Rachel Krubsack, Editor - EHS
February 25, 2025
If OSHA came knocking, would your company face fines for Hazard Communication (HazCom) violations? From missing or inaccessible Safety Data Sheets (SDSs) to lack of a written HazCom program and chemical inventory, there are a number of ways companies get tripped up. Following are some common questions we get regarding SDSs and the written program.
A: The written HazCom program essentially describes how your company is complying with the HazCom Standard. It must address:
Another requirement of the written program is the chemical list or inventory. This is a list of all hazardous chemicals known to be present in the workplace, even if they’re in storage. It must contain the product identifier, such as the product name or number, from the corresponding SDS and label.
A: Where there’s more than one employer operating on a site, and employees may be exposed to the chemicals used by the other employers, your written HazCom program must address:
OSHA allows you to decide on the method of information exchange.
Each employer on a multi-employer worksite must make a written HazCom program available to their own employees, whether they generate the hazard, or the hazard is generated by other employers on the site.
A: Yes, the SDS must be specific to the product and manufacturer.
A: OSHA says there must be a backup procedure or system in place in case the electronic system isn’t functioning. One option is to maintain paper copies.
A: The requirement for SDSs in this situation is found at 1910.1200(b)(4) and says that employers must:
A: The consumer product exemption at 1910.1200(b)(6)(ix) can be confusing. These products are exempt from HazCom where the employer can show they’re used in the workplace for the purpose intended by the chemical manufacturer or importer, and the use results in a duration and frequency of exposure which isn’t greater than what could reasonably be experienced by consumers when used for the intended purpose.
It’s possible that you could have some consumer products that require an SDS and some that don’t, depending on their use. For example, if a cleanser is used occasionally by employees to wipe down their desk, that would meet the consumer use exemption. If that same cleanser is used for custodial or janitorial purposes, where its use exceeds that of a typical consumer, you need an SDS for it.
A: There’s no distance requirement, but employees must be able to access SDSs in their work area within each work shift. If SDSs are stored electronically, employees must be trained to use the system. There must be no barrier to access, such as storing SDSs in a locked cabinet or having to ask a supervisor for an SDS.
Managing Hazard Communication (HazCom) compliance can be overwhelming, with requirements ranging from maintaining accurate Safety Data Sheets (SDSs) to ensuring multi-employer worksite coordination. Common questions about written programs, electronic SDS storage, and consumer product exemptions highlight the complexity of compliance.
A chemical management service can simplify these challenges by providing expert guidance, streamlining SDS organization, and ensuring that your HazCom program meets OSHA’s requirements. With professional support, businesses can avoid costly fines, enhance workplace safety, and ensure that employees have immediate access to critical chemical hazard information.
Learn more about J. J. Keller's Chemical Management Service!