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 courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

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

Dorothy Rurak

Environmental Specialist

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

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

Morgan Bliss

Principal Industrial Hygienist

The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!

Curtis Ahonen

EHS&S Manager

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste 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

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.