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 exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

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

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective.

John Gratacos

Logistics Manager

Download Our Latest Whitepaper

Tips to identify and manage universal waste under more-stringent state regulations for generators and universal waste handlers in California.

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.