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Guidelines for Employer Compliance (Advisory)

Appendix E to the Hazard Communication Standard, 29 CFR 1910.1200

[Note: Annotations made in green text below are tips/commentary by ILPI, not OSHA.]

Table of Contents

Introduction to the HCS

    The Hazard Communication Standard (HCS) is based on a simple concept - that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring. The HCS is designed to provide employees with the information they need.

    Knowledge acquired under the HCS will help employers provide safer workplaces for their employees. When employers have information about the chemicals being used, they can take steps to reduce exposures, substitute less hazardous materials, and establish proper work practices. These efforts will help prevent the occurrence of work-related illnesses and injuries caused by chemicals.

    The HCS addresses the issues of evaluating and communicating hazards to workers. Evaluation of chemical hazards involves a number of technical concepts, and is a process that requires the professional judgment of experienced experts. That's why the HCS is designed so that employers who simply use chemicals, rather than produce or import them, are not required to evaluate the hazards of those chemicals. Hazard determination is the responsibility of the producers and importers of the materials. Producers and importers of chemicals are then required to provide the hazard information to employers that purchase their products.

    Employers that don't produce or import chemicals need only focus on those parts of the rule that deal with establishing a workplace program and communicating information to their workers. This appendix is a general guide for such employers to help them determine what's required under the rule. It does not supplant or substitute for the regulatory provisions, but rather provides a simplified outline of the steps an average employer would follow to meet those requirements.

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A Simplified Compliance Outline For Employers

  1. "Becoming Familiar With The Rule."

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  2. "Identify Responsible Staff"

      Hazard communication is going to be a continuing program in your facility. Compliance with the HCS is not a "one shot deal." In order to have a successful program, it will be necessary to assign responsibility for both the initial and ongoing activities that have to be undertaken to comply with the rule. In some cases, these activities may already be part of current job assignments. For example, site supervisors are frequently responsible for on-the-job training sessions. Early identification of the responsible employees, and involvement of them in the development of your plan of action, will result in a more effective program design. Evaluation of the effectiveness of your program will also be enhanced by involvement of affected employees.

      For any safety and health program, success depends on commitment at every level of the organization. This is particularly true for hazard communication, where success requires a change in behavior. This will only occur if employers understand the program, and are committed to its success, and if employees are motivated by the people presenting the information to them.

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  3. "Identify Hazardous Chemicals in the Workplace."

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  4. "Preparing and Implementing a Hazard Communication Program".

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  5. "Checklist for Compliance"

    The following checklist will help to ensure you are in compliance with the rule:

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  6. "Further Assistance"

    If you have a question regarding compliance with the HCS, you should contact your local OSHA Area Office for assistance. In addition, each OSHA Regional Office has a Hazard Communication Coordinator who can answer your questions. Free consultation services are also available to assist employers, and information regarding these services can be obtained through the Area and Regional offices as well.

    The telephone number for the OSHA office closest to you should be listed in your local telephone directory. If you are not able to obtain this information [ILPI says: follow that hyperlink in the previous paragraph!], you may contact OSHA's Office of Information and Consumer Affairs at (202) 219-8151 for further assistance in identifying the appropriate contacts.

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    [52 FR 31877, Aug. 24, 1987; 52 FR 46080, Dec. 4, 1987; 53 FR 15035, Apr. 27, 1988; 54 FR 6888, Feb. 15, 1989; 54 FR 24334, June 7, 1989; 59 FR 6170, Feb. 9, 1994; 59 FR 17479, April 13, 1994; 59 FR 65947, Dec. 22, 1994; 61 FR 5507, Feb. 13, 1996; 61 FR 9227, March 7, 1996]

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    Entry last updated: Wednesday, June 17, 2009. This hypermarked and content-enhanced page is copyright 2001-2014 by ILPI, all rights reserved. Unauthorized duplication or posting on other web sites is expressly prohibited. For questions, comments and concerns, please contact us at our MSDS email address.

    The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099&p_text_version=FALSE.