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HAZARD COMMUNICATION TRAINING
FOR SMACNA MEMBER COMPANIES
Who Must Comply with the OSHA
HAZCOM Standard
This section applies to any chemical which is known to be
present in the workplace in such a manner that employees
may be exposed under normal conditions of use or in a
foreseeable emergency.
Does not apply to:
Hazardous Waste – SWD Act.
Substance Defined by CERCLA
Tobacco, Food and Alcohol Products
Untreated Wood Products
Consumer Products used in such a way.
Nuisance Particulates that are harmless.
Ionizing and Non Ionizing Radiation
Biological Hazards
Scope of Responsibilities
Chemical Manufacturers and Importers.
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Labeling
MSDS
SMACNA Member Companies that have
employees who use potentially hazardous
materials… Main Parts of HAZCOM Program
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Written Program
Chemical List (Inventory)
MSDS for Each Chemical in the Inventory
Labeled Containers
Training (All Employees)
Definitions
Hazardous Chemical
Any chemical which has a physical
or health hazard effect.
Container
Any bag, barrel, box, can, cylinder,
drum, vessel, storage tank or the likes
that contain a hazardous chemical.
Use
Package, handle, react, emit,
extract or generate as a byproduct
or transfer.
STEP 1
WRITTEN
HAZCOM POLICY
STEP 5
WRITTEN
PROGRAM
STEP 4
INFORMATION
AND TRAINING
STEP 2
LABELS ON
ALL
CONTAINERS
STEP 3
MSDS: COMPLETE
HAZARD ANALYSIS
Labeling Information
Manufacturers
Requirements
Chemical Name
Manufacturer Name
Manufacturer Address
Appropriate Hazard
Warning
Employer’s
Responsibility
Chemical Name
Appropriate Hazard
Warning
(such as “flammable”
or “toxic”)
Employers’ Labeling Requirements
 All containers of chemicals are labeled. The
words ‘container’ and ‘label’ have broad
meaning in 1910.1200
 Exception: immediate use of employee
 Do not remove or deface labels
Change labels as hazard information
changes (within 3 months)
Information
on an MSDS
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Identity
What’s in it?
Physical/Chemical Properties
Health Hazards
Route of Entry
PEL – TLV - Limits
Listed Under NTP, IARC or
NIOSH
• Safe Handling / Use
• Controls – Work Practices –
PPE
• Emergency and 1st Aid
Requirements
Form 174 - MSDS
 Non-Mandatory Form with Twelve
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(12) Mandatory Spaces
Blank spaces are not permitted.
Use NA
Produced by chemical
manufacturers and distributors and
accepted in good faith by employers
Blank 174s are available from
www.osha.gov
Trade Secrets
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Manufacturer can withhold
information from MSDS
Nurse or physician can request
proprietary information in writing
OSHA makes final decision if
information is denied to nurse or
physician
Employee Exposure & MSDS
Your
employee
Your
temporary
employee
Your
supervisor
Visitors and
other
contractors
Employee Access to MSDS
The employer shall maintain in the workplace copies of the required material safety
data sheets for each hazardous chemical, and shall ensure that they are readily
accessible during each work shift to employees when they are in their work area(s).
(Electronic access, microfiche, and other alternatives to maintaining paper copies of
the MSDS are permitted as long as no barriers to immediate employee access in each
workplace are created by such options.)
Information and Training
Requirements of
1910.1200
Operations where
hazardous chemicals
are used
Information about
labeling systems, the
written program and
MSDS
Physical and chemical
hazards
Methods to detect the
presence or release of
the chemical
Protective measures
Review your Company’s Written Hazard Communication
Program and MSDS for information specific to the
chemicals you use!