Question of the Week | Recent OSHA News | Recent OSHA Rules | Recent OSHA Interpretations
Health & Safety News
Volume 8, Issue 1
Question of the WeekHow Comprehensive Must I Make My Master Chemical List? Q. I am updating my MSDS (Material Safety Data Sheet) books and believe that I need to make up a master chemical list to include at the front of the book(s). What I'm wondering is, just how comprehensive should the master list be? For example, must I list a can of spray paint just because it came in the door with an MSDS? That would seem a bit ridiculous to me. Do I need to simply list every item with an MSDS, or is the purpose of the master list to show only the heavily used items? A. The "master list" you are asking about would most likely be the list of hazardous chemicals that is a mandatory component of an employer's hazard communication program, which is required under OSHA's Hazard Communication standard (29 CFR 1910.1200). The standard requires employers to create "[a] list of the hazardous chemicals known to be present using an identity that is referenced on the appropriate material safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas)" (29 CFR 1910.1200(e)(1)(i)). On the list, employers must include every hazardous chemical that employees are exposed to because of their jobs (with a few exceptions, some of which are mentioned below). The standard defines a hazardous chemical as one that is either a physical hazard or a health hazard. Physical hazards are things such as explosives, oxidizers, flammable liquids, etc. Health hazards include corrosives, sensitizers, carcinogens, toxic agents, and the like. (See 29 CFR 1910.1200(c) for the complete definitions of physical and health hazards, as well as Appendix A to the standard for further explanations of health hazards.) When determining what chemicals need to be included in this list, there are a few things that you need to know: (1) Manufacturers commonly create MSDSs for every material they produce, whether the material poses a hazard or not. Therefore, just because a particular chemical has an MSDS does not necessarily mean that the chemical poses a physical or health hazard. You must look at the MSDS to determine if a particular chemical is a physical or health hazard. (2) Numerous exclusions to the hazard communication standard are provided under 29 CFR 1910.1200(b)(6). Substances listed in Part 1910.1200(b)(6) do not need to be included in a hazard communication program and, therefore, would not need to be included on the master list of chemicals. Examples include:
To learn more about OSHA'S mandatory hazard communication plan, check out our new Managing Hazard Communication web seminar. Fully interactive and informative, this course will help you design and implement a HazCom plan that meets the requirements of OSHA and, more importantly, the needs of your facility. Join the conversation! Visit the osh-mgmt Discussion Group to post comments, ask questions, and get answers!
Recent OSHA News12/26/2006—West
Hartford, Conn., Manufacturer Fined Nearly $250,000 by OSHA Following
Latest Safety and Health Inspection 12/21/2006—OSHA
Seeking Comments on Third Phase of Standards Improvement Process 12/12/2006—OSHA
Joins the Centro Latino de Apoyo, Recursos y Oportunidades (CLARO)
to Raise Safety and Health Awareness for Hispanic Employees
12/14/2006—CSB
Releases Findings from Fatal Daytona Beach Wastewater Plant Explosion
Investigation; Cites Inadequate Engineering, Lack of Public Worker
Safety Coverage Recent OSHA Rules and StandardsFor Lion Members and Recent Course Attendees 12/21/2006—Standards
Improvement Project, Phase III Recent OSHA InterpretationsTo view the most recent OSHA interpretive letters visit the Lion Online Library. |
