Other states have adopted non-government-funded safety and health programs that cover their state or specific counties, cities, or towns, or towns, so just because your state isn`t on the list above doesn`t mean OSHA regulations (or their equivalents) aren`t in place! In addition, state or local “right to know” laws may (or may not) contain specific requirements for hazard communication (e.g., SDSs). And of course, Title III of SARA also covers SDSs. In practice, this means that an employer must teach its employees in a language and vocabulary that employees can understand. For example, if an employee does not speak or understand English, lessons must be given in a language that the employee can understand. If the employee`s vocabulary is limited, the training must take this limitation into account. If employees cannot read or write, it is not enough to ask the employer to read the training material. In general, employers are expected to recognize that while they usually need to provide work instructions or other workplace information to workers at a certain level of vocabulary or in a language other than English, they must also provide workers with safety and health training in the same manner. Of course, employers can also instruct non-English speaking employees on how to learn the English language. Over time, this may lead to training on the Occupational Health and Safety Act in other languages. OSHA notes that the GHS itself is not a regulation or standard. The GHS standard specifies agreed provisions for hazard classification and communication with explanatory information on the application of the system.
The GHS elements provide a procedure for meeting the basic requirements of any hazard communication system, which consists of deciding whether the chemical manufactured and/or supplied is hazardous and, if so, establishing a label and/or safety data sheet. Prior to the establishment of the GHS, there were several country-specific chemical hazard documentation systems. Some worked well, some didn`t. Only a few were compatible with each other. This led to great confusion about the actual dangers of a particular chemical and how the material could be handled, used and disposed of safely. The GHS approach and its single, standardized SDS format aim to address these issues. Here, too, paperless compliance only works if employees have “easy access.” If your database is accessible to the required employees on your company`s intranet, you`re probably fine. This assumes that you have a written contingency plan in place to access SDS information in the event of a power outage or other emergency. Such a plan may include keeping copies or using a battery-powered laptop. For online SDS subscriptions, OSHA allows you to use a phone as a backup system (but not as the primary system) instead of requiring printed copies. Organizations that follow these five steps are well positioned to ensure safe work environments and comply with federal requirements.
You can consult our commented list of SDS suppliers as well as our commented list of SDS software. The companies listed there pay a small fee to be listed, which helps us bring you this free SDS security information portal. However, because this chain of information transfer by the distributor can sometimes be broken, OSHA has added a requirement that manufacturers provide a copy of the safety data sheet to other “downstream” employers upon request. Your “FAX-on-demand” system can be used to meet this requirement. Further explanation of the requirements for the provision of safety data sheets can be found in the revised wording of paragraphs (g) 6) and g) 7) of the Standard. Sections 1 to 8 provide general information on the chemical, hazard identification, composition, safe handling, and emergency control measures (e.g., firefighting). This information should be useful to those who need to get the information quickly. Sections 9 to 11 and 16 contain other technical and scientific information, such as information on physical and chemical properties, stability and reactivity, toxicological information, exposure control information and other information, including the date of manufacture or last revision.
The SDS must also indicate that no applicable information has been found if the creator does not find information relevant to a required item. To make sure your suppliers meet OSHA requirements, it can`t hurt to add the following type of declaration to your orders: In summary, an SDS is required in almost all cases, unless there is essentially no possibility that the amount of material could cause damage. For more information, see this 1993 OSHA interpretation as well as this 2005 interpretation entitled “Requirement to Disclose All Chemicals Scientifically Proven to Pose a Health Risk, Regardless of Concentrations in the Product on the Safety Data Sheet.” “The HCS deals with chemical hazards that are inherent properties of the hazardous chemical and that would be present in any amount in the workplace. The risk depends on the inherent hazard and the level of exposure. A substance is a hazardous or non-hazardous chemical; The definition of HCS cannot be interpreted to mean that a substance could be a hazardous chemical at certain concentrations but not at others. For more information, see this OSHA interpretation letter, Application of the Hazard Communication Standard to the Art Materials Industry. The revised Hazard Communication Standard (HCS) 2012 (29 CFR 1910.1200(g)) requires the manufacturer, distributor or importer of the chemical to disclose safety data sheets (SDSs) (formerly safety data sheets or safety data sheets) for each hazardous chemical to downstream users in order to communicate information about those hazards. The information contained in the SDS is largely the same as that in the SDS, except that the SDS must now be presented in a consistent and user-friendly format with 16 sections.
This brief description contains instructions to help workers handling hazardous chemicals become familiar with the format and understand the contents of safety data sheets. The big question is what to do if the manufacturer has gone out of business or merged. This situation will be addressed in the next question. No. OSHA Hazard Communication Standard 1910.1200 contains the minimum elements required for an employee education and training program. While SDSs are a necessary part of these requirements, it is not enough to provide or distribute them to employees. According to an OSHA interpretation letter dated October 24, 2005, “hazardous energy control (LOTO) and hazard communication standards training programs are not met by simply providing written documentation to employees,” OSHA hazard communication standard 29 CFR 1910.1200 requires a “downstream flow of information.” For example, the original manufacturer or importer, Employer A, must create an SDS for each hazardous chemical it produces. If they send it to a professional customer or distributor, Employer B, they must send the SDS to Employer B. If Employer B then supplies the chemical to another company, Employer C, it is the responsibility of Employer B to forward the SDS “downstream” to Employer C.
In other words, information flows: employers. See Who should I give an SDS to and what is Downstream Flow? above. See also Why I don`t always get SDS when I order chemicals. Consumers: As mentioned above, many manufacturers or distributors are happy to give an SDS to anyone who requests it, but they are not obligated to distribute it to consumers. See this OSHA interpretation letter and downstream flow entry above for more information on how to distribute SDSs. OSHA has a practical guide for verifying the completeness of SDSs in Appendix H of CPL 02-02-079. The comprehensive directive also contains much other useful information for chemical hygiene agents. Chemical safety training should go beyond what is defined in the SDS. Appropriate training describes the hazards associated with chemicals in the work area, what can be done to minimize the risk of a spill response, and how this work relates to the hazard communication standard as a whole. Employees should have the opportunity to ask clarifying questions and even work with the chemical under supervision. For www.osha.gov/dsg/hazcom/hazcom-faq.html, OSHA estimates the total cost of compliance with the revised HCS 2012 compared to the previous version as follows: Yes. Safety data sheets must be specific to the manufacturer and include contact information for the “responsible party”.
In accordance with paragraph G.1.l of Directive No. 02-02-079.CPL safety data sheets must be specific to the product and the manufacturer. Theoretically, you could get away with a sheet for the chemical if certain conditions are met. See OSHA`s interpretation of the Hazard Communication Standard and Material Safety Data Sheets. The main points are: The most popular types of electronic formats today are Internet providers (which usually operate on a subscription basis) and “in-house” solutions, where companies digitize their SDS into a database instead of using a paper filing system. Other versions that fall by the wayside in the Internet age are CD-ROM subscriptions (renewable quarterly or annually) and fax-on-demand services (which fax you a copy as soon as you request one).