What is the appropriate osha standard for hazard communication

The OSHA Hazard Communication Standard (HCS), 29 CFR 1910.1200, is designed to protect employees from hazardous chemicals used or stored in the workplace. It gives workers the right to know and understand the chemicals they are exposed to and how to work with them safely. The standard aligns with the Globally Harmonized System of Chemical Classification and Labeling (GHS) for a consistent approach to classifying chemicals and communicating the hazards associated with their use.

Under the HazCom standard, all workplaces that have hazardous chemicals are required to maintain a chemical inventory and have a written hazard communication program. Laboratories and work operations where employees only handle chemicals in sealed containers, such as a warehouse, are not required to have a written program; however, they do have other responsibilities under the HazCom standard.

The written program must describe how it will meet the HCS requirements for:

• Labels and other forms of warning for hazardous chemical containers,
• Safety data sheets (SDS) for all hazardous chemicals, and
• Training and information for any employee who has the potential of being exposed to a hazardous chemical

It also must include:

• A list/inventory of the hazardous chemicals present in the workplace
• How the employer will inform employees of the hazards of non-routine tasks and the hazards associated with chemicals in unlabeled pipes
• How chemical hazard information will be communicated on multi-employer worksites

December 29, 1992

Mr. Stephen Hill
Vice President
Britthaven, Inc.
Post Office Box 6159
1214 Highway 258 N
Kinston, North Carolina 28502-6159

Dear Mr. Hill:

This is in further response to your inquiry of September 25, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, 29 CFR 1910.1200.

Sara Prueitt of my staff contacted you to see if she could answer your questions over the telephone, however you requested written clarification for your files. You asked whether your long term health care facilities would fall under the scope of the Hazard Communication standard (HCS) in cases where your residents buy their medications from pharmacies that are independent from your facilities and which are prescribed to them by outside physicians.

The HCS applies to your staff of health professionals in many ways, as you have acknowledged. For example, Britthaven would have to inform employees of the hazards involved in using standard (i.e. foreseeable) medications used in practicing health care in your facility, such as the "house drugs" mentioned in your telephone conversation. However, in cases where the residents of your facilities purchase drugs from independent/outside pharmacies, and the drug and its potential hazards are not known until an outside physician orders a prescription, the HCS would not apply.

The purpose of HCS is to communicate information concerning hazards and appropriate protective measures to employees. Employers must provide information to their employees about the hazardous chemicals to which they are exposed by means of a written hazard communication program. The hazard communication program must be developed, implemented and maintained at the workplace, and must also include a list of hazardous chemicals known to be present at the worksite.

Employees must be allowed to have access to information; therefore, if employees find themselves working with a medication brought in by a resident they may ask their employer to obtain a material safety data sheet for the medication. The HCS requires employers to provide information on "any chemical which is known to be in the workplace in such a manner that employees may be exposed..." (29 1910.1200(a). Britthaven's facilities must incorporate their individual method of compliance into its existing HCS program.

Please find enclosed a copy of the OSHA booklet "Chemical Hazard Communication" which explains the standard and employers' responsibility under the rule. Under the Occupational Safety and Health Act of 1970, States are permitted to assume responsibility for their own occupational safety and health programs under a plan approved and closely monitored by Federal OSHA. The North Carolina Department of Labor operates under such a plan. As a condition of plan approval, States are required to adopt and enforce standards that are either identical to or "at least as effective" as the Federal standards. For information regarding the requirements of North Carolina standards, you may want to contact:

North Carolina Department of Labor
4 West Edenton Street
Raleigh, North Carolina 27601

Telephone: (919) 733-7166

We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,

Roger A. Clark, Director
Directorate of Compliance Programs

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