OSHA Hazard Communication Standard Compliance

Miller Engineering is often asked to evaluate chemical product literature against mandatory regulations and consensus standards.  The most applicable mandatory standard for industrial chemicals is often OSHA’s Hazard Communication Standard (HCS) 29CFR1910.1200. OSHA recently updated the Hazard Communication Standard for consistency with international standards.

As always, we stayed on top of these changes. We continue to evaluate product literature to the most applicable standards and regulations for the time period.  Further, we can help your company write product literature such as Material Safety Data Sheets (MSDS), Product Labels, & other technical documents.

Allow us to prepare or review your chemical product labels and Safety Data Sheets!

OSHA Hazcom Standard (HCS)

The premiere standard for communicating hazards associated with chemicals found in the workplace 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 requirement that employees be provided 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. OSHA incorporated the GHS guidelines into the HazCom Standard. As always, Miller Engineering stayed current on the process and updated our analyses to reflect these changes. We assure that all literature is evaluated consistent with the regulations contemporary to the time period of exposure.

ANSI Hazard Communication Standards

The American National Standards Institute has published the following standards, which are the primary consensus standards related to chemical hazard communication in the U.S.:

  • 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).