for the distribution industry]

letter: EIsenberg 01-22-90

Maintaining all MSDSs on a chemical produced by several manufacturers.

29 CFR 1910.1200(h)(3)(iv)

Question: Specific chemicals such as acetone, xylene, etc. do not always come from the same manufacturer and each manufacturer supplies an MSDS for their chemicals. Is it necessary to have in the central repository copies of all MSDSs from each company or could one complete MSDS serve the needs for all acetone, etc. used for routine purposes, emergency situations or both?

Given the performance oriented nature of the standard, an employer must be certain that employees are provided all the necessary information concerning the hazards of chemicals in the workplace. There are a number of concerns with the approach you describe. First, you must ensure that the specific identity on the MSDS can be cross referenced to the corresponding label of the hazardous chemical containers [(29 CFR 1910.1200(g)(2)(iv))]. Second, the employer must ensure that employees are informed during the hazard communication training of this practice of using one MSDS as representative of all vendors, otherwise it could lead to confusion [(29 CFR 1910.1200(h)(3)(i))]. Third, the MSDS you select must have complete and accurate information as required by section (g)(5) of the HCS. And finally, the standard requires that the MSDS contain the name, address and telephone number of the party who prepares or distributes the MSDS [(29 CFR 1910.1200(g)(2)(xii))]. The party listed must be able to provide additional information on the hazardous chemicals or clarification of the information on the MSDS, as well as, additional emergency procedures, if necessary, in lieu of the actual manufacturer. A chemical manufacturer, importer or distributor may not wish to and is not required to act as the responsible party for a chemical that they did not produce.

letter: JBalsamo 02-01-94

Conveying hazard information through labels, MSDS, and training

29 CFR 1910.1200(h)(3)(iv)

OSHA is currently reviewing labels and material safety data sheets (MSDS) to determine whether modifications to the requirements are necessary to improve the presentation and quality of the information. With regard to abbreviations, these documents are being used by health and safety professionals, as well as by workers. Technical information must be conveyed to be useful to these multiple audiences. In order to ensure that employees can access the information, employers are required to train workers to read and understand the MSDS information, including abbreviations where used.

The label you included in your letter is not required by OSHA, and is not being used in most workplaces. OSHA has permitted employers to use such labeling in their workplaces, as long as the required training clearly explains the labeling system, and supplements this type of acute hazard label with information about chronic hazards as well. It would not be appropriate to require preparers of MSDSs to provide such non-mandatory or voluntary label information on the data sheet itself.

letter: HHannum 11-09-90


Trade secrets and medical emergencies

29 CFR 1910.1200(i)

The designation of an incident as a "medical emergency" is left to the discretion of the treating physician or nurse.

CPL 2-2.38C: A-36 10-22-90

MSDS preparation under trade secret provisions

29 CFR 1910.1200(i)

You requested guidance on how to prepare a Material Safety Data Sheet (MSDS) under the trade secret provisions of the standard.

1. Is it acceptable to state "proprietary component A" or must you state "proprietary sulfur compound"?

It would be acceptable to refer to the trade secret chemical either as "Component A" or as "proprietary sulfur compound."

2. How does one state a Threshold Limit Value (TLV) for a proprietary compound? Can this be omitted or can several TLV's be stated if all are appropriate?

If there is an OSHA permissible exposure limit and a TLV for the proprietary component A, then that value would need to be reflected on the MSDS. If there is a PEL and TLV for the proprietary component A it cannot be withheld from the MSDS.

3. Can volume percentages be omitted for proprietary components?

The standard does not require the release of any volume percentages of any chemicals on the MSDS.

4. Under Health Hazard is it acceptable to refer to components as "Component A" or as "one component"? Can overexposure symptoms be discussed without divulging chemical families?

It would be acceptable to reference the health hazards associated with one chemical to that particular constituent; [Ex. Health Hazards of Component A are...] The health hazard information must include the signs and symptoms of exposure.

letter: RRoberson 12-10-85


Determination of carcinogenicity of a mixture containing attapulgite clay.

29 CFR 1910.1200 Appendix B

[Scenario:] The...MSDS [for a product containing attapulgite clay] specifies that attapulgite clay contains 1-10% crystalline silica. The Attapulgite clay mixture has been "tested as a whole" by the International Agency for Research on Cancer (IARC) and classified as a Group 3 substance.

An IARC Group 3 classification indicates that insufficient evidence is available to classify an agent as to its carcinogenicity (i.e., interpretations of human and animal data are restricted and limited, respectively).

The IARC classifies crystalline silica as a probable human carcinogen (Group 2A).

In addition to IARC classifications, OSHA requires a health hazard to be listed on the MSDS whenever one positive study conducted in accordance with established scientific principles indicates a hazardous effect.

[Question:] [Given the above information, is it] necessary to include a carcinogenic statement or an inference of a carcinogenic hazard on the MSDS for the product containing Attapulgite?

[The importer or manufacturer of this product] would be required to list crystalline silica as a hazardous component, with the statement that crystalline silica is a probable human carcinogen, for the following reasons:

1. Appendix B of 29 CFR 1910.1200 establishes the criteria in making hazard determinations of products that meet the requirements of this standard. The appendix states that: "Hazard evaluation is a process which relies heavily on the professional judgement of the evaluator, particularly in the area of chronic hazards. The performance-orientation of the hazard determination does not diminish the duty of the chemical manufacturer, importer, or employer to conduct a thorough evaluation, examining all relevant data and producing a scientifically defensible evaluation. The appendix also requires that, "all available scientific data on carcinogenicity must be evaluated in accordance with this appendix and the requirements of the rule."

Given that Attapulgite has been tested as a whole, and the result is inconclusive, the statistically significant and scientifically valid evidence supporting carcinogenicity for crystalline silica cannot be discounted and must be presented on the MSDS. We believe that this position is consistent with section 1910.1200(d)(5)(i) of the standard that addresses mixtures tested as a whole.

2. The April 18, 1989 version of the MSDS for Attapulgite clay states that the percent composition for crystalline silica is between 1% and 10%. There is no indication that the composition of the Attapulgite clay has changed. Therefore, since...[the] product [identified on the MSDS] contains roughly one third Attapulgite, it clearly contains greater than 0.1% crystalline silica.

3. Further, no evidence is presented to indicate that crystalline silica is inextricably bound in Attapulgite. Therefore, under normal conditions of use or during foreseeable emergencies crystalline silica [should] be indicated as a hazardous ingredient, since it potentially results in employee exposure.

letter: DSperanza 06-16-94


HCS and the Paperwork Reduction Act

The Supreme Court ultimately decided this issue, and ruled that the Paperwork Reduction Act applied only to information collection requirements, not to information disclosure requirements, and that therefore, OMB had no authority regarding the requirements of the HCS.

Coverage of drugs regulated by the food and drug administration (FDA)

29 CFR 1910.1200(b)(2)

In 1987 OSHA received a letter from the OMB [Office of Management and Budget] which was published in the Federal Register on December 4, 1987 (Volume 52, page 46075). The letter concluded that OMB disapproved the [Hazard Communication Standard's (HCS)] coverage of any FDA regulated drugs in the non-manufacturing sector. On OMB's advice, OSHA published a statement of concurrence in a Notice of Proposed rulemaking and Notice of Public Hearing for the HCS, published in the Federal Register on August 8, 1988 (Volume 53, page 29822).

However, on August 19, 1988, the U.S. Court of appeals for the Third Circuit invalidated OMB's actions as being outside OMB's authority under the Paperwork Reduction Act (see United Steelworkers of America v. Pendergrass, 855 F.2d 108 (3rd. Cir., 1988), Ex. 4-190). As ordered by the court, OSHA published a notice in the Federal Register on February 15, 1989 (Volume 54, page 6886) to inform affected employers and employees that all provisions of the HCS would be in effect in all industries, and set March 17, 1989, as the date for initiation of programmed compliance inspections. In Dole v. United Steelworkers of America, 110 S.Ct 929 (1990), the supreme Court affirmed the ruling of the Third Circuit. Therefore, HCS applies to FDA regulated drugs in the non-manufacturing sector, that pose a hazard to employees.

letter: MRichards 12-30-92

Disapproved provisions reinstated, and HCS to be enforced in construction industry

29 CFR 1910.1200(b)

On August 24, 1987, a final rule covering all employers was published in the Federal Register. Due to subsequent court and administrative actions, for a number of months OSHA was prevented from enforcing the rule in the construction industry, and enforcing in any industry certain requirements dealing with the maintenance of material safety data sheets on multi-employer worksites, coverage of consumer products, and the coverage of drugs in the non-manufacturing sector. As a result of further court actions, all provisions of the rule are now in effect in all segments of industry. OSHA, however, extended the compliance date until March 17, 1989, for programmed inspections in the construction industry and the three previously disapproved provisions.

memorandum: TShepich (DCP) to RAs 03-17-89

Office of management and budget faulty analysis under paperwork reduction act

29 CFR 1910.1200

The Office of Management and Budget (OMB) found all three of the requirements of the Hazard Communication Standard (HCS) to meet the provisions of the Paperwork Reduction Act. These three requirements are: 1) the requirement that material safety data sheets be provided on multi-employer worksites; 2) the coverage of any consumer product that falls within the "consumer products" exemption included in Section 311 (3) of the Superfund Amendments and Reauthorization Act of 1986; and 3) the coverage of any drugs regulated by the Food and Drug Administration in the nonmanufacturing sector.

On August 19, 1988, The United States Court of Appeals for the Third Circuit ruled that the OMB had exceeded its authority, under the Paperwork Reduction Act, in disapproving three provisions of the expanded HCS. The court ordered OSHA to "publish in the Federal Register a notice that those parts of the August 27, 1987, HCS which were disapproved by OMB are now effective." On September 2, 1988, the Department of Justice filed a petition for rehearing with a suggestion for rehearing by the entire court. The Court has now denied the petition for rehearing (November 29, 1988), as well as requests for stay of the decision. In addition, a further motion by industry representatives for a stay of the decision was denied on January 24, by U.S. Supreme Court Justice Brennan. The Solicitor General has authorized the filing of a petition for a writ of certiorari on behalf of the government in the United Steelworkers case. Also, on January 27, industry resubmitted its stay request with Chief Justice Rehnquist in both United Steelworkers and Associated Builders and Contractors. That request is pending. If certiorari is granted, the Supreme Court will ultimately decide the enforceability of these provisions. The Third Circuit's decision became effective January 30 of this year and all provisions of the HCS are now in effect in all industries.

letter: WEmerson 03-03-89 Congress

OSHA Publications and Compliance Guidance

OSHA compliance directive: guidelines for HCS

29 CFR 1910.1200 & CPL 2-2.38C

On October 22 [1990], the newly-revised Hazard Communication compliance directive, OSHA Instruction CPL 2-2.38C, was issued. This directive, entitled "Inspection Procedures for the Hazard Communication Standard," contains compliance guidelines, clarifications and interpretations on all provisions of the standard, including the Agency's enforcement policies regarding workplace use of consumer products.

Please note that this OSHA Instruction is not a "rule", per se, ... OSHA Instructions provide interpretative guidance and Agency enforcement policies which are particularly relevant and helpful for this "performance oriented" standard.

letter: DHelm 11-27-90

Two OSHA booklets

29 CFR 1910.1200

... two OSHA booklets, "Chemical Hazard Communication" and "Hazard Communication Guidelines for Compliance" ... may be helpful to you in explaining the requirements of OSHA's Hazard Communication Standard, 29 CFR 1910.1200.

letter: JReardon 10-20-90

Step-by-step guidance for compliance with HCS

29 CFR 1910.1200

OSHA has developed a number of resources to assist employers in complying with the Hazard Communication Standard (HCS). A kit produced to OSHA is available that provides step-by-step guidance on complying with the requirements of the standard and serves equally well the needs of all employers, regardless of the industry in which they operate. The kit may be purchased through the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C., 20402-9325 at a cost of $18.00. It has a GPO Order No. 929-022-00000-9 and is OSHA 3104, Hazard Communication Kit. It may be ordered by telephone from GPO by calling (202) 783-3238 and using a credit card.

In addition, a booklet entitled, "Chemical Hazard Communication" (copy enclosed) provides employers with an easy-to-read explanation of the responsibilities of employers under the HCS. The booklet also contains a directory of all OSHA Regional and Area Offices. Employers may contact a Regional or Area Office for additional information or assistance.

[Originally written for oil and gas production industry]

letter: DBoren 05-03-89 Congress

Hazard communication compliance kit

29 CFR 1910.1200

OSHA has developed a number of resources to assist employers in complying with the HCS. A kit produced by OSHA is available that provides step-by-step guidance on complying with the requirements of the standard and serves equally well the needs of all employers, regardless of the industry in which they operate.

The kit may be purchased through the Superintendent of Documents, U.S. Government Printing Office, Washington D.C., 20402-9325, at a cost of $18.00. It has GPO Order No. 929-022-00000-9 and is OSHA 3104 Hazard Communication Compliance Kit. It may be ordered by telephone from GPO by calling (202) 783-3238 and using a credit card.

letter: BEmerson 03-03-89

OSHA does not "approve" compliance assistance materials

29 CFR 1910.1200(g)

We do not approve materials developed by the private sector. OSHA staff has informally reviewed a number of materials at the request of the organizations preparing them, and has pointed out to them any inaccuracies or inconsistencies. However, in no case have we thereby endorsed or approved such materials.

If any organization represents OSHA's review as an approval, and advertises the material as being OSHA-approved, OSHA will refer the matter to the Federal Trade Commission for investigation.

Other than the informal reviews requested by preparers of compliance assistance, OSHA only reviews the adequacy of such materials in an enforcement proceeding. When a compliance officer inspects a facility, the adequacy and accuracy of material safety data sheets and other written materials is assessed. We do not provide prior review for anyone, or indicate in advance of an inspection whether such materials would meet the requirements of the rule in any particular facility.

letter: SSmith 09-13-88

Abbreviations, Label/MSDS (h)(3)-9

Access to Employee Exposure and Medical Records Standard (g)(11)-2

Acetaldehyde (d)(4)--4

Acetylene cylinders (g)(8)-3

Association of Governmental Industrial Hygienists (ACGIH) TLVs (d)(2)-9, (d)(3)-3, (d)(4)--8

Hazard determination (d)(3)-2

MSDS (d)(5)-6, (g)(2)-12, (g)(2)-15

Acrylonitrile Standard (f)(4)-3, (f)(4)-4


Food (b)(2)-3, (b)(5)-4, (c)-8, (d)(1)-6, (d)(3)-5

Gasoline (d)(5)-6, (g)(2)-10, (g)(2)-14

Wood (b)(6)-9

Adhesive tapes (c)-5

Adhesives (b)(2)-10

Aerosols (b)(2)-12, (b)(6)-21

Agriculture (b)-4

Air Contaminants Standard (d)(3)-6

Carcinogen labeling (f)(4)-3

Hazard determination (d)(3)-2

MSDS requirements (g)(2)-15

Transitional limits (d)(3)-4, (d)(3)-5


PELs & allergic response reactions (d)(3)-6

SSensitizer(s) (c)-25, (g)(2)-13

Alloy (g)-7, (g)(2)-1, (g)(2)-18

American National Standard Institute (ANSI) guidelines

Labeling (f)-3, (f)(1)-12, (f)(1)-14, (f)(5)-2, (f)(5)-10

MSDS (g)-3

Antifreeze (d)(5)-6, (d)(5)-7, (g)(2)-10, (g)(2)-11

Appendix A

Health hazards/target organs (c)-26

Approval (b)(6)-10

Approval (OSHA) I-5

Argon (b)(1)-1, (c)-24

Articles (b)(6)-10, (c)-2, (c)-3, (c)-7

Definition (c)-1, (b)(6)-12, (c)-2, (c)-4, (c)-6

Drill bits (b)(6)-12

Examples (c)-5

Exemption (b)(6)-10, (b)(6)-12

Normal use (c)-2, (c)-4, (c)-27, (e)(1)-2

Scrap (c)-7

Scrap dealers (c)-13, (g)(7)-4

Trace exposure (b)(2)-12, (b)(2)-14, (d)(1)-12, (f)(1)-10

Asbestos (b)(1)-9, (b)(6)-4, (e)(1)-6, (e)(1)-7, (e)(2)-7-8, (f)(4)-2, (g)(2)-15

Asphyxiants (b)(1)-1, (b)(2)-3, (c)-23, (d)(1)-3

Attapulgite Clay (d)(4)--2, (d)(4)--3, (d)(5)-2, (g)(2)-8, (g)(2)-9, B-1, B-2

Bales (c)-11, (f)(1)-2

Beauty salon industry (g)(7)-5, (g)(7)-17

Employer (c)-16

Multi-employer workplace (e)(2)-5

Biological Hazards (b)(6)-12, (b)(6)-17, (c)-6, (g)(5)-3

Bloodborne Pathogens Standard (b)(1)-3-4, (b)(6)-3

Brake shoes (b)(6)-10, (c)-3, (c)-4

Bricks (b)(2)-4, (b)(6)-10, (c)-3, (c)-5

Bulk packaging (f)(3)-1, (f)(9)-1

sBulk storage (d)(5)-6, (g)(2)-10

Bulk storage tanks (f)(6)-3

By-products (b)(2)-9, (b)(2)-10

Cadmium (b)(2)-1, (b)(2)-2, (d)(5)-9, (f)(4)-1

Calcium Silicate (f)(1)-10, (f)(5)-4

Carbide (c)-8, (f)(2)-2, (g)(2)-4

Carcinogens (d)(1)-9, (d)(2)-6-7, (d)(2)-9, (d)(3)-3, (d)(3)-7, (d)(4)-4-8, (d)(4)-12, (d)(4)-15, (d)(5)-8, (f)(1)-2, (f)(4)-1, (f)(5)-3

Diesel exhaust (d)(2)-8

Exposure calculation (f)(1)-4, (f)(1)-9, (f)(5)-3, (f)(5)-4

Hazard evaluations (d)(2)-2, (d)(2)-5, (d)(4)-2-3, (d)(4)-10, (d)(5)-1, (d)(5)-3, (d)(5)-11, (g)(2)-8, B-1, B-2

IARC (d)(2)-6, (d)(4)-4-7, (d)(4)-13-14, (f)(1)-6, (f)(1)-8, (f)(1)-17, (g)(2)-18

IARC Findings (d)(4)-9, (f)(4)-1, (f)(5)-3

Label notations (f)(1)-7, (f)(1)-10, (f)(4)-4, (f)(5)-4

Lubricating oils (d)(4)-13

MSDS Notations (d)(4)-11, (d)(5)-11, (g)(2)-17, (g)(5)-5

NTP (d)(4)-7, (f)(4)-2, (f)(5)-3

Wood dust (d)(1)-3

Cement (b)(2)-11, (c)-8, (g)(2)-14

Chemical manufacturer, definition (c)-9, (g)(1)-3

Chemical manufacturing industry (a)-5, (a)-6, (b)(1)-11, (b)(2)-12, (c)-25, (d)(1)-10, (d)(2)-5, (d)(3)-6, (d)(4)-7, (d)(5)-10, (f)-4, (f)-5, (f)(7)-1, (f)(5)-13, (g)-5, (g)(1)-3, (g)(2)-13, (g)(6)-6, (g)(7)-14-15

Chemical testing (d)(1)-4

Chemical, definition (c)-7, (d)(1)-6

Steel Coils/Carbide Blades (c)-8

Chemotherapeutic agents

See Drugs (g)(5)-3

China producers industry (d)(1)-9, (d)(5)-8

Chromium (c)-3, (d)(5)-11

Classified information (g)(6)-7

Cleaning chemicals (d)(1)-10

Commercial customers (c)-13, (g)(6)-6, (g)(7)-5, (g)(7)-11-12, (g)(7)-14-15, (g)(7)-17

Communication industry (d)(1)-11

Compressed gases (b)(1)-1, (b)(1)-6, (b)(2)-3, (c)-22, (c)-24, (d)(1)-2, (f)(7)-3, (g)(8)-3

Concrete (b)(2)-11, (e)(1)-2

see: Cement

Silica, Crystalline

Construction industry (b)(1)-10, (b)(6)-10, (c)-3, (c)-5, (c)-12, (e)(2)-5, (e)(2)-6, (e)(2)-12, (h)(1)-3, I-2

Common hazards (b)(2)-3, (d)(1)-2

Exposure records (g)(11)-2

hazard definition (b)(2)-13, (c)-22, (c)-25

MSDS (b)(1)-10

MSDS access (g)(8)-9

Multi-employer worksite (e)(2)-4, (e)(2)-6, (e)(2)-10, (g)(8)-4

Multiple worksite/written HCP/MSDS (e)(1)-8, (e)(2)-8, (g)(8)-10, (g)(8)-11, (g)(8)-12, (g)(10)-2

Training (h)(1)-2

Workplace/work area (c)-28

Consumer products

Application of the HCS (b)(6)-21, (b)(6)-22

Conditions of use (g)(6)-6, (g)(7)-11, (g)(7)-13, (g)(7)-14, (g)(7)-17, (g)(8)-7

Container, Definition (c)-12


Defense / classified information (g)(6)-7

Multi-employer worksite (e)(2)-2, (e)(2)-5-6, (e)(2)-8, (e)(2)-10-11, (g)(8)-4, (g)(8)-11

Training (h)-2, (h)(3)-4

Copper Chromated Arsenate (CCA) pressure-treated wood (f)-1

Copy Machines

Ozone (b)(2)-9, (e)(1)-4

Toner (b)(2)-4, (b)(2)-12, (d)(5)-11

Corrosive materials (c)-3, (c)-22, (c)-24, (d)(5)-6, (e)(1)-3

Court cases

15 BNA OSHC 1313, Docket No. 89-2253, 1991 (c)-28, (g)(8)-4

15 BNA OSHC 1353, Docket No. 90-1084, 1991 (g)(8)-3

ARA 15 BNA OSHC 1417, Docket No. 89-1894, 1991 (h)-4

Dole v United Steelworkers, No. 88-1434, 1990 (b)(6)-18

Durez v. OSHRC, 906 F.2d 1 (D.C. Cir. 1990) (d)(1)-10, (d)(5)-11

General Carbon Co. v. OSHRC, 860 F.2d 479 (D.C. Cir. 1979) (d)(1)-10

General Carbon v. OSHRC, Docket No. 860 F.2d 479, 1988 (b)(2)-14, (d)(1)-12, (f)(1)-11

Crude oil (g)(1)-6

Crushed stone (a)-5, (b)(2)-12, (e)(1)-6, (f)-3

Cutting Equipment (f)(2)-2, (g)(2)-4

De minimis releases (b)(2)-12, (b)(2)-14, (d)(1)-12, (f)(1)-10

Decomposition products (d)(1)-5, (d)(5)-5, (g)(2)-12

Demolition (b)(6)-11, (e)(1)-2, (e)(1)-6, (h)(3)-6

Dental laboratories (b)(3)-2, (b)(3)-4

Dental offices (b)(1)-12, (f)(5)-2, (g)(5)-2, (g)(6)-1-2, (g)(6)-4

Department of Defense (DOD) (g)(6)-7

Diesel fuel exhaust (b)(1)-11, (b)(2)-10, (d)(1)-5, (d)(2)-8, (f)-4, (g)(5)-6, (h)-6

Distributors (c)-12, (c)-13, (f)(1)-19, (g)(2)-22, (g)(7)-1, (g)(7)-4, (g)(7)-12, (g)(7)-14, (g)(8)-10, (g)(10)-1, (h)-4, (h)(3)-8

Commercial accounts (g)(7)-5, (g)(7)-11

Definition (c)-12

Material Safety Data Sheets (MSDS) (g)(7)-8, (g)(7)-9

MSDS / payment for MSDS (g)(6)-6, (g)(7)-16

MSDS, consumers (b)-3

Payment for MSDS (g)(7)-7

Repackaging/labels (f)(5)-7, (f)(6)-4

Downstream flow of information (a)-2, (g)(6)-2

Drill Bits (b)(6)-12

Drugs (b)(1)-5, (b)(2)-2, (b)(6)-16, (b)(6)-18, (b)(6)-19, (d)(1)-2, (g)(5)-3

Biological (b)(6)-17

Exempted (b)(5)-3, (b)(6)-14, (b)(6)-15, (b)(6)-17

FDA regulated I-1

Material Safety Data Sheets (MSDS) (b)-2, (g)-8, (g)(5)-3

Non-manufacturing sector I-2

Parenteral cytotoxic pharmaceuticals (b)(1)-2, (b)(6)-2

Radiological (b)(6)-17

Solid and final form (b)(6)-17, (b)(6)-19

Solid final form (b)(1)-4, (b)(6)-16

Drums (b)(6)-4, (c)-11, (f)(3)-1, (f)(6)-4, (f)(9)-1

Electrical manufacturing industry (b)(2)-11, (d)(1)-7

Emergency contact information (f)(1)-18, (g)(2)-22, (g)(2)-23


see: Diesel fuel exhaust


Hazardous by-products

Employee exposure records (g)(11)-1

Engine oils (d)(5)-6, (g)(2)-10

Environmental Protection Agency (EPA) (b)-4, (b)(1)-4, (b)(6)-4-7, (b)(6)-12, (c)-6, (g)-6

Exemption for hazardous waste (b)(6)-6

Registration number for pesticides (b)(5)-2

Epidemiological studies (d)(2)-3, (d)(2)-7, (d)(2)-8, (f)(1)-2

Epoxy (g)(11)-1

Ethanol (f)(1)-17

Ethylene Dibromide (d)(5)-7, (g)(2)-10

Ethylene Oxide Standard (29 CFR 1910.1047) (g)(2)-9

Evacuation procedures (b)(4)-3

Exemptions (b)(6)-10

Consumer products (b)(6)-22

Drugs (b)(5)-3, (b)(6)-14, (b)(6)-15

Hazardous waste (b)(6)-7

Sealed containers (b)(4)-2

Veterinary employers / products (b)(5)-3, (b)(6)-15

Wood products (b)(6)-8

Exposure calculations (b)(2)-11, (d)(5)-7, (f)(1)-9, (f)(5)-4, (g)(2)-11

Hazard Determination (b)(2)-14, (d)(1)-12, (f)(1)-4, (f)(1)-10, (f)(5)-3

Exposure levels (g)(2)-15

Exposure potential (b)(2)-10, (b)(2)-12, (b)(2)-13

Airborne (b)(2)-9

Silica (b)(2)-5

Farms (b)-4

Food and Drug Administration (FDA) (b)(1)-4, (b)(2)-2, (b)(5)-4, (b)(6)-16, (d)(1)-2, (d)(3)-5, (d)(4)-4, I-1

Federal Trade Commission I-5

Fertilizer (g)(4)-1

Fibrous glass (f)(1)-3, (f)(1)-15, (f)(1)-16

Glass textile fibers (b)(2)-7, (d)(2)-4

Glass wool (b)(2)-7, (d)(2)-3

Hazard determination (d)(2)-6, (d)(2)-7, (d)(4)-5, (f)(1)-2

Respirable items (d)(6)-1

Fire extinguishers (e)(2)-1, (f)(1)-1, (f)(5)-1, (f)(7)-3

Fire extinguishers, 49 CFR 173.306

Fire extinguishers (b)(1)-1

First Aid (h)(3)-8

Flammable liquids, definition (c)-18, (c)-19

Flammable Lubricants (b)(6)-21

Food and Drug Administration (b)(5)-4

Food colorant (b)(2)-3, (d)(3)-5

Food Industry

Exemption (b)(6)-13

Food products as chemicals (c)-8

Labeling requirements (b)(5)-4

Food products (b)(5)-4, (b)(6)-13, (c)-8

Hazard determination (d)(1)-6

Fuel products

Multi-employer worksite (e)(2)-3

Written HCP (e)(1)-3, (e)(2)-3

Fuels (b)-5

Funeral homes (f)(5)-2

Gas calibration bottles (c)-2

Gasoline (b)-5, (b)(2)-10, (c)-12, (d)(5)-6, (g)(2)-10

Grain dust, hazards (b)(1)-13

Hardware industry

Distribution/MSDS (d)(1)-8, (g)(7)-12, (g)(8)-9, (g)(10)-1

Hazard information/downstream use (g)(1)-6

Non-employer/employee situations (b)-3

Retail distributors (g)(7)-6, (g)(7)-12, (g)(7)-13

Hazard Communication Compliance Kit I-4

Hazard communication program (e)(1)-2

Hazard determination (d)(1)-3, (d)(2)-3, (g)(2)-5

Attapulgite Clay (d)(4)-2, (d)(4)-3, (d)(5)-1, (d)(5)-2

Carcinogens (d)(4)-3, (d)(4)-10, (d)(5)-3

Coatings on automobile parts (d)(1)-1, (d)(3)-1, (d)(4)-1

Crystalline Silica (d)-1

Drugs (d)(2)-1

Exposure calculations (b)(2)-11

Exposure calculations: carcinogen concentrations at 0.1% (f)(1)-9, (f)(5)-4

Exposure calculations: carcinogen warning (f)(1)-4, (f)(5)-3

Exposure route (c)-17

Floor / metals (c)-23, (d)(3)-4, (d)(4)-11

Floor of hazardous chemicals (d)(2)-7, (d)(3)-2, (d)(4)-10

Hazardous paints (d)-1

IARC findings (d)(4)-6

In vitro studies (d)(2)-5

Mixtures (d)(1)-9, (d)(2)-2, (d)(5)-3, (d)(5)-6-8, (d)(5)-10, B-1

Negative findings (d)(2)-10, (d)(3)-3, (d)(4)-8

One study criterion (d)(2)-9, (d)(3)-2, (d)(3)-3, (d)(4)-7, (d)(4)-8, (d)(4)-9, (d)(4)-11

PELs (d)(3)-4, (d)(5)-11

Potential exposure (d)(1)-4

Recognized sources (d)(3)-2

Suspected mutagens (d)(2)-2, (d)(5)-3

Hazard Warnings (f)(1)-15-17, (f)(5)-13

Labels (a)(2)-1

Hazardous by-products

covered by HCS (d)(1)-5

Hazardous chemical inventory (e)(1)-8

Hazardous chemical, definition (c)-22

Metals (d)(3)-4, (d)(4)-11

Hazardous waste (b)(6)-3, (b)(6)-5, (b)(6)-6, (b)(6)-7

Cytotoxic waste (b)(1)-2, (b)(6)-2

Exemption (b)(6)-7

Incineration (b)(6)-12, (c)-6

TSD facilities (b)-5

Health care employers (a)-4

Health care products (c)-14, (g)(7)-15

Health hazard, definition (a)-7, (c)-22-3

Helium (b)(1)-1, (c)-24

Help supply services industry

Application of the HCS (b)-2

HMIS system (f)(5)-2, (f)(5)-10, (f)(5)-12

Hospital industry (h)(3)-4

Humidification systems

No specific PELs (b)(2)-6

Heating, Ventilation and Air Conditioning (HVAC) industry (a)-5, (e)(2)-5, (e)(2)-11, (e)(2)-12, (g)(8)-8, (h)-5

Hydraulic fluid (d)(5)-6, (g)(2)-10

Importer (d)(1)-7, (f)(1)-9

In Vitro studies

Hazard determination (d)(2)-5

Incidental exposure (b)(2)-6, (b)(2)-8

Ventilation systems (b)(2)-6

Incineration (b)(6)-12, (c)-6

Indoor air pollution (b)(2)-7

Industrial thermometers (c)-28

Inert gases (b)(1)-1, (b)(2)-3, (c)-23, (c)-24, (d)(1)-2

Insulation industry (d)(1)-6, (f)(1)-9

Internationl Agency for Research on Cancer (IARC) (b)(2)-4, (d)(4)-4, (d)(4)-6-7, (d)(4)-9, (d)(4)-12, (d)(4)-14, (f)(1)-6

Hazard Determination (d)(2)-9, (d)(3)-3, (d)(4)-2-3, (d)(4)-8, (d)(4)-10, (d)(4)-14-15, (d)(5)-1, (f)(1)-6

Label/MSDS requirements (d)(4)-14, (f)(1)-6, (f)(1)-7, (f)(1)-17, (f)(4)-1, (f)(5)-3, (g)(2)-4, (g)(2)-8, (g)(2)-16, B-1

Inventory of chemicals (e)(1)-9

Iron oxide (b)(2)-3, (d)(3)-5

Isolated exposures (b)(2)-4

Janitorial services industry (b)(1)-7, (h)(3)-1

Jurisdiction (b)-4

Kerosene (d)(5)-6, (g)(2)-10

Labeling Requirements

Cadmium containing compounds (f)(4)-1

Container only (f)(5)-2

Containers leaving the workplace (f)(1)-17, (f)(5)-13

Copper Chromated Arsenate (CCA) pressure-treated wood (f)-1

Fire extinguishers (f)(1)-1, (f)(5)-1

Hazard warnings (g)(2)-14

In-plant labeling (f)(1)-17, (f)(5)-13, (f)(6)-2

In-plant labeling Systems (c)-11, (f)(1)-1, (f)(5)-2, (f)(5)-5, (f)(5)-8, (f)(5)10-11, (f)(6)-1-2, (h)(3)-9

Mixtures (f)(4)-1

MSDS hazard warning language (f)(1)-13, (f)(5)-9

Placement/visibility (f)-5

Responsible party (f)(1)-18, (g)(2)-22

Retention (f)(7)-3

Shipped containers (f)(1)-11, (f)(5)-6

Stationary process/bulk storage containers (f)(6)-3

Target organ effects (f)(1)-12, (f)(1)-14

Treated wood products (f)(2)-1

Laboratory (b)(3)-2

Laboratory Standard (b)(3)-2

Production process exclusion (b)(3)-2

Lead (g)(2)-14

Leaks (b)(4)-3

Long term health care facilities

see nursing homes (b)(1)-5, (b)(6)-18

Lubricants (d)(5)-6, (g)(2)-10

Lubricating oils (d)(4)-12


By-products (b)(2)-9

Man-made mineral fiber (d)(2)-7, (f)(1)-2

Material Safety Data Sheets (MSDS)

Access (e.g., Electronic) (g)(8)-1

Accessibility (b)(4)-1, (g)(8)-2

Asbestos removal operations (g)(1)-5

Carcinogens (g)(2)-8

CD ROM (e)(1)-1, (g)(1)-1

Distributors (g)(7)-8, (g)(7)-9

Downstream flow (g)(6)-2

Emergency contact / responsible party (g)(2)-18

Generic (e)(1)-1, (g)(1)-1

Hazardous paints (g)-1

Maintenance (g)(1)-2, (g)(2)-7, (g)(2)-19, (g)(5)-1, (g)(7)-9, (g)(8)-1, (g)(8)-2, (h)(3)-8

Mobile worksites / traveling between workplaces (e)(5)-1, (g)(9)-1

Product specific (e)(1)-1, (g)(1)-1

Purpose (a)-1

Retail (g)(7)-8, (g)(7)-9-10, (h)-1

Retail pharmacy (g)(6)-8

Transmission (g)(6)-1, (g)(6)-2, (g)(6)-3, (g)(7)-10

Wood products (g)(7)-9

Medical industry

Consumer products/frequency/duration of use (a)(2)-1

Drug exemption (b)(6)-20

Drugs/frequency of exposure (b)(1)-6, (b)(6)-20

Laboratories (b)(3)-2

Liquid drugs (b)(1)-6, (b)(6)-19

MSDSs for drugs (g)-8

Package insert/generic MSDS (g)-8

Pharmaceutical/labeling (b)(5)-5

Physicians (b)-1

Medical surveillance (h)-3

Metals (d)(1)-1, (d)(3)-1, (d)(4)-1, (g)(2)-1, (g)(2)-18

Methylene Chloride (g)(2)-15

Mine Safety and Health Administration (c)-3, (g)-5

Mineral fibers

Rock wool (d)(2)-3


Components with similar hazards (g)(4)-1

Carcinogens (d)(5)-7

Definition (c)-8

Hazard determination (d)(2)-2, (d)(4)-2, (d)(5)-1, (d)(5)-3, (d)(5)-5-7, (d)(5)-9-10, (g)(2)-8, B-1

Labeling requirements (f)(4)-1

MSDS, mixtures not tested as a whole (g)(2)-13

Multi-employer worksites (b)(1)-10, (e)(2)-3, (e)(2)-5-6, (e)(2)-9, (g)(8)-13, I-2

training (h)-5, (h)(3)-4

Mutagenicity (d)(2)-5

N-Nitroso compounds (b)(2)-6

National Fire Protection Association (NFPA) (f)(5)-2, (f)(5)-10

National Cancer Institute (g)(5)-3

Nickel (c)-18

NIOSH (b)(2)-4, (b)(2)-10, (c)-3, (d)(4)-10, (e)(4)-1, (g)(5)-6

Hazard determination (d)(2)-8

RELs (d)(3)-2, (g)(2)-15

Nitrogen (b)(1)-1, (c)-24

Nitrosated compounds (b)(2)-6

Non-occupational uses (g)(6)-5

Normal conditions of use (b)(1)-8, (b)(2)-10, (b)(2)-11


Carcinogens (f)(4)-1, (f)(5)-3

Hazard determination (d)(2)-9, (d)(3)-3, (d)(4)-4, (d)(4)-6-8, (d)(4)-10

Label requirements (f)(1)-7

MSDS requirements (g)(2)-4

NTP Findings

MSDS Requirements (g)(2)-17

Nursing Homes (b)(1)-5, (b)(6)-18, (c)-13, (g)(7)-15

Office of Management and Budget I-1, I-2

Oil & gas

MSDS (g)(4)-1

Oil & gas producers (c)-9

OSH Act of 1970 (b)-3, (c)-15, (d)(3)-2, (d)(5)-11

Definition, Employee (e)(2)-5

OSHA Form 174 (g)(2)-1, (g)(2)-18

MSDS (g)(2)-4

OSHA jurisdiction (b)-3

Outside shipping containers (f)(3)-1, (f)(9)-1

Overwarning (a)(2)-1

Oxide Fume (d)(1)-1, (d)(3)-1, (d)(4)-1

Oxygen cylinders

"readily accessible" (g)(8)-3

compressed gas (b)(1)-6

Ozone (b)(2)-9, (e)(1)-3

Paperwork Reduction Act I-1, I-2

PCB-contaminated waste (b)(6)-4

Performance-oriented standard (flexibility in compliance) (e)(1)-9, (f)(1)-14

Material Safety Data Sheets (MSDS) (a)-1

Permissible Exposure Limits (PELs) (b)(6)-9, (d)-1, (d)(3)-4, (d)(3)-6, (d)(3)-10, (d)(4)-7, (d)(5)-6, (d)(5)-11, (g)(2)-12, (g)(2)-16

Crystalline Silica (d)-1

Dust particulate (d)(3)-10

Hazard determination (d)(3)-6

Iron Oxide (b)(2)-2, (d)(3)-5

Wood dust (b)(6)-9

Personal Protective Equipment (PPE) (h)-2

Pesticides (b)-4, (b)(5)-2

labeling (b)(5)-2

responsibility of distributors (g)(7)-14

Physical hazard, definition (c)-22

Physical hazards (b)(2)-3, (d)(1)-2

Propane (d)(5)-6, (g)(2)-10

Purpose/intent (a)-5, (a)-7, (b)-3

Radiological hazards (b)-4, (b)(6)-17


1910.20 (e)(4)-1, (g)(11)-2

HCP (e)(4)-1

Lead Standard (d)(1)-11

MSDS (g)(11)-2-3

Training (h)(1)-3

Repackaging chemicals (g)(7)-6

Request for comments and information

MSDS (g)-7

Resource Conservation and Recovery Act (RCRA) (b)-5, (b)(6)-6, (b)(6)-7

Hazardous waste (b)(6)-3, (b)(6)-6

Respirator cartridges (c)-3

Responsible party (g)(2)-20, (h)(3)-5

Emergency Contact (g)(2)-18

Retail distributors (g)(6)-6, (g)(7)-8-9, (g)(7)-16, (g)(7)-17

Rock wool (d)(2)-3

Scope (b)-3, (b)(1)-7

Scrap dealers industry (c)-7, (g)(1)-8, (g)(2)-2, (g)(7)-4

Distributors (g)(7)-3

Metals (b)(6)-7

MSDS (g)(1)-4, (g)(5)-6

Sealed container exemption (b)(4)-2

Sensors (c)-2, (e)(1)-2

Shipbuilding (b)(2)-15

Shipped Containers

Labeling Requirements (f)(1)-11, (f)(5)-6


Containerized shipping industry (b)(4)-2

Silica Sand (d)(1)-3

Construction Industry (b)(1)-11

definition of "health hazard" (c)-22, (c)-25

Silica, Amorphous (d)(4)-12

Silica, Crystalline (b)(2)-4, (b)(2)-5, (d)-1, (d)(5)-2, (g)(2)-8, (g)(2)-9, B-1, B-2

Available for exposure (d)(1)-9, (d)(5)-8, (d)(5)-9, (f)-2, (g)(2)-11

Bound in elastomers (b)(2)-9

Definition, article (c)-4

Hazard determination (d)-1, (d)(4)-9, (d)(5)-9

Hazards (d)(1)-3

Respirable dust (b)(2)-5, (b)(6)-10, (c)-3, (c)-18, (d)-1, (d)(1)-3, (d)(5)-4, (f)-2

Silicone rubber elastomers (d)(5)-9

Slag wool (f)(1)-1

Sodium hypochlorite (d)(2)-5

Spills (b)(4)-3

State OSH Programs (a)(2)-1

State program

MSDS format alternatives (g)(10)-2

Responsibility for MSDS change (g)(2)-21, (g)(5)-5

Stationary process containers (f)(5)-5, (f)(5)-6, (f)(6)-3, (f)(7)-2

Steam humidification systems

Office workers exposed to trace amounts of chemicals (b)(2)-6, (b)(2)-8

Volatile amines (b)(2)-6

Steel (d)(1)-1, (d)(3)-1, (d)(4)-1

Stevedores (b)(4)-2

Stretch wrapping (c)-11

Substance specific hazard assessments (b)(2)-7, (d)(2)-4, (g)-7

Substance specific standards (a)-7, (f)(4)-1, (f)(4)-2, (f)(4)-4, (f)(5)-3, (g)(2)-15

Tank trailers

Cleaning (e)(2)-9

Labeling (f)(1)-5, (f)(3)-3

Target organ effects (e)(1)-5, (f)(1)-14, (f)(1)-15, (h)(3)-6

Hazard warnings; DOT labels (f)(3)-3

Health hazard (c)-25

HMIS system (f)(5)-12

In-plant labelling (f)(5)-10, (f)(5)-12

Shipped containers (f)(1)-11-12, (f)(5)-6

Target organs, Definition (c)-26

Textile industry (b)(2)-8, (d)(2)-4, (f)(4)-4, (g)(2)-18

Tire (b)(6)-10, (c)-3, (g)(1)-4

Toluene Diisocyanate (g)(2)-10

Trade names (e)(1)-9

Trade secrets (g)(2)-13

MSDS / PELs / TLVs (g)(2)-6, I-i

Trailers (with cargo) (b)(4)-2

Training (b)(4)-3, (h)(1)-3

Evacuation Procedures (b)(4)-3

Generic (h)(3)-4

Labeling system (e)(1)-5, (h)(3)-6

Material Safety Data Sheets (MSDS) (h)(3)-8

MSDS/Labels (h)(3)-9

Multi-employer worksites (h)-5

Previous (h)(3)-5

Retail (g)(7)-9, (h)-1

Temporary employees (h)-2

Training Aides

Audiovisuals (e)(4)-2

Transfer of hazardous chemicals (f)(5)-4, (f)(6)-3, (f)(7)-1

Travelling between worksites (b)(1)-7

Trucks (b)-5

Work Area (b)(1)-11, (f)-4, (h)-6

TSCA (Toxic Substances Control Act) (b)(6)-4

TSDs (b)(6)-5, (b)(6)-6

Tuberculocidal Disinfectants (b)(1)-4

Use, definition (c)-26-7

Voluntary consensus standard (g)-4

Wallboard (d)(5)-4, (f)-2

Waste Oil (g)(2)-5

Welding operations (b)(2)-3, (b)(2)-9, (b)(2)-14, (c)-8, (d)(1)-2, (e)(1)-4, (e)(2)-10, (g)(8)-4

Wood dust (d)(1)-3

Wood products (b)(6)-8

Copper Chromated Arsenate (CCA) pressure-treated wood (b)(1)-3

Exemption (b)(6)-8

Material Safety Data Sheets (MSDS) (g)(7)-9

Treated wood products (f)(2)-1

Work Place/ Work Area, definition (b)(1)-11, (f)-4, (h)-6

Written Hazard Communication Program (e)(1)-6, (e)(2)-1

Copies (e)(4)-2

Employee/management interviews (h)-5

Employer's responsibility (e)(1)-3, (e)(2)-3

Laboratories (b)(3)-4

Multi-employer worksite (e)(2)-2

Pocket-size copies (e)(4)-1

Supplemental hazard warnings (f)(1)-11, (f)(5)-5

Zinc (d)(1)-1, (d)(3)-1, (d)(4)-1

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