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Regulated Materials and Written Program

The OSHA Hazard Communication Standard regulates all chemical substances that present a physical or health hazard.  Substances that meet these criteria are defined in OSHA Appendix I and have been defined as hazardous substances by OSHA.

Client is responsible for addressing hazard communications to non-English speaking personnel.

All chemical substances used at client facilities, as defined in OSHA Appendix I, are subject to this policy.  This program does not apply to chemicals subject to the Consumer Product Safety Act, wood products, foods, or tobacco products.  It states that a consumer product which is hazardous and used in the same manner as normal consumer use and which results in a duration and frequency of exposure which is not greater than exposures experienced by consumers is not subject to the requirements of the hazard communication standard - including MSDSs.  The stipulation MMI has placed on consumer products is that they should not normally be stored in quantities exceeding 5 - 10 gallons or significantly more than a consumer would normally store in a home or garage.

Each client location must have a written Hazard Communication Program.  This program will satisfy the written requirements as long as the provisions set forth below are followed and are available upon request of a compliance officer.  The Client’s Safety Representative is responsible for coordinating this program. Where employees must travel between work places during a work shift, the client’s written program must be kept at a primary job site.

Material Safety Data Sheets (MSDS)

Each client location shall maintain a current MSDS for each substance covered by the Hazard Communication Standard that is used at that specific location.  Purchased products should not be accepted unless a MSDS accompanies the delivery.  Each location must send a MSDS for substances used on that specific facility to the Safety Representative to be included in the master list.  A chemical inventory shall be maintained at each office for chemicals used within their specific areas.  This inventory should be updated every 6 months.  If a chemical is no longer in use the MSDS should not be thrown away.  MSDSs are considered exposure records and must be maintained on file for 30 years.  This file should be retained in the Home Office.

Labeling

Container labels should contain the following information:  Identity of hazardous chemicals, appropriate hazard warnings, and name and address of the chemical manufacturer, importer or other responsible party.  Labels should not be remove or defaced.

Chemical Container Labeling - Containers Received

All chemical containers received from vendors must be labeled and must be delivered with a Material Safety Data Sheet.  Labels shall include:

 Secondary Container Labeling

All bulk chemical-dispensing units should be labeled with the vendor’s label that informs the user as to above.

A labeling system has been developed for secondary containers.  This labeling system will satisfy requirements and conform to the following:

1. Labeling shall be consistent throughout each facility.

2. Labels must be linked to the MSDS available for that substance.  The chemical name identified on the container must match the name on the MSDS

Process Piping and Vessel Labeling

All process piping and vessel that contain substances regulated by the standard shall be labeled.  It is not mandatory that the process vessels be labeled as long as the products they contain are identified via the alternative labeling provision of the OSHA standard.

Labels or signs identifying the substance must appear as stated on the MSDS or correspond to a consistent numbering system that correlated to a central sign that specifies what the numbers mean.  The chemical names on the central sign must appear as stated on the MSDS as well.

Information and Training

Personnel who may be exposed to hazardous chemicals in the course of their routine responsibilities or in a foreseeable emergency, shall be provided with information and training about these potential hazards.  Such information and training shall be provided at the time of initial assignment, annually thereafter, and whenever a new hazard is introduced to the employee’s work area.

Training shall include:

Non-Routine Tasks

Employees must be informed as to the chemical hazards of non-routine tasks and the hazards associated with chemicals in unlabeled pipes in their work areas.  The primary methods to be used will include:

1. Pre-job (job planning) meetings

2. Scheduled safety meetings

3. Tail-gate safety meetings

4. Preparation and availability of procedures

5. Safety bulletins or posting of specific information

6. Required annual training sessions

Health Hazard Definitions: 

Sanitizers: A substance that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the substance.

Irritant: A substance, which is not corrosive, but which causes a reversible inflammatory effect on living tissue by chemical action at the site of contact.

Corrosives: A substance that causes visible destruction of, or irreversible alterations in, living tissue chemical action at the site of contact.  This term shall not refer to action on inanimate surfaces.

Carcinogens: A substance or agent producing or inciting cancer.

Toxics: A substance that has been proven to be lethal to laboratory animals when administered in nominal, predetermined doses.

Highly toxic: A substance that is up to 10 times more deadly to laboratory animals than a Toxic material when administered in predetermined doses.

Label Examples

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