Hazard Communication

Self-Inspection Checklist

Guidelines

This checklist covers hazard communication regulations (29 CFR 1910.1200) issued by the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA). The purpose of these regulations is to ensure that health and safety information about hazardous chemicals is transmitted to affected employees. These regulations are applicable to any work site where employees may be exposed to hazardous chemicals under normal conditions of use or in an emergency. The following chemicals or items are not covered by this regulation: hazardous waste, tobacco, tobacco products, wood, wood products, manufactured articles, foods, alcoholic beverages, drugs, cosmetics, consumer products, nuisance particulates, ionizing radiation, nonionizing radiation, and biological hazards. The regulations cited apply only to private employers and their employees, unless adopted by a State agency and applied to other groups such as public employees. Definitions of terms in bold type are provided at the end of the checklist.

Hazard Communication Program

1. Has a written hazard communication program been developed, implemented, and maintained at your worksite? [29 CFR 1910.1200(e)(1)]
2. Has a list of known hazardous chemicals at your facility been prepared? [29 CFR 1910.1200(e)(1)(i)]
3. Have methods been developed to inform employees of the hazards of nonroutine tasks? [29 CFR 1910.1200(e)(1)(ii)] Note: Such tasks may include emergency response or equipment repair.
4. Are methods developed for communicating hazards to outside contractors or vendors who may be exposed to hazardous chemicals at your worksite? [29 CFR 1910.1200(e)(2)]

   Labels

5. Are all containers of hazardous chemicals in the workplace labeled, tagged, or marked with the following information? [29 CFR 1910.1200(f)(1)]
   • The identity of the hazardous chemical(s)
   • The appropriate warnings
   • The name and address of the chemical manufacturer, importer, or other responsible party

   Note: Labels must be affixed to all containers of hazardous chemicals when they are shipped by a manufacturer or supplier. If the container is received without a hazard warning label, you must make a good faith effort to obtain the missing information from the manufacturer or supplier. The following hazardous chemicals are exempt from this labeling requirement, although subject to other labeling requirements: pesticides, foods, food additives, color additives, drugs, cosmetics, medical devices, alcoholic beverages, consumer products, hazardous waste, tobacco products, and wood products.

6. Is removal or defacing of labels on incoming containers of hazardous chemicals prohibited? [29 CFR 1910.1200(f)(8)]
7. Are labels or other forms of warnings legible, in English, and prominently displayed? [29 CFR 1910.1200(f)(9)]
8. Material Safety Data Sheets Are material safety data sheets on hand for each hazardous chemicals used and identified on the hazardous chemicals list? [29 CFR 1910.1200(g)(1)]
9. If a hazardous chemical has no material safety data sheet, are attempts made to obtain one from the chemical manufacturer or importer as soon as possible? [29 CFR 1910.1200(g)(6)(iii)]
10. Are material safety data sheets for the hazardous chemicals kept in the facility and made readily accessible to employees? [29 CFR 1910.1200(g)(10)]

    Information and Training

11. Is information and training on hazardous chemicals in the worksite provided on initial assignment and whenever new physical hazards or health hazards are introduced into the work area? [29 CFR 1910.1200(h)(1)]
12. Does the information provided include the requirements of this standard, as well as the following? [29 CFR 1910.1200(h)(2)]
    • The operations at the worksite where hazardous chemicals are present
    • The location and availability of the written hazard communication program, including the list of hazardous chemicals and material safety data sheets
13. Does the training provided include information about the following? [29 CFR 1910.1200(h)(3)]
    • Methods and observations that may be used to detect the presence or release of a hazardous chemicals in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc)
    • The physical hazards and health hazards of the chemicals in the work area
    • The measures employees can take to protect themselves from these hazards, including procedures the employer has implemented to protect employees from exposures to hazardous chemicals (appropriate work practices, emergency procedures, and personal protective equipment)
    • The details of the hazard communication program developed by the employer, including explanations of the labeling system, material safety data sheets, and how employees can obtain and use the appropriate hazard information.

Definitions

Article: a manufactured item other than a fluid or particle that (a) is formed to a shape or design during manufacture, (b) has end use function(s) dependent in whole or in part on its shape or design during end use, and (c) under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical, and does not pose a physical hazard or health risk to employees.

Hazardous chemical: any chemical that is a physical hazard or a health hazard.

Health hazard: a chemical for which statistically significant evidence exists that acute or chronic health effects may occur in exposed employees. This evidence must be based on at least one study conducted in accordance with established scientific principles. The term includes chemicals that are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosive, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents that act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.

Physical hazard: a chemical for which scientifically valid evidence exists that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, and oxidizer, pyrophoric, unstable (reactive) or water-reactive.