05/16/1988 - Office workers routinely performing short clean up procedures using chemicals covered by the HCS.

Interactive Learning Paradigms, Incorporated


The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995!
The history and philosophy behind this resource.
A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics.
Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term.
An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more.
A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers.
Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet.
Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources.
Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors
You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard
Commercial suppliers of SDS authoring and management software as well as cloud compliance services.
Commercial companies that will create SDS's for your specific needs as well as SDS translation companies.

Safety signs, banners, and scoreboards? Get yours at Safety Emporium!

XXXPrevNext
Title: 05/16/1988 - Office workers routinely performing short clean up procedures using chemicals covered by the HCS.
Record Type: InterpretationStandard Number: 1910.1200

    May 16, 1988

    Mr. Gregory M. Leitner
    Law Offices
    Leitner, Warner, Moffitt, Williams,
    Dooley, Carpenter & Napolitan
    Third Floor Pioneer Building
    Chattanooga, Tennessee 37402

    Dear Mr. Leitner:

    This is in response to your letter of March 22, addressed to Mr. Steven Simon of my staff, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.

    The HCS applies, as stated in 1910.1200(b)(2), " ... to any chemical which is 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." Under the definition of "employee" workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. The amount of time an employee is exposed is not a parameter for determining whether a worker is covered by the standard. Rather, if an employee can be exposed to a hazardous chemical while performing his/her job function, then that employee is covered by the standard. For example, if a cashier is required to perform a clean up procedure at the end of the work shift, that employee would be covered by the standard even if the time required for the clean up was short.
    As you state in your letter your client has no duty to evaluate chemicals. The HCS requires employers to have a written program for their workplaces which at least describes how the requirements for labels and other forms of warning, material safety data sheets, and employee information and training will be met. The written program must also include a list of hazardous chemicals used in the workplace and, if applicable, the methods the employer will use to inform employees of the hazards of non-routine tasks, and the hazards associated with chemicals contained in unlabeled pipes in their work areas.

    The HCS does not specify how training is to be accomplished. The employer is free to select any method of training including an oral presentation. In addition, the standard does not state how long the training must be. If your client determines that a 15 minute oral presentation is sufficient to meet the training requirements of the HCS, OSHA would not object unless we determine that the training was not adequate. From an enforcement standpoint, therefore, OSHA would determine compliance with the training provisions based on whether an employee has been adequately trained and not on the type or length of the training program.

    If we can be of further assistance, please feel free to contact me again.

    		Spill cleanup training

    Hazardous materials spill cleanup training DVD's and other safety training materials are available at Safety Emporium.

    Sincerely,

    Thomas J. Shepich, Director
    Directorate of Compliance Programs<

The original official public domain version of this document is available from OSHA at XXXOSHAURL.