Possible Solutions

OSHA requires that employers implement a written program that meets the requirements of the Hazard Communication Standard (HCS) to provide for worker training, warning labels, and access to Material Safety Data Sheets (MSDSs).

The Hazard Communication Standard ensures employee awareness of the hazardous chemicals they are exposed to in the workplace.

• Agents with any of the following characteristics are considered hazardous: carcinogens, corrosives, toxic or highly toxic, irritants, sensitizers, or target organ effectors. Hazard Communication Standard Appendix A and chemicals listed in 29 CFR 1910.1000 Table 2.
  
  
  • Use both human and animal data in this determination. The Hazard Communication Standard Appendix B lists sources of toxicity information.
  
  
• There are exceptions to some of the requirements of the HCS for consumer products that are subjected to the labeling requirements of the terms as defined in the Consumer Product Safety Act and the Federal Hazardous Substances Act [29 CFR 1910.1200(b)(5)(v)].
  
  
  • For example, OSHA does not require that MSDSs be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them i.e., where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. This exemption applies to many of the cleaning products used in nursing homes.
    
    
    • Provision of MSDSs for consumer products used in the workplace. OSHA Standard Interpretation, (1990, January 9).
      
      
    • Do you need to keep MSDSs for commercial products such as "Windex" and "White-out"? FAQ's for Hazard Communication, (1998).
  
  
• Provide readily available Material Safety Data Sheets (MSDSs) for all hazardous chemicals.
  
  
• Train workers in potential chemical hazards and controls (engineering controls, work practices, PPE) necessary to prevent hazards in the work area [29 CFR 1910.1200(h)(3)].
  
  
• Clearly label as hazardous all hazardous chemicals such as those found in some soaps, disinfectants, and pesticides [29 CFR 1910.1200(f)].

Medical Services and First Aid: Where the eyes or body of any person may be exposed to injurious corrosive materials, provide suitable facilities for quick drenching or flushing of the eyes and body within the work area for immediate emergency use [29 CFR 1910.151(c)].

An employer may choose to use a product that is not considered hazardous.

For additional hazardous drugs information, see Pharmacy.

Additional Information:

• OSHA 174 is a sample MSDS form.
• Hazard Communication. OSHA Safety and Health Topics Page.
• Small Business Handbook. OSHA Publication 2209, (2005). Also available as a 260 KB PDF, 56 pages.
  • Hazardous Substances Communication.
• 29 CFR 1910.1200. OSHA Hazard Communication Standard (HCS).
  • Appendix E, Guidelines for Employer Compliance with the Hazard Communication standard.