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

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

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

Larry Ybarra

Material Release Agent

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

Andy D’Amato

International Trade Compliance Manager

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

Download Our Latest Whitepaper

This report details major changes for hazardous waste generators from US EPA’s Generator Improvements Rule, as well as the latest updates from states that are still working to adopt new, stricter Federal requirements.

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.