OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

Subject: Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVES) Manual

A. PURPOSE. This instruction transmits revised and new pages to the Regulatory and General Industry SAVEs Manual for Hazard Communication.

B. SCOPE. This instruction applies OSHA-wide.

C. ACTION. Regional Administrators and Area Directors shall ensure that all compliance personnel:

1. Make the following page changes to the Regulatory and General Industry (SAVEs) Manual:

677.1 through 678

2. File a copy of this transmittal sheet behind OSHA Instruction CPL 2.35 CH-20 in the appropriate OSHA Directives System binder.

D. BACKGROUND. Revisions to 29 CFR 1910.1200, Hazard Communication, and Final Rules and Regulations for 29 CFR 1910.1200, Hazard Communication, were published in the FEDERAL REGISTER, Vol.52, No. 163, on August 24, 1987.

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

E. STATE PLAN STATES. Regional Administrators shall advise State designees of the action required by this instruction and encourage their participation in the SAVEs program.

Roger A. Clark, Acting Director Directorate of Compliance Programs

DISTRIBUTION: National, Regional, and Area Offices Compliance Officers State Designees Area Office Clericals 11(c)/405 Programs NIOSH Regional Program Directors

OSHA Instruction CPL 2.35 CH-15 February 18, 1991 Office of General Industry Compliance Assistance

1 29 CFR 1910.1048(o)(5)(i): The employer did not retain exposure to formaldehyde records and determinations for at least 30 years:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS)

2 29 CFR 1910.1048(o)(5)(ii): The employer did not retain medical records of employees exposed to formaldehyde for the duration of employment, plus 30 years:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS)

3 29 CFR 1910.1048(o)(5)(iii): The employer did not retain respirator fit testing records of employees exposed to formaldehyde until replaced by a more recent record:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS)

4 29 CFR 1910.1048(o)(6)(ii): The employer did not make employee exposure to formaldehyde records, including estimates made from representative monitoring available upon request for examination and copying to the subject employee, or former employee, and employee representatives in accordance with 29 CFR 1910.20(a)-(e) and (g)-(i):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS)

5 29 CFR 1910.1048(o)(6)(iii): Employee medical records for exposure to formaldehyde required by this standard were not provided upon request for examination and copying, to the subject employee or former employee or to anyone having the specific written consent of the subject employee or former employee:

(a) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(b)(3)(i): The employer of employees working in laboratories did not ensure that labels on incoming containers of hazardous chemicals were not removed or defaced:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING CHEMICAL/PRODUCT INVOLVED) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE)

OPTION 1 2 29 CFR 1910.1200(b)(3)(ii): The employer of employees working in laboratories did not maintain material safety data sheets that were received with incoming shipments of hazardous chemicals:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING CHEMICAL/PRODUCT(S)) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE)

OPTION 2 3 29 CFR 1910.1200(b)(3)(ii): The employer of employees working in laboratories did not ensure that material safety data sheets were readily accessible to the employees:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING CHEMICAL/PRODUCT(S) FOR WHICH MSDS WERE MISSING)(INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE, INCLUDING DATE MSDS(S) WERE RECEIVED)

4 29 CFR 1910.1200(b)(3)(iii): The employer did not ensure that laboratory employees were apprised of the hazards of the chemicals in their workplaces in accordance with 29 CFR 1910.1200(h):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING HAZARDS THE EMPLOYEES WERE NOT APPRISED OF)(INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(b)(4)(i): In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, the employer did not ensure that labels on incoming containers of hazardous chemicals were not removed or defaced:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING HAZARDOUS CHEMICAL OR CHEMICAL PRODUCT(S) INVOLVED) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE)

OPTION 1 2 29 CFR 1910.1200(b)(4)(ii): In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, the employer did not maintain copies of any material safety data sheets that were received with incoming shipments of the sealed containers of hazardous chemicals:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING HAZARDOUS CHEMICAL OR CHEMICAL PRODUCT(S) INVOLVED) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE)

OPTION 2 3 29 CFR 1910.1200(b)(4)(ii): In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, the employer did not obtain a material safety data sheet for sealed containers of hazardous chemicals received without a MSDS when an employee requested the MSDS:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING HAZARDOUS CHEMICAL OR CHEMICAL/PRODUCT (S) INVOLVED) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

OPTION 3 1 29 CFR 1910.1200(b)(4)(ii): In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, the employer did not ensure that the material safety data sheets were readily accessible during each work shift to employees when they were in their work areas:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING CHEMICAL/PRODUCT(S) FOR WHICH MSDS WERE NOT READILY ACCESSIBLE) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DATE)

2 29 CFR 1910.1200(b)(4)(iii): In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, the employer did not ensure that employees were provided with information and training in accordance with 29 CFR 1910.1200(h), to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS INCLUDING WHAT WAS LACKING THAT DEMONSTRATED EMPLOYER DID NOT MEET THIS REQUIREMENT) (INCLUDE THE NUMBER OF EMPLOYEES EXPOSED AND DATE)

NOTE: Can not be cited for the location and availability of the written hazard communication program under 29 CFR 1910.1200(h)(1)(iii).

3 29 CFR 1910.1200(d)(1): Chemical manufacturers and importers did not evaluate chemicals produced in their workplace or those imported to determine if they were hazardous:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) FOR WHICH A HAZARD DETERMINATION HAS NOT BEEN CONDUCTED)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(d)(2): Chemical manufacturers, importers, or employers evaluating chemicals did not identify and consider the available scientific evidence to determine if they were hazardous:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT AND THE AVAILABLE SCIENTIFIC EVIDENCE THE MANUFACTURER, IMPORTER OR EMPLOYER FAILED TO IDENTIFY AND CONSIDER)

OPTION 1 2 29 CFR 1910.1200(d)(6): Chemical manufacturers, importers, or employers did not describe in writing the procedures used to determine the hazards of the chemical they evaluated:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) AND WRITTEN HAZARD DETERMINATION PROGRAM DEFICIENCIES)

OPTION 2 3 29 CFR 1910.1200(d)(6): Upon request, written procedures used to determine the hazards of a chemical were not made available to employees or their designated representatives:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) AND PERSONS DENIED ACCESS TO WRITTEN HAZARD EVALUATION PROCEDURES)

4 29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:

(a) (LOCATION) (IDENTIFY EMPLOYER'S DEFICIENCY IN MEETING WRITTEN PROGRAM REQUIREMENTS (e.g., "NO PROGRAM WAS DEVELOPED" OR "NO PROGRAM WAS MAINTAINED AT THE WORKPLACE", AS APPLICABLE) (IF PROGRAM EXISTS BUT IS DEFICIENT, DESCRIBE DEFICIENCIES) (IDENTIFY WORKPLACE EXPOSURE BY JOB TITLE/DESCRIPTION AND IDENTITY OF HAZARDOUS CHEMICAL(S))

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(e)(1)(i): The written hazard communication program did not include a list of the hazardous chemicals known to be present using an identity that was referenced on the appropriate material safety data sheet:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATION AND/OR CONDITIONS INCLUDING CHEMICAL/PRODUCT AND DEFICIENCIES)

2 29 CFR 1910.1200(e)(1)(ii): The written hazard communication program did not include 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:

(a) (LOCATION) (IDENTIFY TASK AND FREQUENCY OF TASK AND HAZARDS ANTICIPATED THAT WAS NOT ADDRESSED IN THE WRITTEN PROGRAM)

3 29 CFR 1910.1200(e)(2): The employer produced, used, or stored hazardous chemicals at the workplace in such a way that employees of other employer(s) could be exposed and did not ensure that the hazard communication program included all of the elements listed in 29 CFR 1910.1200(e)(2)(i) through (iii):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS) (DESCRIBE EXPOSURE OF EMPLOYEES OF OTHER EMPLOYERS) (DESCRIBE CONDITIONS OF USE OF CHEMICALS(S) AND IDENTIFY CHEMICAL HAZARD(S)) (DATE & SHIFT)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(e)(2)(i): The employer's hazard communication program did not include methods the employer will use to provide other employers with a copy of the material safety data sheet, or to make it available at a central location in the workplace, for each hazardous chemical the other employers employees could be exposed to while working:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS) (NAMES OF OTHER EMPLOYER(S) WITH EMPLOYEES EXPOSED AND STATE "NAME OF EMPLOYER'S WRITTEN PROGRAM DID NOT INCLUDE THE METHODS WHICH COULD HAVE BEEN USED OR EITHER MAKE THEM AVAILABLE AT A CENTRAL LOCATION TO OTHER EMPLOYERS")

2 29 CFR 1910.1200(e)(2)(ii): The employer's hazard communication program did not include methods the employer will use to inform the other employer(s) of any precautionary measures that need to be taken to protect employees during the workplace's normal operating conditions and in foreseeable emergencies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS) (NAMES OF OTHER EMPLOYERS WITH EMPLOYEES EXPOSED AND STATE "NAME OF EMPLOYER'S WRITTEN HAZARD COMMUNICATION PROGRAM DID NOT INCLUDE THE METHODS WHICH COULD HAVE BEEN USED TO INFORM OTHER EMPLOYERS OF ANY PRECAUTIONARY MEASURES NECESSARY TO BE TAKEN TO PROTECT EMPLOYEES")

3 29 CFR 1910.1200(e)(2)(iii): The employer's hazard communication program did not include methods the employer will use to inform the other employer(s) of the workplace labeling system:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS) (THE NAMES OF OTHER EMPLOYER(S) WITH EMPLOYEES EXPOSED AND STATE "NAME OF EMPLOYER'S WRITTEN HAZARD COMMUNICATION PROGRAM DID NOT INCLUDE THE METHODS WHICH COULD HAVE BEEN USED TO INFORM OTHER EMPLOYERS OF THE LABELING SYSTEM USED IN THE WORKPLACE") (DATE & SHIFT)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(e)(4): The employer did not make the written hazard communication program available upon request to the employees or their designated representatives in accordance with 29 CFR 1910.20(e):

(a) (LOCATION) (IDENTIFY REQUESTING PERSON AND SPECIFIC DENIAL TO PROVIDE A COPY OF THE WRITTEN PROGRAM WITHIN 15 DAYS)

2 29 CFR 1910.1200(f)(1)(i): The chemical manufacturer, importer, or distributor did not ensure that each container of hazardous chemicals leaving the workplace was labeled, tagged or marked with the identity of the hazardous chemicals:

(a) (LOCATION) (IDENTIFY INCLUDING CHEMICAL/PRODUCT(S) BEING SHIPPED DOWNSTREAM AND IDENTIFY DEFICIENCY)

3 29 CFR 1910.1200(f)(1)(ii): The chemical manufacturer, importer, or distributor did not ensure that each container of hazardous chemicals leaving the workplace was labeled, tagged or marked with the appropriate hazard warnings:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) EXPOSURE INCLUDING SPECIFIC TARGET ORGAN EFFECTS, CARCINOGEN WARNING AND/OR PHYSICAL HAZARDS AS APPLICABLE WHICH ARE NOT LISTED ON THE LABEL)

4 29 CFR 1910.1200(f)(1)(iii): The chemical manufacturer, importer, or distributor did not ensure that each container of hazardous chemicals leaving the workplace was labeled, tagged or marked with the name and address of the chemical manufacturer, importer, or other responsible party:

(a) (LOCATION) (IDENTIFY CHEMICAL/PRODUCT(S) AND DEFICIENCY)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(f)(2): The label for a solid metal was not transmitted to the customer at the time of initial shipment nor when the information on the label changed:

(a) (LOCATION) (IDENTIFY SPECIFIC METAL SHIPMENT INCLUDING CHEMICAL/PRODUCT(S) FOR WHICH A LABEL WAS NOT TRANSMITTED)

2 29 CFR 1910.1200(f)(5)(i): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the identity of the hazardous chemical(s) contained therein:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS, DESCRIPTION OF EMPLOYEE EXPOSURE AND CONDITIONS OF USE INCLUDING THE CONTAINER OF THE CHEMICAL/PRODUCT AND IDENTIFY DEFICIENCY)

3 29 CFR 1910.1200(f)(5)(ii): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the appropriate hazard warnings:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATION) (DESCRIPTION OF EMPLOYEE EXPOSURE AND CONDITIONS OF USE INCLUDING CHEMICAL/PRODUCT(S) AND WARNING (DISCREPANCIES) (INCLUDING SPECIFIC TARGET ORGAN EFFECTS, CARCINOGEN WARNING AND/OR PHYSICAL HAZARDS AS APPLICABLE)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.1200(f)(6): The employer used written materials, such as signs, placards, process sheets, batch tickets in lieu of affixing labels to individual stationary process containers which failed to identify the container to which it is applicable and/or failed to convey the information required by 1910.1200(f)(5) to be on a label:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE WHAT THE EMPLOYER WAS USING IN LIEU OF AFFIXED LABELS ON THE CHEMICAL/PRODUCT(S) ITS IDENTITY AND PARTICULAR INFORMATIONAL DEFICIENCIES UNDER 29 CFR 1910.1200(f)(5))

OPTION 2 2 29 CFR 1910.1200(f)(6): The employer used written materials, such as signs, placards, process sheets, batch tickets in lieu of affixing labels to individual stationary process containers which were not readily accessible to the employees in their work area throughout each work shift:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (DESCRIBE WHAT THE EMPLOYER WAS USING IN LIEU OF AFFIXED LABELS ON THE CHEMICAL/PRODUCT(S) AND WHY OR HOW THE ALTERNATIVE WRITTEN MATERIAL WAS NOT AVAILABLE TO EMPLOYEES)

3 29 CFR 1910.1200(f)(8): The employer removed or defaced labels on incoming containers of hazardous chemicals and did not immediately mark the containers with the required information:

(a) (LOCATION) (IDENTIFY SPECIFIC CONTAINER(S) OF CHEMICAL/PRODUCT(S) AND LABEL DEFICIENCY)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(f)(9): The employer did not ensure that labels or other forms of warning were legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift:

(a) (LOCATION) (IDENTIFY SPECIFIC CONTAINER(S) CHEMICAL/PRODUCT(S) AND DEFICIENCY)

OPTION 1 2 29 CFR 1910.1200(g)(1): Chemical manufacturers and importers did not obtain or develop a material safety data sheet for each hazardous chemical they produced or imported:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S)) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE) (SPECIFIC OPERATIONS AND CONDITIONS OF USE)

OPTION 2 3 29 CFR 1910.1200(g)(1): The employer did not have a material safety data sheet for each hazardous chemical which they used:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT FOR WHICH THE EMPLOYER HAD NOT OBTAINED AN MSDS) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE, SPECIFIC OPERATIONS AND CONDITIONS OF USE)

4 29 CFR 1910.1200(g)(2): Material safety data sheet(s) were not written in English:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) FOR WHICH MSDS WAS NOT IN ENGLISH)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(g)(2)__*__: Each material safety data sheet (MSDS) for hazardous chemicals did not contain at least the following information__**__:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT, SPECIFIC OPERATIONS AND DESCRIPTION OF EMPLOYEE EXPOSURE, AND CONDITION OF USE)

* Insert appropriate subparagraph (g)(2)(i)(A) through (g)(2)(xii) for each OPTION:

** Insert the appropriate statement for each OPTION:

OPTION 1 (i) the identity used on the label:

OPTION 2 (i)(A) its chemical and common name(s) when the hazardous chemical is a single substance:

OPTION 3 (i)(B) the chemical and common names of the ingredients which contributes to the known hazards, and the common name(s) of the mixture itself when the chemical mixture has been tested as a whole to determine its hazards:

OPTION 4 (i)(C)(1) chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition when the chemical mixture has not been tested as a whole:

OPTION 5 (i)(C)(1) a list of the chemical and common name(s) of all ingredients identified as carcinogens which comprised 0.1% or greater of the composition when the chemical mixture has not been tested as a whole:

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

OPTION 6 (i)(C)(2) the chemical and common names of all ingredients which have been determined to present a health hazard when present in the mixture which had not been tested as a whole, which comprise less than 1% of the mixture (0.1% for carcinogens) where there is evidence that the ingredients was released in concentrations which exceed an established OSHA permissible exposure limit or ACGIH Threshold Limit Value or present a health hazard to employees:

OPTION 7 (i)(C)(3) the chemical and common name(s) of all ingredients which have been determined to present a physical hazard when present in the mixture which had not been tested as a whole:

OPTION 8 (ii) physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point):

OPTION 9 (iii) the physical.hazards of the hazardous chemical, including the potential for fire, explosion, and reactivity:

OPTION 10 (iv) the health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical:

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

OPTION 11 (v) the primary route(s) of entry:

OPTION 12 (vi) the OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the material safety data sheet, where available:

OPTION 13 (vii) whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions), or by OSHA:

OPTION 14 (viii) any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for cleanup of spills and leaks:

OPTION 15 (ix) any generally applicable control measures which are known to the chemical manufacturer, importer, or employer preparing the material safety data sheet, such as appropriate engineering controls, work practices, or personal protective equipment:

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

OPTION 16 (x) emergency and first aid procedures:

OPTION 17 (xi) the date of preparation of the material safety data sheet or the last change to it:

OPTION 18 (xii) the name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary:

1 29 CFR 1910.1200(g)(3): When no relevant information was found for any given category, the chemical manufacturer, importer, or employer who prepared the material safety data sheet did not mark it to indicate that no applicable information was found:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) FOR WHICH THE PRODUCT'S DATA SHEET FAILED TO INDICATE NO APPLICABLE INFORMATION WAS FOUND)

2 29 CFR 1910.1200(g)(5): Significant new information regarding the hazards of a chemical or ways to protect against the hazards was not added to the material safety data sheet within three months after the employer became aware of such information, or before the chemical was introduced into the workplace again:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S), DATA SHEET AND MISSING INFORMATION)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(g)(6): Chemical manufacturers or importers did not ensure that distributors and employers were provided an appropriate material safety data sheet with their initial shipment, and with the first shipment after a material safety data sheet was updated:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) FOR WHICH NO DATA SHEET WAS PROVIDED TO DOWNSTREAM DISTRIBUTOR OR EMPLOYER AFTER INITIAL SHIPMENT OR MSDS UPDATE)

OPTION 1 2 29 CFR 1910.1200(g)(7): Distributors did not ensure that material safety data sheets and updated information were provided to other distributors and employers:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) FOR WHICH NO DATA SHEET WAS PROVIDED TO DOWNSTREAM DISTRIBUTOR OR EMPLOYER)

OPTION 2 3 29 CFR 1910.1200(g)(7): Retail distributors who sold hazardous materials to commercial customers did not provide material safety data sheets to such employers upon request:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT'S DATA SHEET AND UTILIZING EMPLOYER)

OPTION 3 4 29 CFR 1910.1200(g)(7): Retail distributors who sold hazardous chemicals to commercial customers did not post a sign or otherwise inform the employer that material safety data sheets were available:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT'S DATA SHEET AND UTILIZING EMPLOYER)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.1200(g)(8): The employer did not maintain copies of the required material safety data sheets for each hazardous chemical in the workplace:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND CONDITIONS OF USE, INCLUDING CHEMICAL/PRODUCT(S) FOR WHICH A DATA SHEET WAS NOT MAINTAINED)(DATE & SHIFT)

OPTION 2 2 29 CFR 1910.1200(g)(8): The employer did not ensure that material safety data sheets were readily accessible to the employees in their work area during each work shift:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND CONDITIONS OF USE, INCLUDING CHEMICAL/PRODUCTS AND HOW MSDS WERE NOT READILY ACCESSIBLE) (DATE & SHIFT)

3 29 CFR 1910.1200(g)(9): The employer did not maintain the material safety data sheets in each workplace or at a central location at the primary workplace facility in case of an emergency, where employees must travel between workplaces during a workshift:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND CONDITIONS OF USE, INCLUDING CHEMICAL/PRODUCT(S) AND DESCRIPTION OF EMPLOYEE EXPOSURE)(LOCATION WHERE MATERIAL SAFETY DATA SHEET WAS NOT MAINTAINED AT THE WORKPLACE)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(g)(11): Material safety data sheets were not made available upon request to the designated representatives:

(a) (LOCATION) (IDENTIFY SPECIFIC CHEMICAL/PRODUCT(S) FOR WHICH DATA SHEETS ACCESS WAS DENIED) (PERSON DENIED)

2 29 CFR 1910.1200(h): Employees were not provided information and training as specified in 29 CFR 1910.1200(h)(1) and (2) on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard was introduced into their work area:

(a) (LOCATION) (INCLUDE DESCRIPTION EMPLOYEE EXPOSURE, CONDITIONS OF USE FOR CHEMICAL/PRODUCT(S) AND DESCRIPTION OF INFORMATION OR TRAINING NOT PROVIDED)

3 29 CFR 1910.1200(h)(1)(i): The employer did not provide information to the employees on the requirements of the Hazard Communication Standard:

(a) (LOCATION) (IDENTIFY CHEMICAL/PRODUCT(S)) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND DESCRIPTION OF INFORMATION NOT PROVIDED)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(h)(1)(ii): The employer did not provide information to the employees on operations in their work area where hazardous chemicals were present:

(a) (LOCATION) (INCLUDE DESCRIPTION SPECIFIC OPERATIONS, CONDITIONS OF EMPLOYEE USE, CHEMICAL/ PRODUCT(S) AND DESCRIPTION OF INFORMATION NOT PROVIDED)

2 29 CFR 1910.1200(h)(1)(iii): The employer did not provide information to the employees as to the location and availability of the written hazard communication program, and material safety data sheets required by this section:

(a) (LOCATION) (IDENTIFY CONDITIONS OF USE OF CHEMICAL/PRODUCT(S)) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND WHAT INFORMATION WAS NOT PROVIDED)

3 29 CFR 1910.1200(h)(2)(i): The employee training did not include the methods and observations used to detect the presence or release of a hazardous chemical in the work area:

(a) (LOCATION) (IDENTIFY METHODS AND OBSERVATIONS FOR WHICH TRAINING WAS NOT PROVIDED AND CHEMICAL/PRODUCT(S)) (INCLUDE DESCRIPTION OF EMPLOYEE EXPOSURE AND CONDITIONS OF USE)

4 29 CFR 1910.1200(h)(2)(ii): Employee training did not include the physical and health hazards of the chemicals in the work area:

     (a)  (LOCATION) (IDENTIFY SPECIFIC TRAINING
               DEFICIENCIES AND CHEMICAL/PRODUCT(S)) (INCLUDE
               DESCRIPTION OF EMPLOYEE USE AND EXPOSURE
               CONDITIONS)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

1 29 CFR 1910.1200(h)(2)(iii): Employee training did not include the measures employees can take to protect themselves from chemical hazards, including specific procedures the employer had implemented to protect employees from exposure to hazardous chemicals:

(a) (LOCATION) (IDENTIFY SPECIFIC TRAINING DEFICIENCIES AND CHEMICAL/PRODUCT(S)) (INCLUDE DESCRIPTION OF EMPLOYEE'S USE AND EXPOSURE CONDITIONS)

2 29 CFR 1910.1200(h)(2)(iv): Employee training did not include the details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use appropriate hazard information:

(a) (LOCATION) (IDENTIFY SPECIFIC TRAINING DEFICIENCIES, AND CHEMICAL/PRODUCT(S)) (DESCRIPTION OF EMPLOYEE'S USE AND EXPOSURE CONDITIONS)

3 29 CFR 1910.1200(i)(12): Information which this section requires the chemical manufacturer, importer, or employer to make available was not disclosed upon request, to the Assistant Secretary:

(a) (LOCATION) (IDENTIFY CHEMICAL/PRODUCT(S)) (SPECIFY WHAT INFORMATION WAS NOT PROVIDED AND DATE INFORMATION NOT DISCLOSED)

OSHA Instruction CPL 2.35 CH-21 October 21, 1992 Office of General Industry Compliance Assistance

OSHA Instruction CPL 2.35 CH-19 November 18, 1991 Office of General Industry Compliance Assistance

1 29 CFR 1910.1450(c): The employer did not ensure that laboratory employees' exposures to OSHA regulated substances did not exceed the permissible exposure limits specified in 29 CFR Part 1910, Subpart Z:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

          NOTE 1:  This SAVE must be grouped with the appropriate
                   overexposure and/or engineering SAVE in
                   Subpart Z along with the required abatement
                   steps.

          NOTE 2:  Where appropriate respirators were not
                   provided or were used improperly, the
                   appropriate SAVEs from 29 CFR 1910.1450(i)
                   and 29 CFR 1910.134 must also be grouped to
                   help support this SAVE.

2 29 CFR 1910.1450(d)(1): The employer did not measure the laboratory employee's exposure to a substance regulated by a standard which required monitoring when there was reason to believe that exposure levels for that substance routinely exceeded the action level (or in the absence of an action level, the PEL):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS)

NOTE: This SAVE must be grouped with the appropriate monitoring SAVEs in Subpart Z.

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