Hazard Communication: Labels, Safety Data Sheets, and Training

Workers cannot guard against chemical hazards they do not know about. The Hazard Communication standard requires all employers to give employees information about the hazardous chemicals they are exposed to, by means of a hazard communication program, labels and other forms of warning, safety data sheets (SDSs), and information and training (1910.1200(b)(1)). This guide covers employers whose workers use chemicals.

Who it applies to

The standard applies to any chemical known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency (1910.1200(b)(2)). For construction work, the requirements are identical to those in 1910.1200 (1926.59).

Chemical manufacturers and importers classify the hazards. You are not required to, unless you choose not to rely on their classification (1910.1200(d)(1)).

Where employees only handle chemicals in sealed containers that are not opened under normal conditions of use (such as warehousing or retail sales), the standard applies only in part. You must ensure incoming labels are not removed or defaced, keep the SDSs you receive readily accessible, obtain a missing SDS as soon as possible if an employee requests it, and train employees to the extent necessary to protect them from a spill or leak (1910.1200(b)(4)).

The standard does not apply to the items listed in 1910.1200(b)(6), including:

• Articles. Manufactured items, other than fluids or particles, that meet all three parts of the definition in paragraph (c): the item is formed to a specific shape or design during manufacture; its end use function depends in whole or in part on that shape or design; and under normal conditions of use it does not release more than very small quantities (minute or trace amounts) of a hazardous chemical and does not pose a physical hazard or health risk to employees (1910.1200(b)(6)(v); 1910.1200(c)).
• Consumer products. A consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act and the Federal Hazardous Substances Act, but only where you can show it is used in the workplace for the purpose the manufacturer or importer intended, with a duration and frequency of exposure not greater than the range consumers could reasonably experience when using it for that purpose (1910.1200(b)(6)(ix)).

What the standard requires

Labels on containers you receive

The manufacturer, importer, or distributor must ensure each container of hazardous chemicals leaving its workplace is labeled, tagged, or marked. Expect a product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name, U.S. address, and U.S. telephone number of the manufacturer, importer, or other responsible party (1910.1200(f)(1)).

You must not remove or deface existing labels on incoming containers unless the container is immediately marked with the required information (1910.1200(f)(9)).

Labels in your workplace

You must ensure that each container of hazardous chemicals in the workplace is labeled, tagged, or marked with either:

• The shipped container label information in (f)(1)(i) through (v) (1910.1200(f)(6)(i)); or
• The product identifier and words, pictures, symbols, or a combination, that give at least general information on the hazards and that, with the other information immediately available to employees under your program, give them the specific information on the physical and health hazards (1910.1200(f)(6)(ii)).

Exceptions:

• Stationary process containers. You may use signs, placards, batch tickets, operating procedures, or similar written materials instead of labels, as long as the method identifies the containers it applies to, conveys the required label information, and is readily accessible to employees in their work area throughout each work shift (1910.1200(f)(7)).
• Portable containers. You are not required to label portable containers into which hazardous chemicals are transferred from labeled containers and which are intended only for the immediate use of the employee who performs the transfer (1910.1200(f)(8)). "Immediate use" means the chemical will be under the control of and used only by the person who transfers it, and only within the work shift in which it is transferred (1910.1200(c)).

Safety data sheets

You must have an SDS in the workplace for each hazardous chemical you use (1910.1200(g)(1)). You must ensure the copies are readily accessible during each work shift to employees when they are in their work areas. Electronic access and other alternatives to paper copies are permitted as long as they create no barriers to immediate employee access in each workplace (1910.1200(g)(8)).

Training

You must 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 chemical hazard the employees have not previously been trained about is introduced into their work area (1910.1200(h)(1)).

Employees must be informed of the standard's requirements, any operations in their work area where hazardous chemicals are present, and the location and availability of the written program, chemical list, and SDSs (1910.1200(h)(2)).

Training must include at least (1910.1200(h)(3)):

• Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area
• The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area
• The measures employees can take to protect themselves, including the specific procedures you have implemented
• The details of your program, including an explanation of the labels received on shipped containers and your workplace labeling system, and the SDS, including the order of information and how employees can obtain and use the appropriate hazard information

Written programs and records

You must develop, implement, and maintain a written hazard communication program at each workplace. It must at least describe how you will meet the label, SDS, and training requirements, and include (1910.1200(e)(1)):

• A list of the hazardous chemicals known to be present, using a product identifier that is referenced on the appropriate SDS (1910.1200(e)(1)(i)).
• The methods you will use to inform employees of the hazards of non-routine tasks and of chemicals in unlabeled pipes in their work areas (1910.1200(e)(1)(ii)).

If you produce, use, or store hazardous chemicals in a way that may expose another employer's employees (for example, a contractor working on-site), the program must also include the methods you will use to give that employer on-site access to SDSs, and to inform it of needed precautionary measures and of your labeling system (1910.1200(e)(2)).

You must make the written program available, upon request, to employees, their designated representatives, the Assistant Secretary (OSHA), and the Director (NIOSH) (1910.1200(e)(4)).

Easy-to-miss requirements

• Unlabeled pipes. Pipes and piping systems are not "containers" under the standard (1910.1200(c)), but your written program must still address the hazards of chemicals in unlabeled pipes (1910.1200(e)(1)(ii)).
• Traveling crews. Where employees travel between workplaces during a workshift, SDSs may be kept at the primary workplace facility, but you must ensure employees can immediately obtain the required information in an emergency (1910.1200(g)(9)).
• Missing SDSs. If an SDS is not provided with a shipment that has been labeled as a hazardous chemical, you must obtain one from the manufacturer or importer as soon as possible (1910.1200(g)(6)(iii)).

Related guides

• Respiratory protection
• PPE hazard assessment

Source

This guide is based on the text of 29 CFR 1910.1200 as published on osha.gov. The regulation itself always controls. States that run their own OSHA-approved State Plans may have additional or stricter rules.