Reference Interpretation and Compliance Letters: What are the container labeling requirements under HAZCOM?Under HCS, the manufacturer, importer, or distributor is required to label each container of hazardous chemicals.If the hazardous chemicals are transferred into unmarked containers, these containers must be labeled with the required information, unless the container into which the chemical is transferred is intended for the immediate use of the employee who performed the transfer.Reference Interpretation and Compliance Letters: How does HAZCOM apply to pharmaceutical drugs?
In meeting the requirements of OSHA's Hazard Communication Standard, the temporary agency employer would, for example, be expected to provide generic hazard training and information concerning categories of chemicals employees may potentially encounter.
The HCS only applies to pharmaceuticals that the drug manufacturer has determined to be hazardous and that are known to be present in the workplace in such a manner that employees are exposed under normal conditions of use or in a foreseeable emergency.
The pharmaceutical manufacturer and the importer have the primary duty for the evaluation of chemical hazards.
If the employee's work area includes the area where the MSDSs can be obtained, then maintaining MSDSs on a computer would be in compliance.
If the MSDSs can be accessed only out of the employee's work area(s), then the employer would be out of compliance with paragraphs (g)(8) or (g)(9) [of the Hazard Communication Standard].
Hazard information must be transmitted on Material Safety Data Sheets (MSDSs) that must be distributed to the customer at the time of first shipment of the product.