OSHA Hazard Communication Standard Compliance

Miller Engineering is often asked to evaluate chemical product literature against mandatory regulations and consensus standards. Since Dr. Miller worked for OSHA when MSDS requirements were created, he has a historical perspective which many clients have found to be historically valuable in cases of long term chemical exposure. We assure that all literature is evaluated consistent with the regulations contemporary to the time period of exposure.

Allow us to help your company prepare or review your chemical product literature such as Safety Data Sheets (MSDS/SDS), product labels, & other technical documents!

OSHA Hazcom Standard (HCS)

The premiere mandatory standard for communicating hazards associated with industrial chemicals is the Occupational Health and Safety Administration (OSHA) Hazard Communication Standard (HazCom or HCS) found in 29 CFR 1910.1200, which includes the following sections:

(a) purpose;
(b) scope and application;
(c) definitions;
(d) hazard determination;
(e) written hazard communication program;
(f) labels and other forms of warning;
(g) material safety data sheets;
(h) employee information.

Prior to the HazCom’s promulgation in the mid-1980’s, there was no national “right to know” requirement that employees be provided detailed information about the hazards associated with the chemicals they were handling, or instructions for remedial action to avoid or minimize the risk associated with those hazards.

Now, in the United States, national requirements were recently aligned with the Globally Harmonized System (GHS) for Classification & Labeling of Chemicals. For consistency with international standards, OSHA incorporated the GHS guidelines into the HCS. As always, Miller Engineering stayed current on the process and updated our analyses to reflect these changes. We continue to evaluate product literature to the most applicable standards and regulations for the time period.

ANSI Hazard Communication Standards

In addition to the OSHA HazCom standard, the American National Standards Institute (ANSI) has published the following standards, which are consensus standards related to chemical hazard communication in the U.S. and which supplement OSHA’s requirements:

  • American National Standard for Hazardous Industrial Chemicals – Precautionary Labeling (ANSI Z129.1)
  • American National Standard for Hazardous Industrial Chemicals – Material Safety Data Sheets – Preparation (ANSI Z400.1)

ANSI Z129.1 provides recommendations for chemical label format, color, size, symbols, & wording. These aspects of a label are important in creating an effective warning that workers will heed.

Similar to the our evaluations to OSHA standards, Miller Engineering has established processes for comparing chemical product label and MSDS language with the ANSI guidelines.

Other Agency Labeling Requirements

Depending on the type of packaging, method of exposure, and chemical properties of a hazardous chemical, additional product labeling may be required other than that specified by OSHA.

Agencies such as the Department of Transportation, the Environmental Protection Agency, and the Consumer Product Safety Commission all regulate aspects of product labeling.

Further there are consensus organizations such as the National Fire Protection Agency (NFPA) and the National Paint & Coatings Association (NPCA) provide guidelines for information to include on product labels.

Miller Publications Regarding Chemical Exposure

  • Miller, J.M. (2007). “Hazard Communication Compliance”, in Safety Engineering Handbook, American Society of Safety Engineers.
  • Lehto, M.R., House, T.E. and Papastavrou, J.D. (2000). “Interpretation of Fuzzy Qualifiers by Chemical Workers,” International Journal of Cognitive Ergonomics, Vol. 4, No. 1, pp. 73-88.
  • Lehto, M.R. (1998).“The Influence of Chemical Warning Label Content and Format on Information Retrieval Speed and Accuracy,”Journal of Safety Research, Vol. 29, No. 1, pp.1-14.
  • Lehto, M.R. and House, T.E. (1997). “Evaluation of the Comprehension of Hazard Communication Phrases by Chemical Workers,” International Ergonomics Association 13th Triennial Congress, Tampere, Finland.
  • Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1975). Psychomotor and Neuromuscular Changes in Workers Exposed to Inorganic Mercury. Journal of the American Industrial Hygiene Association, October.
  • Miller, J.M. and Chaffin, D. (1973). Behavioral and Neurological Evaluation of Workers Exposed to Inorganic Mercury. (NIOSH Contract #5T01-0N00161-02).
  • Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1973). An Evaluation of the Effects of Chronic Mercury Exposures on EMG and Psychomotor Functions (Final Report, NIOSH Contract #5T01-0N00161-02).