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CPL 2-2.38D - Appendix D

Guide for Reviewing MSDS Completeness

NOTE: This guide has been developed for use as an optional aid during inspections.

During CSHO review for Material Safety Data Sheet completeness, the following questions may be helpful:

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1. Do chemical manufacturers and importers have an MSDSfor each hazardous chemical produced or imported into the United States?

2. Do employers have an MSDS for each hazardous chemical used?

3. Is each MSDS in at least English?

4. Does each MSDS contain at least the:
   1. Identity used on the label?

   2. Chemical and common name(s) for single substance hazardous chemicals?

   3. For mixtures tested as a whole:
      • Chemical and common name(s) of the ingredients which contribute to the known hazards?

      • Common name(s) of the mixture itself?

   4. For mixtures not tested as a whole:
      • Chemical and common name(s) of all ingredients which are health hazards (1 percent concentration or greater), including carcinogens (0.1 percent concentration or greater)?

      • Chemical and common name(s) of all ingredients which are health hazards and present a risk to employees, even though they are present in the mixture in concentration of less than 1 percent or 0.1 percent for carcinogens?

   5. Chemical and common name(s) of all ingredients which have been determined to present a physical hazard when present in the mixture?

   6. Physical and chemical characteristics of the hazardous chemical (vapor pressure, flash point, etc.)?

   7. Physical hazards of the hazardous chemical including the potential for fire, explosion, and reactivity?

   8. Health hazards of the hazardous chemical (including signs and symptoms and medical conditions aggravated)?

   9. Primary routes of entry?

   10. OSHA permissible exposure limit (PEL)? The American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV)? Other exposure limit(s) (including ceiling and other short term limits)?

   11. Information on carcinogen listings (reference OSHA regulated carcinogens, those indicated in the National Toxicology Program (NTP) Annual Report on Carcinogens and/or those listed by the International Agency for Research on Carcinogens (IARC))?
       
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       NOTE: Negative conclusions regarding carcinogenicity, or the fact that there is no information, do not have to be reported unless there is a specific space or blank for carcinogenicity on the form.

   12. Generally applicable procedures and precautions for safe handling and use of the chemical (hygienic practices, maintenance and spill procedures)?

   13. Generally applicable control measures (engineering controls, work practices and personal protective equipment)?

   14. Pertinent emergency and first aid procedures?

   15. Date that the MSDS was prepared or the date of the last change?

       Name, address and telephone number of the responsible party?

5. Are all sections of the MSDS completed?

This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.