The requirements of 40 CFR Part 370, promulgated pursuant to EPCRA Sections 311 and 312, apply to facilities that have certain quantities of hazardous chemicals for which they are required, under the Occupational Safety and Health Act (OSHA), to prepare or have available Material Safety Data Sheets (MSDSs). How should a facility determine whether it must comply with 40 CFR Part 370 if it is uncertain whether it has a hazardous chemical for which OSHA requires an MSDS? Show There is no comprehensive list of hazardous chemicals. The EPCRA regulations in 40 CFR Part 370 cite OSHA's broad definition of hazardous chemical (with certain exceptions listed in EPCRA Section 311(e)), which includes any element, compound, or mixture of elements that is a physical hazard or a health hazard (29 CFR Section 1910.1200(c) and 40 CFR Section 370.2). Health hazards include, among others, chemicals that are carcinogens, toxics, reproductive toxins, irritants, corrosive, neurotoxins, hepatotoxins, and chemicals that damage the lungs, skin, eyes, or mucous membranes (29 CFR Section 1910.1200(c) and Appendix A). Physical hazards include, among others, chemicals that are combustible, explosive, flammable, oxidizers, reactive, unstable, water-reactive, as well as compressed gases (29 CFR Section 1910.1200(c)). OSHA's Hazard Communication Standard (29 CFR Section 1910.1200) requires chemical manufacturers and importers to obtain or develop an MSDS for each hazardous chemical that they produce or import, and requires employers to have an MSDS available for each hazardous chemical that they use (29 CFR Section 1910.1200(g)). OSHA regulations list several exemptions to the Hazard Communication Standard in 29 CFR Section 1910.1200(b)(6). OSHA provides the following guidance regarding which chemicals are covered by the Hazard Communication Standard: The Hazard Communication Standard applies to any chemical with an OSHA permissible exposure level, anything listed with a threshold limit value by the American Conference of Governmental Industrial Hygienists, any carcinogen listed by the International Agency for Research on Cancer (Groups 1, 2A, and 2B), any carcinogen listed by the National Toxicology Program, or any chemical regulated by OSHA as a carcinogen. In addition to these chemicals, the Hazard Communication Standard applies to any substance for which there is statistically significant evidence, based on at least one positive study conducted in accordance with established scientific principles, that indicates a health hazard as defined in 29 CFR Section 1910.1200(c). One option for facility owners or operators who are not certain whether they have a hazardous chemical that requires an MSDS under OSHA is to contact the manufacturer of the substance for assistance in making this determination. The manufacturer (or importer) of a particular chemical substance has the primary responsibility under OSHA for determining whether that chemical is subject to OSHA's MSDS requirements. OSHA regulations require manufacturers and importers to provide information on the hazard of their chemicals to persons using or distributing those chemicals. A second option for such owners or operators is to assume that an MSDS is required, and to determine whether the requirements in 40 CFR Part 370 apply, based on whether or not the substance was present at the facility in a threshold amount or more. Facility owners or operators who require additional assistance in determining whether or not they are subject to OSHA's Hazard Communication Standard (i.e., the MSDS requirements) may contact the appropriate local area OSHA office. Check the blue pages of a local telephone directory, under United States Government, Department of Labor, for telephone and address information. afe Handling of Hazardous Materials - PRE/POST Test Review:You may close this window to continue. Click any test to rPOST| 90% | Saturday, November 30, 2019 | 00:02:56(Click to view test.)A hazmat is a substance or material that is capable of posing an unreasonable risk to health, saf...Which of the following government agencies provides the Hazcom Standards or “Right to Know” laws? Get answer to your question and much more Working Safely with ChemicalsThe Hazard Communication Standard, also known as the Right to Know Law, is mandated in US federal regulation 29 CFR 1910.1200 with enforcement by the Occupational Safety & Health Administration (OSHA); it is also mandated in State of Tennessee Regulations chapter 0800-1-9 with enforcement by the Tennessee Division of Occupational Safety & Health (TOSHA). The OSHA web site provides extensive information about the standard. The Hazard Communication Standard requires that employees receive safety training if they will be working with hazardous chemicals. The Hazard Communication Standard requires that Safety Data Sheets (SDS) be provided by chemical manufacturers and distributors and that facilities where hazardous chemicals are located must train workers on how to safely handle hazardous chemicals. Instruction on the use of SDS and proper chemical labeling must be included in this training. Individuals who work with chemicals in laboratories are required to comply with the OSHA Lab Standard, which includes the requirements of the Hazard Communication standard but also incorporates additional requirements. Please note that the Lab Standard requires a written Chemical Hygiene Plan instead of a written Hazard Communication plan. HCS Training RequirementsTraining must include a description of the Standard, recognition of HCS pictograms, how to obtain, use & understand Safety Data Sheets (SDS), health effects (including reproductive risks), how to interpret information provided on chemical container labels, secondary container labeling requirements, personal protective equipment, safe work practices and emergency procedures. Due to the wide variety in chemical use at Vanderbilt, training is provided in two parts: general information and department-specific information. General training information is described below in Part One, while department-specific requirements are described in Part Two. Important: The OSHA Hazard Communication Standard was revised in 2012. All individuals who work with chemicals at Vanderbilt must complete training that covers all requirements of this law. Frequency: Initial with annual retraining Contact the OCRS webmaster if you have questions about HCS training requirements. Part One: General Hazard Communication TrainingRequired for all employees. Required annually for all employees who are exposed to and work directly with hazardous chemicals. Also required annually for all VUMC employees, per VUMC Policy Hazardous Chemical Right-to-Know, Hazard Communication. Part one training provides general information about requirements of the standard, such as a description of Safety Data Sheets (SDS), the need for chemical container labeling, proper personal protective equipment (PPE), and other requirements of this standard. This training is general and does not provide all of the information that is specific to different departments and units. See Part two: Specific training, below. The Hazard Communication Standard part one training may be provided to new staff online in the Learning Exchange as part of University or Medical Center online orientation or can be provided within their department. The Hazard Communication Standard online training that is available in the Medical Center Learning Exchange and in VU Oracle Learn can be self-assigned. Annual retraining for part one is also available online. Part Two: Specific Hazard Communication TrainingRequired annually for all employees who are exposed to and work directly with hazardous chemicals. Supervisors are responsible for making sure that this training is provided at the departmental or unit level because it must provide specific information about the hazardous chemicals in use at each location. For advice on how to provide specific Hazard Communication training, contact OCRS. This specific training must include
Class length varies and depends on the extent of chemical use within the department or unit. Class Schedule/Location: This training is provided within an individual department. Hazard Communication Standard ResourcesVanderbilt Hazard Communication Standard Written Programs
Vanderbilt Chemical List and Safety Data Sheet Verification Log
Additional VUMC Resources
Recognize Chemical Hazards (NEW - 3/12/2018) Pictograms
Labels
Safety Data Sheets (SDS)
HCS Training General References:
Chemical Safety ResourcesOCRS provides extensive chemical safety information through this web site:
QuestionsIf you have questions about the Hazard Communication Standard or Hazard Communication training, please contact one of the following:
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