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

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

These are the best classes I attend each year. I always take something away and implement improvements at my sites.

Kim Racine

EH&S Manager

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

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.