Search

Question of the Week: Communicating Unknown Hazards

Posted on 2/1/2011 by James Griffin

Q. When an employer discovers that a chemical product has a hazard that is NOT indicated on the manufacturer’s Material Safety Data Sheet (MSDS), what should he or she do?

A. The Hazard Communication Standard (HCS: 29 CFR 1910.1200(h)) requires chemical manufacturers to assess the hazards of their products and prepare the MSDS accordingly. The MSDS must report all physical and health hazards that may appear during normal use and forseeable emergency situations.

When an employer discovers that an MSDS is inadequate or incomplete, he or she is not responsible for rewriting the MSDS. However, employers must inform their employees of the new hazard and provide them appropriate training and protective equipment.

Employers are encouraged to contact chemical manufacturers about hazards that are not accurately reflected on the MSDS. Chemical manufacturers are required to update their MSDSs when new information comes to their attention (29 CFR 1910.1200(g)(5)).

OSHA has policies in place that explain how to address an inaccurate MSDS. See OSHA Directive 02-00-038 “Inspection Procedures for the Hazard Communication Standard”.

Sources: OSHA letter of interpretation [December 22, 2008]

Tags: HazCom, osha, Safety Data Sheets

Find a Post

Compliance Archives

Lion - Quotes

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

The instructor created a great learning environment.

Avinash Thummadi

CAD & Environmental Manager

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

Amazing instructor; real-life examples. Lion training gets better every year!

Frank Papandrea

Environmental Manager

I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!

Kevin Pylka

Permitting, Compliance & Environmental Manager

Download Our Latest Whitepaper

This guide will help you identify 25 of the most -cited errors in RCRA training, recordkeeping, hazardous waste ID, container management, universal waste, and laboratories.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.