As part of a hazard communication written program, you will need to compile a list of all hazardous chemicals used, or present in your workplace. The list will eventually serve as an inventory of every substance that has an MSDS. At this point, however, preparing the list will help you complete the rest of the program since it will give you some idea of the scope of the program required for compliance in your workplace.
The best way to prepare a comprehensive chemical list is to perform a comprehensive assessment of your facility. This means a department-by-department search for every chemical present. It includes cleaning supplies, such as bathroom and window cleaners; grounds maintenance chemicals, such as weed killers and fertilizer; vendor samples being used on a trial basis; fuels; paints; as well as all chemicals used in your company’s daily operations.
The broadest possible perspective should be taken. Sometimes people think of “chemicals” as being only liquids in containers. The HCS covers chemicals in all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors which determine whether a chemical is covered. If it’s not hazardous and there is no potential for exposure, it’s not covered.
Identify chemicals in containers, including pipes, but also think about chemicals generated in the work operations. For example, welding fumes, dusts, and exhaust fumes are all sources of chemical exposures. Some other suggestions include:
§ Read labels provided by suppliers for hazard information,
§ Make a list of all chemicals that are potentially hazardous,
§ Note the storage and use location(s) of the products, and
§ Note the hazards as found on the label.
As you are compiling this inventory, consider listing the substances separately by department. You will find that it makes it easier to conduct employee training to know which chemicals are used in which departments.
The following list identifies some types of potentially hazardous chemicals that may be present in your workplace.
| Acids | Adhesives |
| Aerosols | Asbestos |
| Battery fluids | Benzene |
| Catalysts | Caustics |
| Cleaning agents | Coal tar pitch |
| Coatings | Degreasing agents |
| Detergents | |
| Etching agents | Fiberglass |
| Flammables | Foaming resins |
| Fuels | Fungicides |
| Gasoline | Glues |
| Greases | Industrial oils |
| Inks | Insecticides |
| Herbicides | Janitorial supplies |
| Kerosene | Lacquers |
| Lead | Lye |
| Oxalic Acid | Paints |
| Pesticides | Plastic resins |
| Process chemicals | Resins |
| Sealers | Shellacs |
| Solders | Solvents |
| Strippers | Sufactants |
| Thinners | Varnishes |
| Water treatments | Wood preservatives |
| Xylene | |
Any substance that presents a physical or health hazard, as defined by OSHA, is considered regulated under the HCS. However, OSHA has designated four separate lists of chemicals that comprise the “floor ”of regulated chemicals. There are about 1,200 chemicals specifically listed as regulated.
IMPORTANT: A SUBSTANCE MAY STILL BE REGULATED EVEN THOUGH IT IS NOT ON ANY LIST.
There are two main categories of hazardous substances covered by OSHA — hazardous chemicals and carcinogenic chemicals. Carcinogenic substances are viewed to present a greater hazard so they are treated more stringently in the regulations.
You will find the list of toxic and/or hazardous substances in OSHA’s subpart Z, §1910.1000 and the ACGIH Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment. Any compound of a substance from these lists is considered part of the floor of covered hazardous chemicals.
The floor lists of carcinogenic substances can be found in OSHA ’s subpart Z, §1910.1000, the NTP Annual Report on Carcinogens, and the IARC Monographs.
Certain hazardous substances are regulated by other agencies; therefore, OSHA has exempted them from coverage by the Hazard Communication Standard. HCS does not apply to the following substances:
§ Any hazardous waste, as defined and regulated under RCRA.
§ Any hazardous substance, as defined and regulated under CERCLA.
§ Tobacco or tobacco products.
§ Wood or wood products, including lumber which will not be processed, where the chemical manufacturer or importer can establish that the only hazard the products pose to employees is the potential for combustion.
§ Food or alcoholic beverages which are sold, used, or prepared in a retail establishment (such as a grocery store or restaurant) and foods intended for personal consumption by employees while in the workplace.
§ Any drug as defined by the federal Food, Drug, and Cosmetic Act when it is in solid, final form for direct administration to the patient (e.g., pills), drugs packaged by the chemical manufacturer for sale to consumers (e.g., over-the-counter drugs), and drugs intended for personal consumption by employees while in the workplace (e.g., first aid supplies).
§ Cosmetics packaged for sale to consumers and those intended for personal use by employees in the workplace.
§ Any consumer product or hazardous substance as defined in the Consumer Product Safety Act and Federal Hazardous Substances Act respectively, used in the workplace in the same manner as normal consumer use, and which use results in exposure which is not greater than exposures experienced by consumers.
§ Nuisance particles when they do not pose any physical or health hazard covered by HCS.
§ Ionizing and nonionizing radiation.
§ Biological hazards.
§ Articles.
If you have exempt substances, you must be able to demonstrate that the substance is subject to other regulations and produce the appropriate label (if required) and any required identification documents, should an OSHA compliance officer inquire.
Weed out non-regulated products
Review the completed inventory list and determine which chemicals are hazardous, as determined by OSHA. This involves checking each chemical against the OSHA-designated lists, reviewing the MSDS information sent by the manufacturer, as well as reviewing §1910.1200(b) to determine if any items can be eliminated from your list because they are exempted materials. Weed out those chemicals not regulated by OSHA.
You will also want to assess employee exposure as it relates to consumer products, such as window cleaner. The level of exposure will determine if the substance must be listed on your hazardous chemical inventory. For example, does the employee use window cleaner to wash windows for the most part of each day, or does the employee use window cleaner once every few months to keep the windows clean, as he or she would at home?
When you are done with this assessment, you will have an inventory of hazardous chemicals. Keep this list current as part of your written hazard communication program.
Once you have compiled a list of the potentially hazardous chemicals used in your workplace, the next step is to find out if there are material safety data sheets for all of them. Check you files against the inventory you have just compiled. If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by copying the letter or writing a note regarding telephone conversations. If you have MSDSs for chemicals that are not on you list, figure out why. Maybe you don’t use the chemical anymore. Or maybe you missed it in your survey. Some suppliers do provide MSDSs for products that are not hazardous. You do not have to maintain these.
Don’t allow employees to use any chemicals for which you have not received an MSDS. The MSDS provides information you need to ensure proper protective measures are implemented prior to exposure.
Items considered “articles” are exempt from the requirements of the HCS. An article is defined as a manufactured item other than a fluid or particle which:
§ Is formed to a specific shape or design during manufacture;
§ Has end use function(s) dependent in whole or in part upon its shape or design during end use; and
§ Must not release more than very small quantities (e.g., minute or trace amounts) of a hazardous chemical, or pose a physical hazard or health risk to employees under normal conditions of use.
It may be difficult to define what is considered “normal conditions of use.” You may have a manufactured item that meets the definition of an article, but if it is burned, it produces a hazardous byproduct. The question then becomes, is burning “normal use” for the product? If burning occurs in its normal use, then it cannot be exempted as an article.
If a hazardous chemical can be expected to be released only when the item is repaired, then that is not considered part of its normal condition of use. The item would be considered an article under the HCS, and thus exempted.
Stainless steel tables, vinyl upholstery, and tires are considered articles. Products that are not articles include:
§ Metal ingots that will be melted under normal conditions of use;
§ Fabric treated with formaldehyde where downstream garment manufacturing employees will be exposed when making clothing; and
§ Switches with mercury in them when a certain percentage break under normal conditions of use.
Basically, if the product will be processed in some way after leaving the manufacturing site — heated, welded, glued, sawed, etc. — and a hazardous chemical could be emitted, it probably will not qualify for the article exemption.
Many chemical products are mixtures or reformulations. If the mixture has been tested as a whole, the results of the test will be used to determine whether it is hazardous. If the mixture has not been tested as a whole and it contains:
§ 1 percent or more of an ingredient that is listed as a health hazard, or
§ 0.1 percent of an ingredient listed as a carcinogen,
then, the whole mixture is assumed to have the same health and/or carcinogenic hazards as its hazardous components.
Even if the mixture contains less than these percentages, but evidence indicates that a hazardous/carcinogenic component could be released in concentrations above an established PEL or TLV, then the mixture again must be assumed to present the same hazard.
The manufacturer, importer, or employer may use whatever scientifically valid data is available to evaluate the physical hazard potential of the mixture. For example, benzene is a carcinogen. If you have an untested mixture containing benzene, and you know there is more than 0.1 percent benzene in the mixture, you must regard the whole mixture as a carcinogen.
If you assume the mixture has the same hazards as its hazardous components, the individual data sheets for the hazardous components will satisfy MSDS requirements (there can be multiple data sheets for one mixture). However, if you decide to test the mixture, a full range of tests need to be performed to determine both the physical and health hazards of mixture.
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