Updating our labels

The training provisions of the HCS are not satisfied solely by giving employee the data sheets to read.An employer's training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program.The HCS only applies to pharmaceuticals that the drug manufacturer has determined to be hazardous and that are known to be present in the workplace in such a manner that employees are exposed under normal conditions of use or in a foreseeable emergency.The pharmaceutical manufacturer and the importer have the primary duty for the evaluation of chemical hazards.

In meeting the requirements of OSHA's Hazard Communication Standard, the temporary agency employer would, for example, be expected to provide generic hazard training and information concerning categories of chemicals employees may potentially encounter.Reference Interpretation and Compliance Letters: What are the requirements for refresher training or retraining a new hire?Additional training is to be done whenever a new physical or health hazard is introduced into the work area, not a new chemical.Reference Interpretation and Compliance Letters: Do you need to keep MSDSs for commercial products such as "Windex" and "White-Out"?OSHA does not require that MSDSs be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience.

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If the employee's work area includes the area where the MSDSs can be obtained, then maintaining MSDSs on a computer would be in compliance.

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