Construction Safety

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Board Question

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Hazard Communication (Hazcom) training is required in all workplaces where hazardous chemicals are used (not just construction).

What has been your experience with Hazcom training? Did it meet the standard? Was it effective? Why?

If you have never participated in Hazcom training, discuss who you think should provide this training on a construction site. How should it be presented?

Unit Assessment

QUESTION 1

What is the difference between a permit-required confined space and a non-permit required confined space? Provide examples that illustrate the difference. Once employees are authorized to enter a permit-required space, what ongoing measures must be in place to ensure their continued safety?
Your response should be at least 200 words in length.

QUESTION 2

How do the primary requirements of the hazard communication standard (written program, safety data sheets, labeling of hazardous substances, and training) work together to keep workers informed of chemical hazards they encounter at work?
Your response should be at least 200 words in length.

Unit VII Research Paper

The Occupational Safety and Health Administration (OSHA) has identified four categories of hazards that account for more than 50% of all construction fatalities:

falls (36.5%),
struck-by object (10.1%), electrocutions (8.6%), and caught-in/between (2.5%).

The assignment is to write a research paper involving one of these four construction hazard categories. You may narrow your topic down to a more specific type of accident within the major category. For example, under falls, you could focus your research on falls from ladders. When writing the paper, consider the questions below.

1. What are the common causative factors?
2. What does data indicate?
3. What are the effective proven corrective measures?

The submission must be a minimum of three pages in length, not counting the title page or references page. A minimum of three scholarly sources must be used from the Waldorf Online Library. Scholarly sources include the ones listed below:

peer-reviewed journal articles (Click here to access a webinar outlining peer-reviewed articles.), safety reference books and textbooks, and
other publications by safety professionals and organizations (print or online).

Note that wikipedia.com, answers.com, ask.com, about.com, and similar broad-based Internet sites are not considered scholarly sources. Use government and professional safety-related sources, such as osha.gov, niosh.gov, asse.org, nsc.org, and nfpa.org. Contact your professor if you have any questions about the validity of a reference source.

APA format is required. Be sure to use in-text citations for direct quotes and paraphrased information.

SubpartAA―Confined Spaces in Construction

1926.1200 Reserved
1926.1201 Scope
1926.1202 Definitions
1926.1203 General requirements
1926.1204 Permit-required confined space program
1926.1205 Permitting process
1926.1206 Entry permit
1926.1207 Training
1926.1208 Duties of authorized entrants
1926.1209 Duties of attendants
1926.1210 Duties of entry supervisors
1926.1211 Rescue and emergency services
1926.1212 Employee participation
1926.1213 Provision of documents to Secretary

Authority: 40 U.S.C. 3701 et seq.; 29 U.S.C. 653, 655, 657; Secretary of Labor’s Order
No. 1-2012 (77 FR 3912); and 29 CFR Part 1911.

§1926.1201 Scope.

(a) This standard sets forth requirements for practices and procedures to protect

employees engaged in construction activities at a worksite with one or more
confined spaces, subject to the exceptions in paragraph (b) of this section.

Note to paragraph §1926.1201(a). Examples of locations where confined spaces may
occur include, but are not limited to, the following: Bins; boilers; pits (such as
elevator, escalator, pump, valve or other equipment); manholes (such as sewer,
storm drain, electrical, communication, or other utility); tanks (such as fuel,
chemical, water, or other liquid, solid or gas); incinerators; scrubbers; concrete pier
columns; sewers; transformer vaults; heating, ventilation, and air-conditioning
(HVAC) ducts; storm drains; water mains; precast concrete and other pre-formed
manhole units; drilled shafts; enclosed beams; vessels; digesters; lift stations;
cesspools; silos; air receivers; sludge gates; air preheaters; step up transformers;
turbines; chillers; bag houses; and/or mixers/reactors.

(b) Exceptions. This standard does not apply to: (1) Construction work regulated by

§1926 subpart P—Excavations. (2) Construction work regulated by §1926 subpart
S—Underground Construction, Caissons, Cofferdams and Compressed Air. (3)
Construction work regulated by §1926 subpart Y—Diving.

hazard in another applicable OSHA standard, the employer must comply with both
that requirement and the applicable provisions of this standard.

§1926.1202 Definitions.

The following terms are defined for the purposes of this subpart only:

Acceptable entry conditions means the conditions that must exist in a permit space,
before an employee may enter that space, to ensure that employees can safely enter into,
and safely work within, the space.

Attendant means an individual stationed outside one or more permit spaces who assesses
the status of authorized entrants and who must perform the duties specified in
§1926.1209.

Authorized entrant means an employee who is authorized by the entry supervisor to enter
a permit space.

Barrier means a physical obstruction that blocks or limits access.

Blanking or blinding means the absolute closure of a pipe, line, or duct by the fastening
of a solid plate (such as a spectacle blind or a skillet blind) that completely covers the
bore and that is capable of withstanding the maximum pressure of the pipe, line, or duct
with no leakage beyond the plate.

Competent person means one who is capable of identifying existing and predictable
hazards in the surroundings or working conditions which are unsanitary, hazardous, or
dangerous to employees, and who has the authorization to take prompt corrective
measures to eliminate them.

Confined space means a space that:

(1) Is large enough and so configured that an employee can bodily enter it;

(2) Has limited or restricted means for entry and exit; and

(3) Is not designed for continuous employee occupancy.

Control means the action taken to reduce the level of any hazard inside a confined space
using engineering methods (for example, by ventilation), and then using these methods to
maintain the reduced hazard level. Control also refers to the engineering methods used
for this purpose. Personal protective equipment is not a control.

Controlling Contractor is the employer that has overall responsibility for construction at
the worksite.

Note. If the controlling contractor owns or manages the property, then it is both a
controlling employer and a host employer.

Double block and bleed means the closure of a line, duct, or pipe by closing and locking
or tagging two in-line valves and by opening and locking or tagging a drain or vent valve
in the line between the two closed valves.

Early-warning system means the method used to alert authorized entrants and attendants
that an engulfment hazard may be developing. Examples of early-warning systems
include, but are not limited to: alarms activated by remote sensors; and lookouts with
equipment for immediately communicating with the authorized entrants and attendants.

Emergency means any occurrence (including any failure of power, hazard control or
monitoring equipment) or event, internal or external, to the permit space that could
endanger entrants.

Engulfment means the surrounding and effective capture of a person by a liquid or finely
divided (flowable) solid substance that can be aspirated to cause death by filling or
plugging the respiratory system or that can exert enough force on the body to cause death
by strangulation, constriction, crushing, or suffocation.

Entry means the action by which any part of a person passes through an opening into a
permit-required confined space. Entry includes ensuing work activities in that space and
is considered to have occurred as soon as any part of the entrant’s body breaks the plane
of an opening into the space, whether or not such action is intentional or any work
activities are actually performed in the space.

Entry Employer means any employer who decides that an employee it directs will enter a
permit space.

Note. An employer cannot avoid the duties of the standard merely by refusing to decide
whether its employees will enter a permit space, and OSHA will consider the failure to so
decide to be an implicit decision to allow employees to enter those spaces if they are
working in the proximity of the space.

Entry permit (permit) means the written or printed document that is provided by the
employer who designated the space a permit space to allow and control entry into a
permit space and that contains the information specified in §1926.1206 of this standard.

Entry rescue occurs when a rescue service enters a permit space to rescue one or more
employees.

Entry supervisor means the qualified person (such as the employer, foreman, or crew
chief) responsible for determining if acceptable entry conditions are present at a permit
space where entry is planned, for authorizing entry and overseeing entry operations, and
for terminating entry as required by this standard.

Note. An entry supervisor also may serve as an attendant or as an authorized entrant, as
long as that person is trained and equipped as required by this standard for each role he or
she fills. Also, the duties of entry supervisor may be passed from one individual to
another during the course of an entry operation.

Hazard means a physical hazard or hazardous atmosphere. See definitions below.

Hazardous atmosphere means an atmosphere that may expose employees to the risk of
death, incapacitation, impairment of ability to self-rescue (that is, escape unaided from a
permit space), injury, or acute illness from one or more of the following causes:

(1) Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable
limit (LFL);

(2) Airborne combustible dust at a concentration that meets or exceeds its LFL;

Note: This concentration may be approximated as a condition in which the
combustible dust obscures vision at a distance of 5 feet (1.52 meters) or less.

(3) Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent;

(4) Atmospheric concentration of any substance for which a dose or a permissible

exposure limit is published in Subpart D—Occupational Health and
Environmental Control, or in Subpart Z—Toxic and Hazardous Substances, of
this part and which could result in employee exposure in excess of its dose or
permissible exposure limit;

Note. An atmospheric concentration of any substance that is not capable of
causing death, incapacitation, impairment of ability to self-rescue, injury, or acute
illness due to its health effects is not covered by this definition.

(5) Any other atmospheric condition that is immediately dangerous to life or health.

Note. For air contaminants for which OSHA has not determined a dose or
permissible exposure limit, other sources of information, such as Safety Data
Sheets that comply with the Hazard Communication Standard, §1926.59 of this
part, published information, and internal documents can provide guidance in
establishing acceptable atmospheric conditions.

Host employer means the employer that owns or manages the property where the
construction work is taking place.

Note. If the owner of the property on which the construction activity occurs has
contracted with an entity for the general management of that property, and has transferred
to that entity the information specified in §1203(h)(1), OSHA will treat the contracted
management entity as the host employer for as long as that entity manages the property.
Otherwise, OSHA will treat the owner of the property as the host employer. In no case
will there be more than one host employer.

Hot work means operations capable of providing a source of ignition (for example,
riveting, welding, cutting, burning, and heating).

Immediately dangerous to life or health (IDLH) means any condition that would interfere
with an individual’s ability to escape unaided from a permit space and that poses a threat
to life or that would cause irreversible adverse health effects.

Note. Some materials—hydrogen fluoride gas and cadmium vapor, for example—may
produce immediate transient effects that, even if severe, may pass without medical
attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure.
The victim “feels normal” after recovery from transient effects until collapse. Such
materials in hazardous quantities are considered to be “immediately” dangerous to life or
health.

Inerting means displacing the atmosphere in a permit space by a noncombustible gas
(such as nitrogen) to such an extent that the resulting atmosphere is noncombustible.

Note. This procedure produces an IDLH oxygen-deficient atmosphere.

Isolate or isolation means the process by which employees in a confined space are
completely protected against the release of energy and material into the space, and
contact with a physical hazard, by such means as: blanking or blinding; misaligning or
removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or
tagout of all sources of energy; blocking or disconnecting all mechanical linkages; or
placement of barriers to eliminate the potential for employee contact with a physical
hazard.

Limited or restricted means for entry or exit means a condition that has a potential to
impede an employee’s movement into or out of a confined space. Such conditions
include, but are not limited to, trip hazards, poor illumination, slippery floors, inclining
surfaces and ladders.

Line breaking means the intentional opening of a pipe, line, or duct that is or has been
carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume,
pressure, or temperature capable of causing injury.

Lockout means the placement of a lockout device on an energy isolating device, in
accordance with an established procedure, ensuring that the energy isolating device and
the equipment being controlled cannot be operated until the lockout device is removed.

Lower flammable limit or lower explosive limit means the minimum concentration of a
substance in air needed for an ignition source to cause a flame or explosion.

Monitor or monitoring means the process used to identify and evaluate the hazards after
an authorized entrant enters the space. This is a process of checking for changes that is
performed in a periodic or continuous manner after the completion of the initial testing or
evaluation of that space.

Non-entry rescue occurs when a rescue service, usually the attendant, retrieves
employees in a permit space without entering the permit space.

Non-permit confined space means a confined space that meets the definition of a
confined space but does not meet the requirements for a permit-required confined space,
as defined in this subpart.

Oxygen deficient atmosphere means an atmosphere containing less than 19.5 percent
oxygen by volume.

Oxygen enriched atmosphere means an atmosphere containing more than 23.5 percent
oxygen by volume.

Permit-required confined space (permit space) means a confined space that has one or
more of the following characteristics: (1) Contains or has a potential to contain a
hazardous atmosphere; (2) Contains a material that has the potential for engulfing an
entrant; (3) Has an internal configuration such that an entrant could be trapped or
asphyxiated by inwardly converging walls or by a floor which slopes downward and
tapers to a smaller cross-section; or (4) Contains any other recognized serious safety or
health hazard.

Permit-required confined space program (permit space program) means the employer’s
overall program for controlling, and, where appropriate, for protecting employees from,
permit space hazards and for regulating employee entry into permit spaces.

Physical hazard means an existing or potential hazard that can cause death or serious
physical damage. Examples include, but are not limited to: explosives (as defined by

paragraph (n) of §1926.914, definition of “explosive”); mechanical, electrical, hydraulic
and pneumatic energy; radiation; temperature extremes; engulfment; noise; and inwardly
converging surfaces. Physical hazard also includes chemicals that can cause death or
serious physical damage through skin or eye contact (rather than through inhalation).

Prohibited condition means any condition in a permit space that is not allowed by the
permit during the period when entry is authorized. A hazardous atmosphere is a
prohibited condition unless the employer can demonstrate that personal protective
equipment (PPE) will provide effective protection for each employee in the permit space
and provides the appropriate PPE to each employee.

Qualified person means one who, by possession of a recognized degree, certificate, or
professional standing, or who by extensive knowledge, training, and experience, has
successfully demonstrated his ability to solve or resolve problems relating to the subject
matter, the work, or the project.

Representative permit space means a mock-up of a confined space that has entrance
openings that are similar to, and is of similar size, configuration, and accessibility to, the
permit space that authorized entrants enter.

Rescue means retrieving, and providing medical assistance to, one or more employees
who are in a permit space.

Rescue service means the personnel designated to rescue employees from permit spaces.

Retrieval system means the equipment (including a retrieval line, chest or full body
harness, wristlets or anklets, if appropriate, and a lifting device or anchor) used for non-
entry rescue of persons from permit spaces.

Serious physical damage means an impairment or illness in which a body part is made
functionally useless or is substantially reduced in efficiency. Such impairment or illness
may be permanent or temporary and includes, but is not limited to, loss of consciousness,
disorientation, or other immediate and substantial reduction in mental efficiency. Injuries
involving such impairment would usually require treatment by a physician or other
licensed health-care professional.

Tagout means:(1) Placement of a tagout device on a circuit or equipment that has been
deenergized, in accordance with an established procedure, to indicate that the circuit or
equipment being controlled may not be operated until the tagout device is removed; and
(2) The employer ensures that (i) tagout provides equivalent protection to lockout, or (ii)
that lockout is infeasible and the employer has relieved, disconnected, restrained and
otherwise rendered safe stored (residual) energy.

Test or testing means the process by which the hazards that may confront entrants of a
permit space are identified and evaluated. Testing includes specifying the tests that are to
be performed in the permit space.

Note. Testing enables employers both to devise and implement adequate control
measures for the protection of authorized entrants and to determine if acceptable entry
conditions are present immediately prior to, and during, entry.

Ventilate or ventilation means controlling a hazardous atmosphere using continuous
forced-air mechanical systems that meet the requirements of §1926.57—Ventilation.

§1926.1203 General requirements.

(a) Before it begins work at a worksite, each employer must ensure that a competent

person identifies all confined spaces in which one or more of the employees it directs
may work, and identifies each space that is a permit space, through consideration
and evaluation of the elements of that space, including testing as necessary.

(b) If the workplace contains one or more permit spaces, the employer who identifies, or

who receives notice of, a permit space must:

(1) Inform exposed employees by posting danger signs or by any other equally

effective means, of the existence and location of, and the danger posed by, each
permit

space; and

Note to paragraph §1926.1203(b)(1). A sign reading “DANGER — PERMIT-
REQUIRED CONFINED SPACE, DO NOT ENTER” or using other similar
language would satisfy the requirement for a sign.

(2) Inform, in a timely manner and in a manner other than posting, its employees’
authorized representatives and the controlling contractor of the existence and
location of, and the danger posed by, each permit space.

authorized employees it directs to work in that space must take effective measures to
prevent those employees from entering that permit space, in addition to complying
with all other applicable requirements of this standard.

(d) If any employer decides that employees it directs will enter a permit space, that

employer must have a written permit space program that complies with §1926.1204
implemented at the construction site. The written program must be made available
prior to and during entry operations for inspection by employees and their authorized

representatives.

(e) An employer may use the alternate procedures specified in paragraph
§1926.1203(e)(2) for entering a permit space only under the conditions set forth in
paragraph §1926.1203(e)(1).

(1) An employer whose employees enter a permit space need not comply with

§§1926.1204 through 1206 and §§1926.1208 through 1211, provided that all of
the following conditions are met:

(i) The employer can demonstrate that all physical hazards in the space are

eliminated or isolated through engineering controls so that the only hazard
posed by the permit space is an actual or potential hazardous atmosphere;

(ii) The employer can demonstrate that continuous forced air ventilation alone
is sufficient to maintain that permit space safe for entry, and that, in the
event the ventilation system stops working, entrants can exit the space
safely;

(iii) The employer develops monitoring and inspection data that supports the
demonstrations required by paragraphs §1926.1203(e)(1)(i) and
§1926.1203(e)(1)(ii);

(iv) If an initial entry of the permit space is necessary to obtain the data
required by paragraph §1926.1203(e)(1)(iii), the entry is performed in
compliance with §§1926.1204 through 1211 of this standard;

(v) The determinations and supporting data required by paragraphs

§1926.1203(e)(1)(i), (e)(1)(ii), and (e)(1)(iii) are documented by the
employer and are made available to each employee who enters the permit
space under the terms of paragraph §1926.1203(e) or to that employee’s
authorized representative; and

(vi) Entry into the permit space under the terms of paragraph §1926.1203(e)(1)
is performed in accordance with the requirements of paragraph
§1926.1203(e)(2).

Note to paragraph §1926.1203(e)(1). See paragraph §1926.1203(g) for
reclassification of a permit space after all hazards within the space have
been eliminated.

(2) The following requirements apply to entry into permit spaces that meet the
conditions set forth in paragraph §1926.1203(e)(1):

(i) Any conditions making it unsafe to remove an entrance cover must be

eliminated before the cover is removed.

(ii) When entrance covers are removed, the opening must be immediately
guarded by a railing, temporary cover, or other temporary barrier that will
prevent an accidental fall through the opening and that will protect each
employee working in the space from foreign objects entering the space.

(iii) Before an employee enters the space, the internal atmosphere must be
tested, with a calibrated direct-reading instrument, for oxygen content, for
flammable gases and vapors, and for potential toxic air contaminants, in
that order. Any employee who enters the space, or that employee’s
authorized representative, must be provided an opportunity to observe the
pre-entry testing required by this paragraph.

(iv) No hazardous atmosphere is permitted within the space whenever any
employee is inside the space.

(v) Continuous forced air ventilation must be used, as follows:

(A) An employee must not enter the space until the forced air ventilation

has eliminated any hazardous atmosphere;

(B) The forced air ventilation must be so directed as to ventilate the

immediate areas where an employee is or will be present within the
space and must continue until all employees have left the space;

source and must not increase the hazards in the space.

(vi) The atmosphere within the space must be continuously monitored unless
the entry employer can demonstrate that equipment for continuous
monitoring is not commercially available or periodic monitoring is
sufficient. If continuous monitoring is used, the employer must ensure that
the monitoring equipment has an alarm that will notify all entrants if a
specified atmospheric threshold is achieved, or that an employee will
check the monitor with sufficient frequency to ensure that entrants have
adequate time to escape. If continuous monitoring is not used, periodic
monitoring is required. All monitoring must ensure that the continuous
forced air ventilation is preventing the accumulation of a hazardous
atmosphere. Any employee who enters the space, or that employee’s

authorized representative, must be provided with an opportunity to
observe the testing required by this paragraph.

(vii) If a hazard is detected during entry:

(A) Each employee must leave the space immediately;

(B) The space must be evaluated to determine how the hazard developed;

and

the hazard before any subsequent entry takes place.

(viii) The employer must ensure a safe method of entering and exiting the space.
If a hoisting system is used, it must be designed and manufactured for
personnel hoisting; however, a job-made hoisting system is permissible if
it is approved for personnel hoisting by a registered professional engineer,
in writing, prior to use.

(ix) The employer must verify that the space is safe for entry and that the pre-
entry measures required by paragraph §1926.1203(e)(2) have been taken,
through a written certification that contains the date, the location of the
space, and the signature of the person providing the certification. The
certification must be made before entry and must be made available to
each employee entering the space or to that employee’s authorized
representative.

(f) When there are changes in the use or configuration of a non-permit confined space
that might increase the hazards to entrants, or some indication that the initial
evaluation of the space may not have been adequate, each entry employer must have
a competent person reevaluate that space and, if necessary, reclassify it as a permit-
required confined space.

(g) A space classified by an employer as a permit-required confined space may only be
reclassified as a non-permit confined space when a competent person determines that
all of the applicable requirements in paragraphs §1926.1203(g)(1) through (g)(4)
have been met:

(1) If the permit space poses no actual or potential atmospheric hazards and if all

hazards within the space are eliminated or isolated without entry into the space
(unless the employer can demonstrate that doing so without entry is infeasible),
the permit space may be reclassified as a non-permit confined space for as long
as the non-atmospheric hazards remain eliminated or isolated;

(2) The entry employer must eliminate or isolate the hazards without entering the

space, unless it can demonstrate that this is infeasible. If it is necessary to enter
the permit space to eliminate or isolate hazards, such entry must be performed
under §§1926.1204 through 1211 of this standard. If testing and inspection
during that entry demonstrate that the hazards within the permit space have been
eliminated or isolated, the permit space may be reclassified as a non-permit
confined space for as long as the hazards remain eliminated or isolated;

Note to paragraph §1926.1203(g)(2). Control of atmospheric hazards through
forced air ventilation does not constitute elimination or isolation of the hazards.
Paragraph §1926.1203(e) covers permit space entry where the employer can
demonstrate that forced air ventilation alone will control all hazards in the
space.

(3) The entry employer must document the basis for determining that all hazards in
a permit space have been eliminated or isolated, through a certification that
contains the date, the location of the space, and the signature of the person
making the determination. The certification must be made available to each
employee entering the space or to that employee’s authorized representative;
and

(4) If hazards arise within a permit space that has been reclassified as a non-permit
space under paragraph §1926.1203(g), each employee in the space must exit the
space. The entry employer must then reevaluate the space and reclassify it as a
permit space as appropriate in accordance with all other applicable provisions of
this standard.

(h) Permit Space Entry Communication and Coordination:

(1) Before entry operations begin, the host employer must provide the following

information, if it has it, to the controlling contractor:

(i) The location of each known permit space;

(ii) The hazards or potential hazards in each space or the reason it is a permit

space; and

(iii) Any precautions that the host employer or any previous controlling
contractor or entry employer implemented for the protection of employees
in the permit space.

(2) Before entry operations begin, the controlling contractor must:

(i) Obtain the host employer’s information about the permit space hazards

and previous entry operations; and

(ii) Provide the following information to each entity entering a permit space
and any other entity at the worksite whose activities could foreseeably
result in a hazard in the permit space:

(A) The information received from the host employer;

(B) Any additional information the controlling contractor has about the

subjects listed in paragraph (h)(1) of this section; and

(C) The precautions that the host employer, controlling contractor, or
other entry employers implemented for the protection of employees in
the permit spaces.

(3) Before entry operations begin, each entry employer must:

(i) Obtain all of the controlling contractor’s information regarding permit

space hazards and entry operations; and

(ii) Inform the controlling contractor of the permit space program that the
entry employer will follow, including any hazards likely to be confronted
or created in each permit space.

(4) The controlling contractor and entry employer(s) must coordinate entry

operations when:

(i) More than one entity performs permit space entry at the same time; or

(ii) Permit space entry is performed at the same time that any activities that

could foreseeably result in a hazard in the permit space are performed.

(5) After entry operations:

(i) The controlling contractor must debrief each entity that entered a permit
space regarding the permit space program followed and any hazards
confronted or created in the permit space(s) during entry operations;

(ii) The entry employer must inform the controlling contractor in a timely
manner of the permit space program followed and of any hazards
confronted or created in the permit space(s) during entry operations; and

(iii) The controlling contractor must apprise the host employer of the

information exchanged with the entry entities pursuant to this
subparagraph.

Note to paragraph §1926.1203(h). Unless a host employer or controlling
contractor has or will have employees in a confined space, it is not
required to enter any confined space to collect the information specified in
this paragraph (h).

(iv) If there is no controlling contractor present at the worksite, the
requirements for, and role of, controlling contactors in §1926.1203 must
be fulfilled by the host employer or other employer who arranges to have
employees of another employer perform work that involves permit space
entry.

§1926.1204 Permit-Required Confined Space Program.

Each entry employer must:

(a) Implement the measures necessary to prevent unauthorized entry;

(b) Identify and evaluate the hazards of permit spaces before employees enter them;

permit space entry operations, including, but not limited to, the following:

(1) Specifying acceptable entry conditions;

(2) Providing each authorized entrant or that employee’s authorized representative

with the opportunity to observe any monitoring or testing of permit spaces;

(3) Isolating the permit space and physical hazard(s) within the

space;

(4) Purging, inerting, flushing, or ventilating the permit space as necessary to

eliminate or control atmospheric hazards;

Note to paragraph §1204(c)(4). When an employer is unable to reduce the
atmosphere below 10 percent LFL, the employer may only enter if the employer
inerts the space so as to render the entire atmosphere in the space non-
combustible, and the employees use PPE to address any other atmospheric
hazards (such as oxygen deficiency), and the employer eliminates or isolates all
physical hazards in the space.

(5) Determining that, in the event the ventilation system stops working, the

monitoring procedures will detect an increase in atmospheric hazard levels in
sufficient time for the entrants to safely exit the permit space;

(6) Providing pedestrian, vehicle, or other barriers as necessary to protect entrants
from external hazards;

(7) Verifying that conditions in the permit space are acceptable for entry throughout
the duration of an authorized entry, and ensuring that employees are not allowed
to enter into, or remain in, a permit space with a hazardous atmosphere unless
the employer can demonstrate that personal protective equipment (PPE) will
provide effective protection for each employee in the permit space and provides
the appropriate PPE to each employee; and

(8) Eliminating any conditions (for example, high pressure) that could make it
unsafe to remove an entrance cover.

(d) Provide the following equipment (specified in paragraphs §1926.1204(d)(1) through
(d)(9)) at no cost to each employee, maintain that equipment properly, and ensure
that each employee uses that equipment properly:

(1) Testing and monitoring equipment needed to comply with paragraph

§1926.1204(e);

(2) Ventilating equipment needed to obtain acceptable entry conditions;

(3) Communications equipment necessary for compliance with paragraphs
§1926.1208(c) and §1926.1209(e), including any necessary electronic
communication equipment for attendants assessing entrants’ status in multiple
spaces;

(4) Personal protective equipment insofar as feasible engineering and work-practice
controls do not adequately protect employees;

Note to paragraph §1926.1204(d)(4). The requirements of subpart E of this part
and other PPE requirements continue to apply to the use of PPE in a permit
space. For example, if employees use respirators, then the respirator
requirements in §1926.103 (Respiratory protection) must be met.

(5) Lighting equipment that meets the minimum illumination requirements in
§1926.56, that is approved for the ignitable or combustible properties of the
specific gas, vapor, dust, or fiber that will be present, and that is sufficient to

enable employees to see well enough to work safely and to exit the space
quickly in an emergency;

(6) Barriers and shields as required by paragraph §1926.1204(c)(4);

(7) Equipment, such as ladders, needed for safe ingress and egress by authorized
entrants;

(8) Rescue and emergency equipment needed to comply with paragraph
§1926.1204(i), except to the extent that the equipment is provided by rescue
services; and

(9) Any other equipment necessary for safe entry into, safe exit from, and rescue
from, permit spaces.

(e) Evaluate permit space conditions in accordance with the following paragraphs (e)(1)

through (6) of this section when entry operations are conducted:

(1) Test conditions in the permit space to determine if acceptable entry conditions

exist before changes to the space’s natural ventilation are made, and before
entry is authorized to begin, except that, if an employer demonstrates that
isolation of the space is infeasible because the space is large or is part of a
continuous system (such as a sewer), the employer must:

(i) Perform pre-entry testing to the extent feasible before entry is authorized;

and,

(ii) If entry is authorized, continuously monitor entry conditions in the areas
where authorized entrants are working, except that employers may use
periodic monitoring in accordance with paragraph §1926.1204(e)(2) for
monitoring an atmospheric hazard if they can demonstrate that equipment
for continuously monitoring that hazard is not commercially available;

(iii) Provide an early-warning system that continuously monitors for non-
isolated engulfment hazards. The system must alert authorized entrants
and attendants in sufficient time for the authorized entrants to safely exit
the space.

(2) Continuously monitor atmospheric hazards unless the employer can
demonstrate that the equipment for continuously monitoring a hazard is not
commercially available or that periodic monitoring is of sufficient frequency to
ensure that the atmospheric hazard is being controlled at safe levels. If
continuous monitoring is not used, periodic monitoring is required with

sufficient frequency to ensure that acceptable entry conditions are being
maintained during the course of entry operations;

(3) When testing for atmospheric hazards, test first for oxygen, then for
combustible gases and vapors, and then for toxic gases and vapors;

(4) Provide each authorized entrant or that employee’s authorized representative an
opportunity to observe the pre-entry and any subsequent testing or monitoring
of permit spaces;

(5) Reevaluate the permit space in the presence of any authorized entrant or that
employee’s authorized representative who requests that the employer conduct
such reevaluation because there is some indication that the evaluation of that
space may not have been adequate; and

(6) Immediately provide each authorized entrant or that employee’s authorized
representative with the results of any testing conducted in accordance with
§1926.1204 of this standard.

(f) Provide at least one attendant outside the permit space into which entry is authorized
for the duration of entry operations;

(1) Attendants may be assigned to more than one permit space provided the duties

described in §1926.1209 of this standard can be effectively performed for each
permit space.

(2) Attendants may be stationed at any location outside the permit space as long as
the duties described in §1926.1209 of this standard can be effectively performed
for each permit space to which the attendant is assigned.

(g) If multiple spaces are to be assigned to a single attendant, include in the permit
program the means and procedures to enable the attendant to respond to an
emergency affecting one or more of those permit spaces without distraction from the
attendant’s responsibilities under §1926.1209 of this standard;

(h) Designate each person who is to have an active role (as, for example, authorized
entrants, attendants, entry supervisors, or persons who test or monitor the
atmosphere in a permit space) in entry operations, identify the duties of each such
employee, and provide each such employee with the training required by
§1926.1207 of this standard;

(i) Develop and implement procedures for summoning rescue and emergency services
(including procedures for summoning emergency assistance in the event of a failed

non-entry rescue), for rescuing entrants from permit spaces, for providing necessary
emergency services to rescued employees, and for preventing unauthorized
personnel from attempting a rescue;

(j) Develop and implement a system for the preparation, issuance, use, and cancellation
of entry permits as required by this standard, including the safe termination of entry
operations under both planned and emergency conditions;

(k) Develop and implement procedures to coordinate entry operations, in consultation
with the controlling contractor, when employees of more than one employer are
working simultaneously in a permit space or elsewhere on the worksite where their
activities could, either alone or in conjunction with the activities within a permit
space, foreseeably result in a hazard within the confined space, so that employees of
one employer do not endanger the employees of any other employer;

(l) Develop and implement procedures (such as closing off a permit space and canceling
the permit) necessary for concluding the entry after entry operations have been
completed;

(m) Review entry operations when the measures taken under the permit space program
may not protect employees and revise the program to correct deficiencies found to
exist before subsequent entries are authorized; and

Note to paragraph §1926.1204(m). Examples of circumstances requiring the review
of the permit space program include, but are not limited to: any unauthorized entry
of a permit space, the detection of a permit space hazard not covered by the permit,
the detection of a condition prohibited by the permit, the occurrence of an injury or
near-miss during entry, a change in the use or configuration of a permit space, and
employee complaints about the effectiveness of the program.

(n) Review the permit space program, using the canceled permits retained under
paragraph §1926.1205(f), within 1 year after each entry and revise the program as
necessary to ensure that employees participating in entry operations are protected
from permit space hazards.

Note to paragraph §1926.1204(n). Employers may perform a single annual review
covering all entries performed during a 12-month period. If no entry is performed
during a 12-month period, no review is necessary.

§1926.1205 Permitting Process.

(a) Before entry is authorized, each entry employer must document the completion of
measures required by paragraph §1926.1204(c) of this standard by preparing an
entry permit.

(b) Before entry begins, the entry supervisor identified on the permit must sign the entry
permit to authorize entry.

(c) The completed permit must be made available at the time of entry to all authorized
entrants or their authorized representatives, by posting it at the entry portal or by any
other equally effective means, so that the entrants can confirm that pre-entry
preparations have been completed.

(d) The duration of the permit may not exceed the time required to complete the
assigned task or job identified on the permit in accordance with paragraph
§1926.1206(b) of this standard.

(e) The entry supervisor must terminate entry and take the following action when any of
the following apply:

(1) Cancel the entry permit when the entry operations covered by the entry permit

have been completed; or

(2) Suspend or cancel the entry permit and fully reassess the space before allowing
reentry when a condition that is not allowed under the entry permit arises in or
near the permit space and that condition is temporary in nature and does not
change the configuration of the space or create any new hazards within it; and

(3) Cancel the entry permit when a condition that is not allowed under the entry
permit arises in or near the permit space and that condition is not covered by
subparagraph (e)(2) of this section.

(f) The entry employer must retain each canceled entry permit for at least 1 year to

facilitate the review of the permit-required confined space program required by
paragraph §1926.1204(n) of this standard. Any problems encountered during an
entry operation must be noted on the pertinent permit so that appropriate revisions to
the permit space program can be made.

§1926.1206 Entry permit.

The entry permit that documents compliance with this section and authorizes entry to a
permit space must identify:

(a) The permit space to be entered;

(b) The purpose of the entry;

(d) The authorized entrants within the permit space, by name or by such other

means (for example, through the use of rosters or tracking systems) as will enable
the attendant to determine quickly and accurately, for the duration of the permit,
which authorized entrants are inside the permit space;

Note to paragraph §1926.1206(d). This requirement may be met by inserting a
reference on the entry permit as to the means used, such as a roster or tracking
system, to keep track of the authorized entrants within the permit space.

(e) Means of detecting an increase in atmospheric hazard levels in the event the
ventilation system stops working;

(f) Each person, by name, currently serving as an attendant;

(g) The individual, by name, currently serving as entry supervisor, and the signature or
initials of each entry supervisor who authorizes entry;

(h) The hazards of the permit space to be entered;

(i) The measures used to isolate the permit space and to eliminate or control permit
space hazards before entry;

Note to paragraph §1926.1206(i). Those measures can include, but are not limited to,
the lockout or tagging of equipment and procedures for purging, inerting, ventilating,
and flushing permit spaces.

(j) The acceptable entry conditions;

(k) The results of tests and monitoring performed under paragraph §1926.1204(e) of this
standard, accompanied by the names or initials of the testers and by an indication of
when the tests were performed;

(l) The rescue and emergency services that can be summoned and the means (such as
the equipment to use and the numbers to call) for summoning those services;

(m) The communication procedures used by authorized entrants and attendants to
maintain contact during the entry;

(n) Equipment, such as personal protective equipment, testing equipment,
communications equipment, alarm systems, and rescue equipment, to be provided
for compliance with this standard;

(o) Any other information necessary, given the circumstances of the particular confined
space, to ensure employee safety; and

(p) Any additional permits, such as for hot work, that have been issued to authorize
work in the permit space.

§1926.1207 Training.

(a) The employer must provide training to each employee whose work is regulated by

this standard, at no cost to the employee, and ensure that the employee possesses the
understanding, knowledge, and skills necessary for the safe performance of the
duties assigned under this standard. This training must result in an understanding of
the hazards in the permit space and the methods used to isolate, control or in other
ways protect employees from these hazards, and for those employees not authorized
to perform entry rescues, in the dangers of attempting such rescues.

(b) Training required by this section must be provided to each affected employee:

(1) In both a language and vocabulary that the employee can understand;

(2) Before the employee is first assigned duties under this standard;

(3) Before there is a change in assigned duties;

(4) Whenever there is a change in permit space entry operations that presents a
hazard about which an employee has not previously been trained; and

(5) Whenever there is any evidence of a deviation from the permit space entry
procedures required by paragraph §1926.1204(c) of this standard or there are
inadequacies in the employee’s knowledge or use of these procedures.

standard and must introduce new or revised procedures, as necessary, for compliance
with this standard.

(d) The employer must maintain training records to show that the training required by
paragraphs §1926.1207(a) through (c) of this standard has been accomplished. The
training records must contain each employee’s name, the name of the trainers, and
the dates of training. The documentation must be available for inspection by

employees and their authorized representatives, for the period of time the employee
is employed by that employer.

§1926.1208 Duties of authorized entrants.

The entry employer must ensure that all authorized entrants:

(a) Are familiar with and understand the hazards that may be faced during entry,

including information on the mode, signs or symptoms, and consequences of the
exposure;

(b) Properly use equipment as required by paragraph §1926.1204(d) of this standard;

(c) Communicate with the attendant as necessary to enable the attendant to assess
entrant status and to enable the attendant to alert entrants of the need to evacuate the
space as required by paragraph §1926.1209(f) of this standard;

(d) Alert the attendant whenever:

(1) There is any warning sign or symptom of exposure to a dangerous situation; or

(2) The entrant detects a prohibited condition; and

(e) Exit from the permit space as quickly as possible whenever:

(1) An order to evacuate is given by the attendant or the entry supervisor;

(2) There is any warning sign or symptom of exposure to a dangerous situation;

(3) The entrant detects a prohibited condition; or

(4) An evacuation alarm is activated.

§1926.1209 Duties of attendants.

The entry employer must ensure that each attendant:

(a) Is familiar with and understands the hazards that may be faced during entry,

including information on the mode, signs or symptoms, and consequences of the
exposure;

(b) Is aware of possible behavioral effects of hazard exposure in authorized entrants;

(c) Continuously maintains an accurate count of authorized entrants in the permit space
and ensures that the means used to identify authorized entrants under paragraph
1926.1206(d) of this standard accurately identifies who is in the permit space;

(d) Remains outside the permit space during entry operations until relieved by another
attendant;

Note to paragraph §1926.1209(d). Once an attendant has been relieved by another
attendant, the relieved attendant may enter a permit space to attempt a rescue when
the employer’s permit space program allows attendant entry for rescue and the
attendant has been trained and equipped for rescue operations as required by
paragraph §1926.1211(a).

(e) Communicates with authorized entrants as necessary to assess entrant status and to
alert entrants of the need to evacuate the space under paragraph §1926.1208(e);

(f) Assesses activities and conditions inside and outside the space to determine if it is
safe for entrants to remain in the space and orders the authorized entrants to evacuate
the permit space immediately under any of the following conditions:

(1) If there is a prohibited condition;

(2) If the behavioral effects of hazard exposure are apparent in an authorized

entrant;

(3) If there is a situation outside the space that could endanger the authorized
entrants; or

(4) If the attendant cannot effectively and safely perform all the duties required
under §1926.1209 of this standard;

(g) Summons rescue and other emergency services as soon as the attendant determines

that authorized entrants may need assistance to escape from permit space hazards;

(h) Takes the following actions when unauthorized persons approach or enter a permit
space while entry is underway:

(1) Warns the unauthorized persons that they must stay away from the permit

space;

(2) Advises the unauthorized persons that they must exit immediately if they have
entered the permit space; and

(3) Informs the authorized entrants and the entry supervisor if unauthorized persons
have entered the permit space;

(i) Performs non-entry rescues as specified by the employer’s rescue procedure; and

(j) Performs no duties that might interfere with the attendant’s primary duty to assess

and protect the authorized entrants.

§1926.1210 Duties of entry supervisors.

The entry employer must ensure that each entry supervisor:

(a) Is familiar with and understands the hazards that may be faced during entry,

including information on the mode, signs or symptoms, and consequences of the
exposure;

(b) Verifies, by checking that the appropriate entries have been made on the permit, that
all tests specified by the permit have been conducted and that all procedures and
equipment specified by the permit are in place before endorsing the permit and
allowing entry to begin;

(d) Verifies that rescue services are available and that the means for summoning them
are operable, and that the employer will be notified as soon as the services become
unavailable;

(e) Removes unauthorized individuals who enter or who attempt to enter the permit
space during entry operations; and

(f) Determines, whenever responsibility for a permit space entry operation is
transferred, and at intervals dictated by the hazards and operations performed within
the space, that entry operations remain consistent with terms of the entry permit and
that acceptable entry conditions are maintained.

§1926.1211 Rescue and emergency services.

(a) An employer who designates rescue and emergency services, pursuant to paragraph

§1926.1204(i) of this standard, must:

(1) Evaluate a prospective rescuer’s ability to respond to a rescue summons in a

timely manner, considering the hazard(s) identified;

Note to paragraph §1926.1211(a)(1). What will be considered timely will vary
according to the specific hazards involved in each entry. For example,
§1926.103—Respiratory Protection requires that employers provide a standby
person or persons capable of immediate action to rescue employee(s) wearing
respiratory protection while in work areas defined as IDLH atmospheres.

(2) Evaluate a prospective rescue service’s ability, in terms of proficiency with
rescue-related tasks and equipment, to function appropriately while rescuing
entrants from the particular permit space or types of permit spaces identified;

(3) Select a rescue team or service from those evaluated that:

(i) Has the capability to reach the victim(s) within a time frame that is
appropriate for the permit space hazard(s) identified;

(ii) Is equipped for, and proficient in, performing the needed rescue services;

(iii) Agrees to notify the employer immediately in the event that the rescue
service becomes unavailable;

(4) Inform each rescue team or service of the hazards they may confront when

called on to perform rescue at the site; and

(5) Provide the rescue team or service selected with access to all permit spaces from
which rescue may be necessary so that the rescue team or service can develop
appropriate rescue plans and practice rescue operations.

(b) An employer whose employees have been designated to provide permit space rescue
and/or emergency services must take the following measures and provide all
equipment and training at no cost to those employees:

(1) Provide each affected employee with the personal protective equipment (PPE)

needed to conduct permit space rescues safely and train each affected employee
so the employee is proficient in the use of that PPE;

(2) Train each affected employee to perform assigned rescue duties. The employer
must ensure that such employees successfully complete the training required
and establish proficiency as authorized entrants, as provided by §§1926.1207
and 1926.1208 of this standard;

(3) Train each affected employee in basic first aid and cardiopulmonary
resuscitation (CPR). The employer must ensure that at least one member of the

rescue team or service holding a current certification in basic first aid and CPR
is available; and

(4) Ensure that affected employees practice making permit space rescues before
attempting an actual rescue, and at least once every 12 months, by means of
simulated rescue operations in which they remove dummies, manikins, or actual
persons from the actual permit spaces or from representative permit spaces,
except practice rescue is not required where the affected employees properly
performed a rescue operation during the last 12 months in the same permit space
the authorized entrant will enter, or in a similar permit space. Representative
permit spaces must, with respect to opening size, configuration, and
accessibility, simulate the types of permit spaces from which rescue is to be
performed.

overall risk of entry or would not contribute to the rescue of the entrant. The
employer must designate an entry rescue service whenever non-entry rescue is not
selected. Whenever non-entry rescue is selected, the entry employer must ensure that
retrieval systems or methods are used whenever an authorized entrant enters a permit
space, and must confirm, prior to entry, that emergency assistance would be
available in the event that non-entry rescue fails. Retrieval systems must meet the
following requirements:

(1) Each authorized entrant must use a chest or full body harness, with a retrieval

line attached at the center of the entrant’s back near shoulder level, above the
entrant’s head, or at another point which the employer can establish presents a
profile small enough for the successful removal of the entrant. Wristlets or
anklets may be used in lieu of the chest or full body harness if the employer can
demonstrate that the use of a chest or full body harness is infeasible or creates a
greater hazard and that the use of wristlets or anklets is the safest and most
effective alternative.

(2) The other end of the retrieval line must be attached to a mechanical device or
fixed point outside the permit space in such a manner that rescue can begin as
soon as the rescuer becomes aware that rescue is necessary. A mechanical
device must be available to retrieve personnel from vertical type permit spaces
more than 5 feet (1.52 meters) deep.

(3) Equipment that is unsuitable for retrieval must not be used, including, but not
limited to, retrieval lines that have a reasonable probability of becoming
entangled with the retrieval lines used by other authorized entrants, or retrieval
lines that will not work due to the internal configuration of the permit space.

(d) If an injured entrant is exposed to a substance for which a Safety Data Sheet (SDS)
or other similar written information is required to be kept at the worksite, that SDS
or written information must be made available to the medical facility treating the
exposed entrant.

§1926.1212 Employee participation.

(a) Employers must consult with affected employees and their authorized

representatives on the development and implementation of all aspects of the permit
space program required by §1926.1203 of this standard.

(b) Employers must make available to each affected employee and his/her authorized

representatives all information required to be developed by this standard.

§1926.1213 Provision of documents to Secretary.

For each document required to be retained in this standard, the retaining employer must
make the document available on request to the Secretary of Labor or the Secretary’s
designee.

FactSheet
Confined Spaces in Construction:
Sewer Systems
Confined spaces can present conditions that are immediately dangerous to workers
if such conditions are not properly identified, evaluated, tested, and controlled. This
fact sheet highlights many of the confined space hazards associated with sewer
systems and how employers can protect workers in these environments.

OSHA has developed a new construction standard
for Confined Spaces (29 CFR 1926 Subpart AA)—
any space that meets the following three criteria:

• Is large enough for a worker to enter it;
• Has limited means of entry or exit; and
• Is not designed for continuous occupancy.

A space may also be a permit-required confined
space if it has a hazardous atmosphere, the potential
for engulfment or suffocation, a layout that might
trap a worker through converging walls or a sloped
floor, or any other serious safety or health hazard.

Fatal Incidents
Confined space hazards in sewer systems have
led to worker deaths. Several tragic incidents in
sewers have included:

• A worker who lost consciousness and died
when he climbed into a sewer vault to retrieve a
tool. His co-worker also died when he attempted
a rescue.

• While repairing a natural gas leak, a worker
entered a drainage pipe to retrieve survey
equipment. The natural gas ignited, killing
the worker.

Training
The new Confined Spaces standard requires
employers to ensure that their workers know about
the existence, location, and dangers posed by each
permit-required confined space, and that they may
not enter such spaces without authorization.

Employers must train workers involved in permit-
required confined space operations so that they
can perform their duties safely and understand the
hazards in permit spaces and the methods used
to isolate, control or protect workers. Workers
not authorized to perform entry rescues must be
trained on the dangers of attempting such rescues.

Safe Entry Requirements
The new Confined Spaces standard includes
several requirements for safe entry.

Preparation: Before workers can enter a confined
space, employers must provide pre-entry planning.
This includes:

• Having a competent person evaluate the
work site for the presence of confined spaces,
including permit-required confined spaces.

• Once the space is classified as a permit-required
confined space, identifying the means of entry and
exit, proper ventilation methods, and elimination
or control of all potential hazards in the space.

• Ensuring that the air in a confined space is tested,
before workers enter, for oxygen levels, flammable
and toxic substances, and stratified atmospheres.

• If a permit is required for the space, removing or
controlling hazards in the space and determining
rescue procedures and necessary equipment.

• If the air in a space is not safe for workers,
ventilating or using whatever controls or
protections are necessary so that employees can
safely work in the space.

Ongoing practices: After pre-entry planning,
employers must ensure that the space is monitored
for hazards, especially atmospheric hazards.
Effective communication is important because
there can be multiple contractors operating on a
site, each with its own workers needing to enter
the confined space. Attendants outside confined
spaces must make sure that unauthorized workers
do not enter them. Rescue attempts by untrained
personnel can lead to multiple deaths.

Confined Spaces in Sewer Systems
Types of sewer systems include sanitary (domestic
sewage), storm (runoff), and combined (domestic
sewage and runoff). Sewer systems are extensive

and include many different components that are
considered confined spaces, including pipelines,
manholes, wet wells, dry well vaults, and lift/pump
stations. Therefore, employers conducting work
in sewer systems will likely have workers who will
encounter confined spaces.

Sewer systems also consist of wastewater
treatment plants, where confined spaces include
digestion and sedimentation tanks, floating
covers over tanks, sodium hypochlorite tanks, and
wastewater holding tanks, among others. Many
of these components may also qualify as permit-
required confined spaces.

Employers must take all necessary steps to
keep workers safe in confined spaces, including
following the OSHA Construction Confined
Spaces standard. This standard applies to both
new construction within an existing sewer and
alterations and/or upgrades. For example:

• Installing or upgrading a manhole.
• Altering or upgrading sewer lines.
• Making nonstructural upgrades to joints, pipes,

or manholes.
• Demolition work.
• Installing new or upgraded pump equipment,

cables, wires, or junction boxes.

Construction work can create confined spaces,
even if there are none at the start of a project.
Changes to the entry/exit, the ease of exit, and air
flow could produce a confined space or cause one
to become confined or permit-required.

Hazards Associated with Sewer Systems
Sewer systems can present a host of confined
space hazards, including:

• Atmospheric hazards (low oxygen, toxic or
flammable gases).

• Chemicals in piping and from roadway runoff
(may harm lungs, skin, or eyes).

• Engulfment and drowning.

• Electrocution (e.g., using electrical equipment in
wet working conditions).

• Slips, trips, and falls.
• Falling objects.
• High noise levels, low visibility, limits to

communication, and long distances to exits.

Personal protective equipment: Employers should
assess the work site to determine what personal
protective equipment (PPE) is needed to protect
workers. Employers should provide workers with
the required PPE and proper training on its use and
about any related hazards before the work starts.

How to Contact OSHA
For questions or to get information or advice,
to find out how to contact OSHA’s free on-site
consultation program, order publications, report
a fatality or severe injury, or to file a confidential
complaint, visit www.osha.gov or call 1-800-321-
OSHA (6742).

Additional Information
OSHA’s Confined Spaces in Construction
standard (29 CFR 1926 Subpart AA)

Confined Spaces: OSHA Construction
Industry Topics by Standard

OSHA Fact Sheet: Procedures for
Atmospheric Testing in Confined Spaces

Confined Spaces: NIOSH Workplace Safety
and Health Topics Page

State Plan Guidance: States with OSHA-
approved state plans may have additional
requirements for confined space safety.

Help for Small and Medium-Sized
Employers: OSHA’s On-site Consultation
Program offers free and confidential advice
to businesses nationwide.

DOC FS-3789 05/2015

This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards.
It does not impose any new compliance requirements. For a comprehensive list of compliance
requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations.
This information will be made available to sensory-impaired individuals upon request. The voice phone
is (202) 693-1999; teletypewriter (TTY) number: 1-877-889-5627.

http://www.osha.gov

http://www.osha.gov/confinedspaces/1926_subpart_aa

http://www.osha.gov/SLTC/confinedspaces/construction.html

http://www.osha.gov/OshDoc/data_Hurricane_Facts/atmospheric_test_confined

http://www.cdc.gov/niosh/topics/confinedspace/

http://www.osha.gov/dcsp/osp/statestandards.html

http://www.osha.gov/html/RAmap.html

FactSheet
Confined Spaces in Construction: Pits
Confined spaces can present conditions that are immediately dangerous to workers
if not properly identified, evaluated, tested, and controlled. This fact sheet highlights
many of the confined space hazards associated with pits and how employers can
protect their workers in these environments.

OSHA has developed a new construction
standard for Confined Spaces (29 CFR 1926
Subpart AA)— any space that meets the
following three criteria:

• Is large enough for a worker to enter it;
• Has limited means of entry or exit; and
• Is not designed for continuous occupancy.

A space may also be a permit-required confined
space if it has a hazardous atmosphere, the
potential for engulfment or suffocation, a layout
that might trap a worker through converging
walls or a sloped floor, or any other serious
safety or health hazard.

Fatal Incidents
Confined space hazards in pits have led to
worker deaths. Several tragic incidents included:

• Two workers suffocated while attempting to
close gate valves in a valve pit.

• A worker lost consciousness, fell, and was
killed while climbing down a ladder into an
unventilated underground valve vault to turn
on water valves.

• While replacing a steam-operated vertical
pump, an equipment repair technician died
from burns and suffocation after falling into
an industrial waste pit.

Training
The new Confined Spaces standard requires
employers to ensure that their workers know
about the existence, location, and dangers posed
by each permit-required confined space, and
that they may not enter such spaces without
authorization.

Employers must train workers involved in permit-
required confined space operations so that they
can perform their duties safely and understand

the hazards in permit spaces and the methods
used to isolate, control or protect workers from
these hazards. Workers not authorized to perform
entry rescues must be trained on the dangers of
attempting such rescues.

Safe Entry Requirements
The new Confined Spaces standard includes
several requirements for safe entry.

Preparation: Before workers can enter a confined
space, employers must provide pre-entry
planning. This includes:

• Having a competent person evaluate the
work site for the presence of confined spaces,
including permit-required confined spaces.

• Once the space is classified as a permit-
required confined space, identifying the
means of entry and exit, proper ventilation
methods, and elimination or control of all
potential hazards in the space.

• Ensuring that the air in a confined space
is tested, before workers enter, for oxygen
levels, flammable and toxic substances, and
stratified atmospheres.

• If a permit is required for the space, removing
or controlling hazards in the space and
determining rescue procedures and necessary
equipment.

• If the air in a space is not safe for workers,
ventilating or using whatever controls or
protections are necessary so that employees
can safely work in the space.

needing to enter the confined space. Attendants
outside confined spaces must make sure that
unauthorized workers do not enter them. Rescue
attempts by untrained personnel can lead to
multiple deaths.

Confined Spaces in Pits
Even though a pit is typically open on top and
over 4 feet deep, it can still be a confined space
or permit-required confined space. Additionally,
pits can be completely underground or below
grade, such as a utility vault within a sewer

system or a pit within
a pit in a wastewater
treatment plant.

Pits are found in
many environments.
Examples include
sump pits, valve
pits or vaults (e.g.,
wastewater treatment
plants, municipal

water systems), electrical pits/vaults, steam pits/
vaults, vehicle service/garage pits, elevator pits,
dock leveler pits, industrial chemical waste pits,
and many more. Many of these spaces qualify as
permit-required confined spaces.

Employers must take all necessary steps to
keep workers safe in confined spaces, including
following the OSHA Construction Confined
Spaces standard. This standard applies to both
new construction in a pit and alterations and/or
upgrades. Among the pit-related tasks covered
by the standard are:

• Opening or closing valves during renovation
work.

• Installing or upgrading pump equipment,
cables, or junction boxes.

Construction work can create confined spaces,
even if there are none at the start of a project.
Changes to the entry/exit, the ease of exit, and
air flow could produce a confined space or cause
one to become permit-required.

Personal protective equipment: Employers
should assess the worksite to determine what
personal protective equipment (PPE) is needed
to protect workers. Employers should provide
workers with the required PPE and proper
training on its use and about any related hazards
before the work starts.

How to Contact OSHA
For questions or to get information or advice, to find
out how to contact OSHA’s free on-site consultation
program, order publications, report a fatality or
severe injury, or to file a confidential complaint, visit
www.osha.gov or call 1-800-321-OSHA (6742).

Additional Information
OSHA’s Confined Spaces in Construction
Standard (29 CFR 1926 Subpart AA)

Confined Spaces: OSHA Construction
Industry Topics by Standard

OSHA Fact Sheet: Procedures for
Atmospheric Testing in Confined Spaces

Confined Spaces: NIOSH Workplace
Safety and Health Topics Page

State Plan Guidance: States with OSHA-
approved state plans may have additional
requirements for confined space safety.

Help for Small and Medium-Sized
Employers: OSHA’s On-site Consultation
Program offers free and confidential
advice to businesses nationwide.

DOC FS-3788 05/2015

http://www.osha.gov

http://www.osha.gov/confinedspaces/1926_subpart_aa

http://www.osha.gov/SLTC/confinedspaces/construction.html

http://www.osha.gov/OshDoc/data_Hurricane_Facts/atmospheric_test_confined

http://www.cdc.gov/niosh/topics/confinedspace/

http://www.osha.gov/dcsp/osp/statestandards.html

http://www.osha.gov/html/RAmap.html

FactSheet
Steps to an Effective Hazard
Communication Program for Employers
That Use Hazardous Chemicals
Employers that have hazardous chemicals in their workplaces are required by
OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a
hazard communication program. The program must include labels on containers of
hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and training
for workers. Each employer must also describe in a written program how it will meet
the requirements of the HCS in each of these areas.

Employers can implement an effective hazard
communication program by following these
six steps:

Step 1. Learn the Standard/Identify
Responsible Staff
• Obtain a copy of OSHA’s Hazard

Communication Standard.
• Become familiar with its provisions.
• Make sure that someone has primary

responsibility for coordinating
implementation.

• Identify staff for particular activities
(e.g., training).

You may obtain a copy of the Hazard
Communication Standard on OSHA’s hazard
communication webpage at www.osha.gov/
dsg/hazcom. The provisions of the standard
that apply to employers using chemicals in their
workplaces are found primarily in paragraphs
(e) written hazard communication program; (f)
labels and other forms of warning; (g) safety
data sheets; and (h) employee information and
training. It is important that you become familiar
with these provisions to determine what is
needed for compliance in your workplace.

In order to ensure that you have an effective
hazard communication program, and address
all of the necessary components, responsibility
for implementation of hazard communication
should be assigned to someone to coordinate.
The person designated for overall program

coordination should then identify staff to
be responsible for particular activities, such
as training.

Step 2. Prepare and Implement a Written
Hazard Communication Program
• Prepare a written plan to indicate how

hazard communication will be addressed
in your facility.

• Prepare a list or inventory of all hazardous
chemicals in the workplace.

Paragraph (e) of the standard requires employers
to prepare and implement a written hazard
communication program. This requirement is to
help ensure that compliance with the standard is
done in a systematic way, and that all elements
are coordinated. The written program must
indicate how you will address the requirements
of paragraphs (f) labels and other forms of
warning; (g) safety data sheets; and (h) employee
information and training, in your workplace.

The written program also requires employers
to maintain a list of the hazardous chemicals
known to be present in the workplace. Using the
product identifier (e.g., product name, common
name, or chemical name) to prepare the list will
make it easier for you to track the status of SDSs
and labels of a particular hazardous chemical.
Remember, the product identifier must be the
same name that appears on the label and SDS of
the hazardous chemical.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

www.osha.gov/dsg/hazcom

Step 3. Ensure Containers are Labeled
• Keep labels on shipped containers.
• Label workplace containers where required.

Chemical manufacturers and importers are
required to provide labels on shipped containers
with the following information: product identifier,
signal word, pictograms, hazard statements,
precautionary statements, and the name,
address and phone number of the responsible
party. Therefore, when an employer receives a
hazardous chemical from a supplier, all of this
information will be located together on the label;
however, additional information may also appear.

As the employer, you are required to ensure
that containers in the workplace are labeled.
You may use the same label from the supplier
or you may label workplace containers with
alternatives, such as third party systems (e.g.,
National Fire Protection Association (NFPA)
or Hazardous Materials Identification System
(HMIS)) in addition to the other required
information. Any container of hazardous
chemicals in the workplace must at a minimum
include the product identifier and general
information concerning the hazards of the
chemical. Whatever method you choose, your
workers need to have access to the complete
hazard information.

Step 4. Maintain Safety Data
Sheets (SDSs)
• Maintain safety data sheets for each

hazardous chemical in the workplace.
• Ensure that safety data sheets are readily

accessible to employees.

Safety data sheets are the source of detailed
information on a particular hazardous chemical.
Employers must maintain copies of SDSs
for all hazardous chemicals present in their
workplaces. If you do not receive an SDS
from your supplier automatically, you must
request one. You also must ensure that SDSs
are readily accessible to workers when they
are in their work areas during their work shifts.

This accessibility may be accomplished in
many different ways. You must decide what
is appropriate for your particular workplace.
Some employers keep the SDSs in a binder in
a central location (e.g., outside of the safety
office, in the pick-up truck on a construction
site). Others, particularly in workplaces with
large numbers of chemicals, provide access
electronically. However, if SDSs are supplied
electronically, there must be an adequate
back-up system in place in the event of a
power outage, equipment failure, or other
emergency involving the primary electronic
system. In addition, the employer must ensure
that workers are trained on how to use the
system to access SDSs and are able to obtain
hard copies of the SDSs. In the event of a
medical emergency, hard copy SDSs must be
immediately available to medical personnel.

Step 5. Inform and Train Employees
• Train employees on the hazardous chemicals

in their work area before initial assignment,
and when new hazards are introduced.

• Include the requirements of the standard,
hazards of chemicals, appropriate protective
measures, and where and how to obtain
additional information.

Paragraph (h) of the HCS requires that employers
train employees on the hazardous chemicals in
their work area before their initial assignment
and when new hazards are introduced into the
work area, and this training must be conducted
in a manner and language that employees can
understand. Workers must understand they are
exposed to hazardous chemicals. They must
know that labels and safety data sheets can
provide them with information on the hazards of
a chemical, and these items should be consulted
when needed. In addition, workers must have
a general understanding of what information is
provided on labels and SDSs, and how to access
them. They must also be aware of the protective
measures available in their workplace, how to
use or implement these measures, and whom
they should contact if an issue arises.

DSG FS-3696 03/2014

Step 6. Evaluate and Reassess
Your Program
• Review your hazard communication program

periodically to make sure that it is still working
and meeting its objectives.

• Revise your program as appropriate to
address changed conditions in the workplace
(e.g., new chemicals, new hazards, etc.).

Although the HCS does not require you
to evaluate and reassess your hazard
communication program, it must remain current
and relevant for you and your employees.
The best way to achieve that is to review your
hazard communication program periodically to
make sure that it is still working and meeting

its objectives and to revise it as appropriate to
address changed conditions in the workplace
(e.g., new chemicals, new hazards, etc.).

Additional Information
See Hazard Communication: Small Entity
Compliance Guide for Employers That
Use Hazardous Chemicals for more
detailed information on how to implement
an effective hazard communication program.
Additional information on the Hazard
Communication Standard can be found on
OSHA’s Hazard Communication webpage at
www.osha.gov/dsg/hazcom.

http://www.osha.gov/Publications/OSHA3695

www.osha.gov/dsg/hazcom

Course Learning Outcomes for Unit VII

Upon completion of this unit, students should be able to:

2. Apply Occupational Safety and Health Administration standards and related practices to construction.
2.1 Discuss the requirements for working safely in confined spaces.

4. Examine methods used to control common construction hazards.
4.1 Analyze hazards that contribute to construction accidents.

8. Examine training and hazard communication strategies.
8.1 Examine hazard communication strategies.

Course/Unit
Learning Outcomes

Learning Activity

2.1
Unit VII Lesson
Required Readings
Unit VII Assessment

4.1
Unit VII Lesson
Required Readings
Unit VII Research Paper

8.1
Unit VII Lesson
Required Readings
Unit VII Assessment

Reading Assignment

Occupational Safety & Health Administration. (2015). Subpart AA, confined spaces in construction [Brochure].
Retrieved from https://www.osha.gov/confinedspaces/1926_subpart_aa

Occupational Safety & Health Administration. (2015). Confined spaces in construction: Pits [Brochure].
Retrieved from https://www.osha.gov/Publications/OSHA3788

Occupational Safety & Health Administration. (2015). Confined spaces in construction: Sewer systems
[Brochure]. Retrieved from https://www.osha.gov/Publications/OSHA3789

Occupational Safety & Health Administration. (2014). Hazard communication: Small entity compliance guide
for employers that use hazardous chemicals [Brochure], pp. 1-29. Retrieved from
https://www.osha.gov/Publications/OSHA3695

Occupational Safety & Health Administration. (n.d.) Steps to an effective hazard communication program
for employers that use hazardous chemicals [Brochure]. Retrieved from
https://www.osha.gov/Publications/OSHA3696

UNIT VII STUDY GUIDE

Confined Space Entry and Hazard
Communication

https://www.osha.gov/confinedspaces/1926_subpart_aa

https://www.osha.gov/Publications/OSHA3788

https://www.osha.gov/Publications/OSHA3789

https://www.osha.gov/Publications/OSHA3695

https://www.osha.gov/Publications/OSHA3696

UNIT x STUDY GUIDE

Title

Unit Lesson

Confined Space Entry

On August 3, 2015, a new Occupational Safety & Health Administration (OSHA) standard regulating confined
space entry in construction became effective, nearly eight years after the proposed rule was first published in
the Federal Register. The standard was needed to protect workers from exposure to serious hazards while
working in confined spaces on construction sites. Workers in other industries have been protected by a
confined space standard for decades, and OSHA recognized that a separate standard was needed for
construction due to the ever-changing nature of construction confined spaces and the type of work done in
them. The standard emphasizes training, monitoring, and communication between contractors and
subcontractors (Cordado, 2015).

By definition, a confined space has three specific characteristics:

 is large enough and so configured that an employee can bodily enter it;

 has limited or restricted means for entry and exit, and

 is not designed for continuous employee occupancy (Occupational Safety & Health Administration
[OSHA], 2015).

It is important to note that “restricted for entry/exit” does not mean “one way in—one way out.” Restricted
means that it may be difficult to exit in an emergency or it may be difficult for rescue workers to enter the
space. Time is a critical factor in confined space emergencies

On construction sites, confined spaces often include pits, trenches, manholes, tanks, sewers, ducts, and
drains. Not all confined spaces need controlled entry. OSHA further defines a permit-required space as one
that has one or more additional characteristics:

 contains or has a potential to contain a hazardous atmosphere,

 contains a material that has the potential for engulfing an entrant,

 has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly
converging walls or by a floor which slopes downward and tapers to a smaller cross-section, or

 contains any other recognized serious safety or health hazard (OSHA, 2015).

Determinations of permit-required spaces must be made by a competent person. If hazards are identified,
control measures that allow safe entry must be implemented, including continuous monitoring of existing

(Almeida, n.d.)

UNIT x STUDY GUIDE

Title

hazards. Employees authorized to enter permit-required spaces must be trained on safe entry procedures,
and employers must ensure that non-authorized employees are not allowed to enter the confined spaces.
Provisions must be in place for emergency egress from the space as well as provisions for emergency rescue
(OSHA, 2015).

Safety professionals familiar with the confined space requirements of OSHA’s General Industry Standards will
recognize many similarities in the Construction Standard. However, some sections of the 29 CFR 1926
version include new or revised requirements based on advances in technology and lessons learned since the
implementation of the 29 CFR 1910 standard. It is important that the standard be read in its entirety before
developing any confined space entry program.

Hazard Communication

In 1983, OSHA published its first Hazard Communication (Hazcom) Standard at 29 CFR 1910.1200 (Haight,
2013). The goal of this standard was to ensure workers were provided information and resources necessary
to identify hazardous chemicals in the workplace and protect themselves from exposure to these chemicals.
The term “Right to Know Law” is often used to describe the Hazcom Standard. More than 30 years later, the
Hazcom Standard remains the second most frequently cited OSHA standard (OSHA, n.d.-a). The reasons for
the number of citations could include that the standard is complex or that the standard was not clear in its
requirements. OSHA originally chose to write a performance standard that provided general guidelines rather
than a specification standard that provided more detail. For example, the old standard did not specify the
formatting of labels used on hazardous material containers, but simply stated that the labels must include
identity of the hazardous chemicals, appropriate hazard warnings, and the name and address of the chemical
manufacturer, importer, or other responsible party (OSHA, 2012). Numerous labeling systems could be found
in a single workplace, creating confusion for both workers and employers. In 2012, OSHA revised the
Hazcom Standard to align with the United Nations Globally Harmonized System of Classification and Labeling
of Chemicals (GHS). The revision resulted in standardized label formatting, the use of pictograms on labels,
standardized wording of precautionary statements, and standardized information required on safety data
sheets. Workers see the same information in the same format regardless of the chemical manufacturer or the
industry in which they work. In OSHA’s own words, “The standard that gave workers the right to know, now
gives them the right to understand” (OSHA, n.d.-b, p.1).

The OSHA construction standard for Hazard Communication (29 CFR 1926.59) states, “The requirements
applicable to construction work under this section are identical to those set forth at 1910.1200 of this chapter”
(OSHA, 1996, p.1). The construction industry must comply with the Hazcom requirements in the General
Industry Standards. The requirements of the standard are summarized in the image below.

UNIT x STUDY GUIDE
Title

The challenge to implementing an effective Hazcom program is, once again, the constant changes that occur
on a typical construction site. The adoption of GHS will improve the understanding of labels and hazard
warnings, but the employer must still ensure all hazardous chemicals are inventoried and the safety
information is communicated effectively to employees.

References

Almeida, A. (n.d.). “Who taught the new guy…” [Cartoon]. Retrieved from
http://www.almeidacartoons.com/Safe_toons1.html

Cordado, T. L. (2015). OSHA issues new construction confined space standard. Retrieved from

OSHA Issues New Construction Confined Space Standard

Haight, Joel M. (Ed.). (2013). Hazardous material management and hazard communication. Des Plaines, IL:
American Society of Safety Engineers.

Occupational Safety & Health Administration. (n.d.-a). Commonly used statistics. Retrieved from
https://www.osha.gov/oshstats/commonstats.html

(OSHA, 2014)

UNIT x STUDY GUIDE

Title
Occupational Safety & Health Administration. (n.d.-b). Hazard communication. Retrieved from

https://www.osha.gov/dsg/hazcom/index.html

Occupational Safety & Health Administration. Regulations (Standards – 29 CRF): Hazard communication.
Retrieved from
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10633&p_table=STANDARDS

Occupational Safety & Health Administration. (2012). Side-by-side comparison of OSHA’s existing Hazard
Communication Standard (HCS 1994) vs. the revised Hazard Communication Standard (HCS 2012).
Retrieved from https://www.osha.gov/dsg/hazcom/side-by-side.html

Occupational Safety & Health Administration. (2014). Hazard communication: Small entity compliance guide
for employers that use hazardous chemicals [Brochure] Retrieved from
https://www.osha.gov/Publications/OSHA3695

Occupational Safety & Health Administration. (2015). Subpart AA, confined spaces in construction [Brochure].
Retrieved from https://www.osha.gov/confinedspaces/1926_subpart_aa

Suggested Reading

Are you looking for more insight on the topics discussed in this unit? Access the items listed below to view
videos and additional information to gain further insight and understanding.

OSHA Construction Standards

Occupational Safety & Health Administration. (n.d.). 29 CFR 1926 Subpart AA, Confined spaces in
construction. Retrieved from https://www.osha.gov/confinedspaces/1926_subpart_aa

OSHA General Industry Standards:

Occupational Safety & Health Administration. (n.d.). Regulations (Standards – 29 CRF): Hazard
communication.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

Occupational Safety & Health Administration. (n.d.) Silent killer in a newly constructed Manhole [PowerPoint
presentation]. Retrieved from https://www.osha.gov/confinedspaces/manhole_cs.ppt

Occupational Safety & Health Administration. (n.d.). The globally harmonized system (GHS) for hazard
classification and labelling Retrieved from https://www.osha.gov/dsg/hazcom/ghsguideoct05

Occupational Safety & Health Administration. (n.d.) Construction focus four training. Retrieved from
https://www.osha.gov/dte/outreach/construction/focus_four/index.html

Learning Activities (Nongraded)

The 2012 revision to OSHA’s Hazard Communication standard changed the warning label requirements for
hazardous material containers to align with the United Nations Globally Harmonized System of Classification
and Labeling of Chemicals (GHS). Create a presentation that can be used to train employees on how to read
and understand the new labeling system.

Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions contact your instructor for further guidance and information.

https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=standards&p_toc_level=1&p_keyvalue=construction

https://www.osha.gov/confinedspaces/1926_subpart_aa

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

https://www.osha.gov/confinedspaces/manhole_cs.ppt

https://www.osha.gov/dsg/hazcom/ghsguideoct05

https://www.osha.gov/dte/outreach/construction/focus_four/index.html

A Guide to

The Globally Harmonized System of
Classification and Labeling of

Chemicals (GHS)

Acronyms/Abbreviations

The following list presents some acronyms and abbreviations used in this document. The 6.0 –
Glossary contains a more complete list.

ANSI: American National Standards Institute

APEC: Asia-Pacific Economic Cooperation

ASTM: American Society of Testing and Materials

CA: Competent Authority

CAS: Chemical Abstract Service

CBI: Confidential Business Information

CFR: Code of Federal Regulations

CG/HCCS: Coordinating Group for the Harmonization of Chemical Classification Systems

CPSC: Consumer Product Safety Commission

DOT: Department of Transportation

EINECS: European Inventory of Existing Commercial Chemical Substances

EPA: Environmental Protection Agency

EU: European Union

FIFRA: Federal Insecticide, Fungicide and Rodenticide Act

GHS: Globally Harmonized System of Classification and Labelling of Chemicals

HCS: Hazard Communication Standard

IARC: International Agency for the Research on Cancer

IFCS: International Forum on Chemical Safety

ILO: International Labor Organization

IOMC: Inter-organization Program on the Sound Management of Chemicals

ISO: International Standards Organization

IUPAC: International Union of Pure and Applied Chemistry

LD50 : Lethal dose

mg/kg: Milligram per kilogram

MSDS: Material Safety Data Sheet

NAFTA: North American Free Trade Agreement

OSHA: Occupational Safety and Health Administration

OECD: The Organization for Economic Cooperation and Development

QSARs: Quantitative Structure-Activity Relationships

SDS: Safety Data Sheet

SME: Small and medium sized enterprises

TFHCL: Task Force on the Harmonization of Classification and Labeling

TSCA: Toxic Substances Control Act

UN: United Nations

UNCED: United Nations Conference on Environment and Development

UNCETDG: United Nations Committee of Experts on the Transport of Dangerous Goods

UNCETDG/GHS: United Nations Committee of Experts on the Transport of Dangerous Goods
and on the Globally Harmonized System of Classification and Labelling of Chemicals

UNITAR: United Nations Institute for Training and Research

WG: work group

WHMIS: Workplace Hazardous Materials Information System

WSSD: World Summit on Sustainable Development

iii

TABLE OF CONTENTS

1. Background —————————————————————————————

1.1 What is the GHS? ————————————————————————– 1
1.2 Why was the GHS developed? ———————————————————–

1.3 What was the International Mandate? —————————————————

1.4 How was the GHS developed? ———————————————————– 4
1.5 How will the GHS be maintained and updated? —————————————

1.6 When will the GHS be implemented? —————————————————

1.7 What are the benefits? ——————————————————————— 6

2. How is the GHS to be applied? ——————————————————————-

2.1 Are all chemicals covered by the GHS? ———————————————— 8
2.2 Will all hazardous chemicals require a GHS label and Safety Data Sheet? ——–

2.3 How will the GHS impact existing regulations? ————————————— 9
2.4 What is meant by GHS Building Blocks? ———————————————

2.5 How should the GHS Building Blocks by applied? ———————————- 10
2.5.1 Transport ————————————————————————-

2.5.2 Workplace ————————————————————————

2.5.3 Consumer ————————————————————————- 12
2.5.4 Pesticides ————————————————————————- 12
2.6 How will the GHS impact countries without existing regulations?—————–12

3. What is Classification? —————————————————————————- 1

3.1 What are the GHS Physical Hazards? ————————————————–

3.1.1 Explosives————————————————————————-

3.1.2 Flammable Gases —————————————————————-

3.1.3 Flammable Aerosols ————————————————————- 15
3.1.4 Oxidizing Gases —————————————————————— 15
3.1.5 Gases Under Pressure————————————————————

3.1.6 Flammable Liquids ————————————————————– 16
3.1.7 Flammable Solids —————————————————————- 16
3.1.8 Self-Reactive Substances ——————————————————- 1

3.1.9 Pyrophoric Liquids—————————————————————

3.1.10 Pyrophoric Solids —————————————————————- 18
3.1.11 Self-Heating Substances ——————————————————– 18
3.1.12 Substances Which in Contact with Water Emit Flammable Gases ——- 18
3.1.13 Oxidizing Liquids —————————————————————18
3.1.14 Oxidizing Solids —————————————————————– 18
3.1.15 Organic Peroxides —————————————————————

3.1.16 Substances Corrosive to Metal ———————————————— 19
3.2 What are the GHS Health and Environmental Hazards?—————————–

3.2.1 Acute Toxicity ——————————————————————–

3.2.2 Skin Corrosion——————————————————————– 21
3.2.3 Skin Irritation ———————————————————————

3.2.4 Eye Effects ———————————————————————— 22
3.2.5 Sensitization ———————————————————————- 22

3.2.6 Germ Cell Mutagenicity———————————————————

3.2.7 Carcinogenicity——————————————————————- 23
3.2.8 Reproductive Toxicity ———————————————————–

3.2.9 Target Organ Systemic Toxicity: Single Exposure &

Repeated Exposure————————————————————— 24
3.2.10 Aspiration Toxicity—————————————————————

3.3 Environmental Hazards ——————————————————————

3.3.1 Hazardous to the Aquatic Environment ————————————— 26
3.3.1.1 Acute Aquatic Toxicity ———————————————— 26
3.3.1.2 Chronic Aquatic Toxicity ——————————————— 26
3.4 What is the GHS approach to classifying mixtures? ———————————

3.5 What are bridging principles? ———————————————————–

3.6 What testing is required? —————————————————————– 28

4. Hazard Communication ————————————————————————— 32
4.1 What factors influenced development of the GHS communication tools?———32
4.2 Labels ————————————————————————————– 32
4.2.1 What does a label look like? —————————————————- 32
4.2.2 USA Examples ——————————————————————-

4.2.3 International Examples ———————————————————-

4.3 What are the GHS label elements? —————————————————–

4.3.1 Symbols (hazard pictograms)—————————————————

4.3.2 Signal Words ——————————————————————— 38
4.3.3 Hazard Statements —————————————————————

4.3.4 Precautionary Statements and Pictograms ———————————— 41
4.3.5 Product Identifier (Ingredient Disclosure) ————————————

4.3.6 Supplier Identification ———————————————————– 42
4.3.7 Supplemental Information —————————————————— 42
4.4 How are multiple hazards handled on labels? —————————————– 42
4.5 Is there a specific GHS label format / layout?—————————————–

4.6 What about risk? ————————————————————————–

4.7 Are workplace containers covered in the GHS? ————————————–

4.8 What is the GHS Safety Data Sheet (SDS)?——————————————- 45
4.9 What is the difference between the GHS SDS and existing MSDSs/SDSs?——

4.10 When should SDSs and labels be updated?——————————————– 50
4.11 How does the GHS address Confidential Business Information (CBI)? ———– 50
4.12 Does the GHS address training? ——————————————————– 50

5. References ——————————————————————————————

6. Glossary ——————————————————————————————— 50

Appendices ———————————————————————————————–

A Comparison of MSDSs/SDSs Elements ——————————————— A-1
B GHS MSDS examples ——————————————————————

B-1

1.0 BACKGROUND

The purpose of this document is to describe the United Nations Globally Harmonized System of
Classification and Labeling of Chemicals (GHS), why it was developed, and how it relates to the
sound management of chemicals. The full official text of the system is available on the web at:
http://www.unece.org/trans/danger/publi/ghs/ghs_rev00/00files_e.html

1.1 What is the GHS?
The GHS is an acronym for The Globally Harmonized System of Classification and Labeling of
Chemicals. The GHS is a system for standardizing and harmonizing the classification and
labeling of chemicals. It is a logical and comprehensive approach to:

• Defining health, physical and environmental hazards of chemicals;
• Creating classification processes that use available data on chemicals for comparison

with the defined hazard criteria; and
• Communicating hazard information, as well as protective measures, on labels and Safety

Data Sheets (SDS).

Many countries already have regulatory systems in
place for these types of requirements. These systems
may be similar in content and approach, but their
differences are significant enough to require multiple
classifications, labels and safety data sheets for the same
product when marketed in different countries, or even in
the same country when parts of the life cycle are covered
by different regulatory authorities. This leads to
inconsistent protection for those potentially exposed to the
chemicals, as well as creating extensive regulatory burdens
on companies producing chemicals For example, in the
United.States (U.S.) there are requirements for
classification and labeling of chemicals for the Consumer
Product Safety Commission, the Department of
Transportation, the Environmental Protection Agency, and
the Occupational Safety and Health Administration.

The GHS itself is not a regulation or a standard. The GHS
Document (referred to as “The Purple Book”, shown in
Figure 1.1) establishes agreed hazard classification and
communication provisions with explanatory information
on how to apply the system. The elements in the GHS supply a mechanism to meet the basic
requirement of any hazard communication system, which is to decide if the chemical product
produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as
appropriate. Regulatory authorities in countries adopting the GHS will thus take the agreed
criteria and provisions, and implement them through their own regulatory process and
procedures rather than simply incorporating the text of the GHS into their national requirements.

Figure 1.1 GHS Document (“Purple Book”)

The GHS Document thus provides countries with the regulatory building blocks to develop or
modify existing national programs that address classification of hazards and transmittal of
information about those hazards and associated protective measures. This helps to ensure the
safe use of chemicals as they move through the product life cycle from “cradle to grave.”

1.2 Why was the GHS developed?
The production and use of chemicals is fundamental to all economies. The global chemical
business is more than a $1.7 trillion per year enterprise. In the U.S., chemicals are more than a
$450 billion business and exports are greater than $80 billion per year.

Chemicals directly or indirectly affect our lives and are essential to our food, our health, and our
lifestyle. The widespread use of chemicals has resulted in the development of sector-specific
regulations (transport, production, workplace, agriculture, trade, and consumer products). Having
readily available information on the hazardous properties of chemicals, and recommended
control measures, allows the production, transport, use and disposal of chemicals to be managed
safely. Thus, human health and the environment are protected.

The sound management of chemicals should include systems through which chemical hazards
are identified and communicated to all who are potentially exposed. These groups include
workers, consumers, emergency responders and the public. It is important to know what
chemicals are present and/or used, their hazards to human health and the environment, and the
means to control them. A number of classification and labeling systems, each addressing specific
use patterns and groups of chemicals, exist at the national, regional and international levels. The
existing hazard classification and labeling systems address potential exposure to chemicals in all
the types of use settings listed above.

While the existing laws and regulations are similar, they are different enough to require multiple
labels for the same product both within the U.S. and in international trade and to require multiple
safety data sheets for the same product in international trade. Several U.S. regulatory agencies
and various countries have different requirements for hazard definitions as well as for
information to be included on labels or material safety data sheets.

Figure 1.2

The numerical values on the hazard index scale in the table are not to scale.

For example, a product may be considered flammable or toxic by one agency or country, but not
by another.

We can see by comparing a few hazards how complex it is to comply with all domestic and
global regulations. Acute oral toxicity (LD50) is a good example (Figure 1.2). Although most
existing systems cover acute toxicity, we can see in the figure that what is considered hazardous
varies considerably. These differences allow the same product to be hazardous in one
country/system and not in another. At the very least, the same product has different labels and
SDSs.

Figure 1.3

The numerical values on the hazard index scale in the table are not to scale.

Flammable liquid is another hazard that is covered by most existing systems. As shown in Figure
1.3, the coverage varies between existing systems within the U.S. and globally. This means that
the same product can be non-hazardous or hazardous with different labels/SDSs. In Section 4,

° F 100° 200°40°20° 73° 140°

OSHA HCS

OSHA/NFPA

WHMIS

DOT

IMO

ICAO/IATA

CPSC

ANSI Z129.1

FLAMMABILITY

Flammable

Combustible

Extremely/Highly/Flammable
131°F

Division 2 Flammable Division 3 Combustible

Flammable Combustible
Combustible

70°F

150°F

20°F

Extremely/Flammable

73°F

Extremely/Flammable
73°F

CombustibleGHSGHS

Figures 4.1 through 4.7 show the diverse domestic and international labels for a fictitious product
(ToxiFlam) which has both oral toxicity and flammability hazards.

These differences in hazards and SDS/labels impact both protection and trade. In the area of
protection, users may see different label warnings or safety data sheet information for the same
chemical. In the area of trade, the need to comply with multiple regulations regarding hazard
classification and labeling is costly and time-consuming. Some multinational companies have
estimated that there are over 100 diverse hazard communication regulations for their products
globally. For small and medium size enterprises (SMEs) regulatory compliance is complex and
costly, and it can act as a barrier to international trade in chemicals.

1.3 What was the International
Mandate?
The single most important force that drove
the creation of the GHS was the international
mandate (Figure 1.4) adopted in the 1992
United Nations Conference on Environment
and Development (UNCED), often called the
“Earth Summit”. The harmonization of
classification and labeling of chemicals was
one of six program areas that were endorsed
by the United Nations General Assembly to
strengthen international efforts concerning the environmentally sound management of chemicals.
It was recognized that an internationally harmonized approach to classification and labeling
would provide the foundation for all countries to develop comprehensive national programs to
ensure the safe use of chemicals.

1.4 How was the GHS developed?
In conjunction with its Convention and Recommendation on Safety in the Use of Chemicals at
Work, the International Labor Organization (ILO) studied the tasks required to achieve
harmonization. The ILO concluded that there were four major existing systems that needed to be
harmonized to achieve a global approach.

No international organization covers all
aspects of chemical classification and
labeling. A broad scope and extensive
expertise and resources were required to
develop a system. In order to proceed,
several decisions were needed:

(a) what systems would be considered
“major” and thus the basis for
harmonization, and (b) how could the work
be divided to get the best expertise for
different aspects. Four existing systems

Figure 1.4
International Mandate from UNCED Agenda 21,
Chapter 19

“A globally harmonized hazard classification
and compatible labelling system, including
material safety data sheets and easily
understandable symbols, should be available, if
feasible, by the year 2000.”

Figure 1.5
Existing Systems Included in the Harmonization

Process
• UN Transport Recommendations
• U.S. Requirements for Workplace, Consumer and

Pesticides
• European Union Dangerous Substance and

Preparations Directives
• Canadian Requirements for Workplace, Consumers

and Pesticides

(Figure #1.5) were deemed to be major and the primary basis for the GHS. While not considered
major, requirements of other systems were examined as appropriate, and taken into account as
proposals were developed.

A Coordinating Group for the Harmonization of Chemical Classification Systems (CG/HCCS)
was created under the Inter-organization Program for the Sound Management of Chemicals
(IOMC) and they were charged with coordinating and managing development of the system.

The GC/HCCS worked on a consensus basis
and included representatives from major
stakeholders, including national
governments, industry and workers. They
created a set of guiding principles (Figure
1.6). The scope and guiding principles
created a common framework for the
organizations that were charged with
developing the different elements of the
system.

In order to get the best expertise and
resources, the work was divided among three technical focal points.

Figure 1.7

shows how the
work was assigned to the three technical focal points and the overall responsibilities of the
Coordinating Group itself. The UN Committee of Experts on Transport of Dangerous Goods
was selected as the lead for work on physical hazards, in cooperation with the ILO. Based on
their work in the testing guidelines and other chemical issues, the Organization for Economic
Cooperation and Development (OECD) was selected for health/environmental hazards and
mixtures. ILO has a long history in MSDS/labels, and was selected to be the lead in hazard
communication. The OECD and ILO groups also included representatives from governments,
industry and workers.

Figure 1.6
Key Guiding Principles of the Harmonization Process

• Protection will not be reduced;
• Will be based on intrinsic properties (hazards) of

chemicals;
• All types of chemicals will be covered;
• All systems will have to be changed;
• Involvement of all stakeholders should be ensured;
• Comprehensibility must be addressed.

Health Endpoint
WGs

Aquatic
WG

M ixture
WG

OECD TFHCL
Health & Environm ental Hazard Criteria

ILO
Hazard Com m unication

Reactivity
WG

Flam m ability
WG

UNCETDG & ILO
Physical Hazard Criteria

IOM C
Coordinating Group for the Harm onization of Chem ical Classification System s

Scope, Guiding Principles and GHS Docum ent

Figure 1.7

1.5 How will the GHS be maintained and updated?
In October 1999, the United Nations Economic and Social Council decided (resolution 1999/65)
to enlarge the mandate of the Committee of Experts on the Transport of Dangerous Goods by
reconfiguring it into a Committee of Experts on the Transport of Dangerous Goods and on the
Globally Harmonized System of Classification and Labeling of Chemicals (UNCETDG/GHS).
At the same time, a new Sub-Committee of Experts on the Globally Harmonized System of
Classification and Labeling of Chemicals (GHS Sub-Committee) was also created.

When the IOMC completed developing the GHS, the system was presented to the UN GHS Sub-
Committee, which formally adopted the system at its first session in December 2002. It was
subsequently endorsed by the UNCETDG/GHS. The UN Economic and Social Council
endorsed the GHS in July 2003.

The Sub-Committee of Experts on the Globally Harmonized System of Classification will:
• Act as custodian of the system, managing and giving direction to the harmonization

process,
• Keep the system up-to-date, as necessary, considering the need to introduce changes or

updates to ensure its continued relevance,
• Promote understanding and use of the system and encourage feedback,
• Make the system available for worldwide use,
• Make guidance available on the application of the system, and on the interpretation and

use of technical criteria to support consistency of application,
• Prepare work programs and submit recommendations to the UNCETDG/GHS.

1.6 When will the GHS be implemented?
There is no international implementation schedule for the GHS. It is likely that different national
systems/sectors will require different timeframes for GHS implementation. Existing systems will
need to consider phase-in strategies for transition from their current requirements to the new
GHS requirements.

Several international bodies have proposed implementation goals. The World Summit on
Sustainable Development (WSSD) and the Intergovernmental Forum for Chemical Safety (IFCS)
have encouraged countries to implement the new GHS as soon as possible with a view to having
the system fully operational by 2008. The Ministers of the Asia-Pacific Economic Cooperation
(APEC) have also said that as many APEC economies as possible should implement, on a
voluntary basis, the GHS by 2006. Under the North American Free Trade Agreement (NAFTA),
the Tri-national Occupational Safety and Health Group and the NAFTA Pesticides Technical
Working Group are discussing the GHS.

Some of the major existing systems have begun discussions about GHS implementation and
situational analyses comparing existing requirements to GHS requirements. Some countries are
considering harmonization to the greatest extent possible between their national sectors.

1.7 What are the benefits?
The basic goal of hazard communication is to ensure that employers, employees and the public
are provided with adequate, practical, reliable and comprehensible information on the hazards of
chemicals, so that they can take effective preventive and protective measure for their health and
safety. Thus, implementation of effective hazard communication provides benefits for
governments, companies, workers, and members of the public.

The GHS has maximum value if it is accepted in all major regulatory systems for chemical
hazard communication. The diversity of hazard definitions is shown in Figures 1.2 and 1.3. The
array of domestic and global labels for one product is shown in Figures 4.1 to 4.7. In the USA
implementation of the GHS would harmonize hazard definitions and label information among
U.S. regulatory agencies (CPSC, DOT, EPA, OSHA, etc.). If the GHS is implemented globally,
consistent information will be communicated on labels and SDSs.

It is anticipated that application of the GHS will:
• Enhance the protection of human health and the environment by providing an

internationally comprehensible system,
• Provide a recognized framework to develop regulations for those countries without

existing systems,
• Facilitate international trade in chemicals whose hazards have been identified on an

international basis,
• Reduce the need for testing and evaluation against multiple classification systems.

The tangible benefits to governments are:
• Fewer chemical accidents and incidents,
• Lower health care costs,
• Improved protection of workers and the public from chemical hazards,
• Avoiding duplication of effort in creating national systems,
• Reduction in the costs of enforcement,
• Improved reputation on chemical issues, both domestically and internationally.

Benefits to companies include:
• A safer work environment and improved relations with employees,
• An increase in efficiency and reduced costs from compliance with hazard communication

regulations,
• Application of expert systems resulting in maximizing expert resources and minimizing

labor and costs,
• Facilitation of electronic transmission systems with international scope,
• Expanded use of training programs on health and safety,
• Reduced costs due to fewer accidents and illnesses,
• Improved corporate image and credibility.

Benefits to workers and members of the public include:
• Improved safety for workers and others through consistent and simplified

communications on chemical hazards and practices to follow for safe handling and use,
• Greater awareness of hazards, resulting in safer use of chemicals in the workplace and in

the home.

2.0 HOW IS THE GHS TO BE APPLIED?
The GHS Classification and Communication elements are the foundation of programs to ensure
the safe use of chemicals, as shown in Figure 2.1. The first two steps in any program to ensure
the safe use of chemicals are to identify intrinsic hazard(s) (i.e., classification) and then to
communicate that information. The design of the GHS communication elements reflect the
different needs of various target audiences, such as workers and consumers. To proceed further
up the pyramid, some existing national programs also include risk management systems as part
of an overall program on the sound management of chemicals. The general goal of these
systems is to minimize exposure, resulting in reduced risk. The systems vary in focus and
include activities such as establishing exposure limits, recommending exposure monitoring
methods and creating engineering controls. However, the target audiences of such systems are
generally limited to workplace settings. With or without formal risk management systems, the
GHS is designed to promote the safe use of chemicals.

2.1 Are all chemicals covered by the GHS?
The GHS covers all hazardous chemicals. There are no complete exemptions from the scope of
the GHS for a particular type of chemical or product. The term “chemical” is used broadly to
include substances, products, mixtures, preparations, or any other terms that may be used by
existing systems. The goal of the GHS is to identify the intrinsic hazards of chemical substances

GHS Classification

Hazard Communication
GHS Safety Data Sheets & Labels

Safe Use
of Chemicals

Risk Management Systems
Risk Communication

Exposure Monitoring/Control

Figure 2.1

and mixtures and to convey hazard information about these hazards. The GHS is not intended to
harmonize risk assessment procedures or risk management decisions, as described above.

“Articles” as defined in the OSHA Hazard Communication Standard (HCS) (29 CFR
1910.1200), or by similar definitions, are outside the scope of the GHS. Chemical inventory
(e.g., TSCA, EINECS, etc.) and chemical control requirements in various countries are not
harmonized by the GHS.

Classification in the GHS is criteria-based, not limiting coverage to a list that can become
outdated. It is not anticipated that the GHS will develop or maintain an international
classification authority or international classification list. Several countries currently maintain
regulatory lists. GHS classification criteria can be used to reclassify chemicals on lists, if desired.
Existing lists, such as those provide by organizations that evaluate cancer hazards, could be used
in conjunction with the GHS to promote harmonization.

2.2 Will all hazardous chemicals require a GHS label and Safety Data Sheet?
The need for GHS labels and/or Safety Data Sheets is expected to vary by product category or
stage in the chemical’s lifecycle from research/production to end use. The sequence of lifecycle
events is shown in Figure 2.2. For example, pharmaceuticals, food additives, cosmetics and
pesticide residues in food will not
be covered by the GHS at the point
of consumption, but will be
covered where workers may be
exposed (workplaces), and in
transport. Also, the medical use of
human or veterinary
pharmaceuticals is generally
addressed in package inserts and is
not part of existing hazard
communication systems. Similarly,
foods are generally not labeled
under existing hazard
communication systems. The exact
requirements for labels and Safety
Data Sheets will continue to be
defined in national regulations.
However, national requirements
are expected to be consistent with
the detailed discussion of scope
provided in Chapter 1.1 of the
GHS document.

2.3 How will the GHS impact existing regulations?
The GHS is a voluntary international system that imposes no binding treaty obligations on
countries. To the extent that countries adopt the GHS into their systems, the regulatory changes

Inception

Develop

Manufacture
Transport

Sell

Use

Disposal

Product
Lifecycle

Design

Inception

Develop

Manufacture
Transport
Sell
Use
Disposal
Product
Lifecycle

Design

Figure 2.2

would be binding for covered industries. For countries with existing systems, it is expected that
the GHS components will be applied within the framework/infrastructure of existing hazard
communication regulatory schemes. For example, exceptions and exemptions found in existing
regulations would not be expected to change (e.g., transportation of limited quantities).

However, the specific hazard criteria, classification processes, label elements and SDS
requirements within an existing regulation will need to be modified to be consistent with the
harmonized elements of the GHS. It is anticipated that ALL existing hazard communication
systems will need to be changed in order to apply the GHS. For example, in the U.S. EPA and
OSHA would be expected to require hazard pictograms/symbols on labels. Canada and the EU
would be expected to adopt the GHS pictograms/symbols instead of those currently in use. The
transport sector is expected to adopt the changed criteria (LD50/LC50) for the GHS Acute
Toxicity Categories 1 – 3. OSHA HCS, WHMIS and the EU would all need to change their acute
toxicity criteria.

Test data already generated for the classification of chemicals under existing systems should be
accepted when classifying these chemicals under the GHS, thereby avoiding duplicative testing
and the unnecessary use of test animals.

2.4 What is meant by GHS Building Blocks?
The GHS classification and communication requirements can be thought of as a collection of
building blocks. In regulatory schemes, coverage and communication of hazards vary by the
needs of target audiences/sectors. Accordingly, the GHS was designed to contain the hazard
endpoints and communication tools necessary for application to known regulatory schemes. The
GHS is structured so that the appropriate elements for classification and communication, which
address the target audiences, can be selected.

The full range of harmonized elements is available to everyone, and should be used if a country
or organization chooses to cover a certain effect when it adopts the GHS. The full range of these
elements does not have to be adopted. Countries can determine which of the building blocks will
be applied in different parts of their systems (consumer, workplace, transport, pesticides, etc.).
For example, some options for implementing the GHS include:

• Not using a GHS class (e.g., cancer, hazardous to the aquatic environment, etc.);
• Not using a GHS category (normally at the beginning or end of a class, e.g., Acute

Toxicity Cat. 5);
• Combining categories (e.g., Acute Toxicity Cat.# 1 and Cat.# 2; Skin Corrosion Cat.1A,

1B and 1C).

2.5 How should the GHS Building Blocks by applied?
Appropriate implementation of the GHS means that the hazards covered by a Competent
Authority (CA) are covered consistently with the GHS criteria and requirements. The EPA,
Health Canada and OSHA are examples of Competent Authorities. Competent Authorities will
decide how to apply the various elements of the GHS based on the CA needs and the needs of
target audiences.

When a regulatory scheme covers something that is in the GHS, and implements the GHS, that
coverage should be consistent. Once an endpoint and subclasses are selected, as needed, the GHS
classification criteria, assigned label elements and SDS provisions should be followed as
specified in the GHS. If a regulatory system covers carcinogenicity, for example, it should
follow the harmonized classification scheme, the harmonized label elements and, where
appropriate, the SDS. Figure 2.3 shows some of the hazard endpoint/subcategory and hazard
communication building block choices for the transport, workplace, consumer and pesticide
sectors.

To gain a better understanding of the building block approach, it is helpful to look at the specific
sectors/target audiences. The needs and regulations of the various sectors vary depending on the
type of chemical and use pattern. Different target audiences or sectors receive and use hazard
information in different ways. The primary sectors/target audiences are transport, workplace,
consumers and agriculture (pesticides). These sectors are described in more detail below.

2.5.1 Transport
For transport, it is expected that application of the GHS will be similar to application of current
transport requirements.

• GHS physical, acute and environmental hazard criteria are expected to be adopted in the
transport sector.

• Containers of dangerous goods will have pictograms that address acute toxicity, physical
hazards, and environmental hazards.

Figure 2.3

Hazard Classes:

Hazard Categories:

Environmental ?Cancer ?

Acute Tox Cat. 4 ? Acute Tox Cat. 5 ?
Cat.1A, Cat.1B, Cat.1C ?

GHS Building Blocks

Hazard Communication:

Etc. ?

SDS / MSDS ?

Corrosive to metals?

Category 1 ?

Skin Corrosion:

Transport, Workplace, Consumers, Pesticides, Etc.

• GHS hazard communication elements such as signal words, hazard statements and SDS
are not expected to be adopted in the transport sector.

2.5.2 Workplace
In the workplace, it is expected that most of the GHS elements will be adopted, including;

• GHS physical and health hazard criteria, as appropriate;
• Labels that have the harmonized core information under the GHS (signal words, hazard

statements and symbols, etc.);
• Safety Data Sheets;
• Employee training to help ensure effective communication is also anticipated;

All workplace systems may not have the jurisdiction to adopt environmental hazards.

2.5.3 Consumer
For the consumer sector, it is expected that labels will be the primary focus of GHS application.

• The appropriate GHS hazard criteria are expected to be adopted;
• These labels will include the core elements of the GHS (signal words, hazard statements

and symbols, etc.), subject to some sector-specific considerations in certain systems (e.g.,
risk-based labeling).

2.5.4 Pesticides
For pesticides, it is expected that the GHS will be adopted.

• The appropriate GHS hazard criteria are expected to be adopted;
• Pesticide labels will include the core elements of the GHS (signal words, hazard

statements and symbols, etc.), subject to some sector-specific considerations in certain
systems.

2.6 How will the GHS impact countries without existing regulations?
Developing and maintaining a classification and labeling system is not a simple task. The GHS
can be used as a tool for developing national regulations. It is expected that countries that do not
have systems will adopt GHS as their basic scheme. The GHS provides the building blocks from
which countries can construct chemical safety programs. Although the GHS will facilitate the
process, many challenges exist in creating new regulations. For example:

• What is the appropriate legal framework for adopting/implementing the GHS?
• What government agencies should be involved? Are there ministries/agencies ready to

implement and maintain the GHS?
• How will stakeholder cooperation and support for implementing the GHS be managed?

Work has begun in international organizations (e.g, UNITAR and ILO) under the guidance of the
UN GHS Sub-Committee, to develop technical assistance for developing countries to write new
regulations using the GHS elements. Guidance has been developed on how to implement a
national GHS action plan. Additionally, pilot implementations have begun in a few countries.
The opportunities and challenges learned from the pilot programs will be documented and are
expected to facilitate future implementations.

3.0 WHAT IS CLASSIFICATION?
Classification is the starting point for hazard communication. It involves the identification of the
hazard(s) of a chemical or mixture by assigning a category of hazard/danger using defined
criteria. The GHS is designed to be consistent and transparent. It draws a clear distinction
between classes and categories in order to allow for “self classification”. For many hazards a
decision tree approach (e.g., eye irritation) is provided in the GHS Document. For several
hazards the GHS criteria are semi-quantitative or qualitative. Expert judgment may be required
to interpret these data.

Figure 3.1

shows the
harmonized definition for
hazard classification, which can
be applied to all hazard
categories in the system.

The data used for classification
may be obtained from tests,
literature, and practical
experience. The GHS health
and environmental hazard
criteria/definitions are test
method neutral. Accordingly,
tests that determine hazardous
properties conducted according
to internationally recognized
scientific principles can be used for purposes of hazard classification.

The GHS endpoints that cover physical, health and environmental hazards are listed in Figures
3.2 and 3.3, respectively. As mentioned earlier, the GHS hazard definitions are criteria-based.
The following information provides an overview of the GHS definitions and classification
criteria. It is recommended that the person responsible for GHS implementation consult the
GHS Document or “Purple Book” for more complete information.

3.1 What are the GHS Physical Hazards?
The GHS physical hazards criteria, developed by the ILO and UNCETDG, were largely based on
the existing criteria used by the UN Model Regulation on the Transport of Dangerous Goods.
Therefore, many of the criteria are already being used on a worldwide basis. However, some
additions and changes were necessary since the scope of the GHS includes all target audiences.
The physical hazards classification process provides specific references to approved test methods
and criteria for classification. The GHS physical hazard criteria apply to mixtures. It is assumed
that mixtures will be tested for physical hazards.

In general, the GHS criteria for physical hazards are quantitative or semi-quantitative with
multiple hazard levels within an endpoint. This is different from several of the existing systems
that currently have qualitative criteria for various physical hazards (e.g., organic peroxide criteria

Hazard Classification

The term “hazard classification” is used to indicate that only the
intrinsic hazardous properties of substances and mixtures are
considered and involves the following 3 steps:

a) Identification of relevant data regarding the hazards of a

substance or mixture;
b) Subsequent review of those data to ascertain the hazards

associated with the substance or mixture; and
c) A decision on whether the substance or mixture will be classified

as a hazardous substance or mixture and the degree of hazard,
where appropriate, by comparison of the data with agreed hazard
classification criteria.

Figure 3.1

under WHMIS and OSHA HCS). This could make classification under the GHS more
consistent.

In developing GHS criteria for physical hazards it was
necessary to define physical states. In the GHS,

• a gas is a substance or mixture which at 50°C has
a vapor pressure greater than 300 kPa; or is
completely gaseous at 20°C and a standard
pressure of 101.3 kPa.

• a liquid is a substance or mixture that is not a gas
and which has a melting point or initial melting
point of 20°C or less at standard pressure of 101.3
kPa.

• a solid is a substance or mixture that does not
meet the definitions of a liquid or a gas.

The GHS physical hazards are briefly described below.
For many of the physical hazards the GHS Document
contains Guidance Sections with practical information to
assist in applying the criteria.

3.1.1 Explosives
An explosive substance (or mixture) is a solid or liquid which is in itself capable by chemical
reaction of producing gas at such a temperature and pressure and at such a speed as to cause
damage to the surroundings. Pyrotechnic substances are included even when they do not evolve
gases. A pyrotechnic substance (or mixture) is designed to produce an effect by heat, light,
sound, gas or smoke or a combination of these as the result of non-detonative, self-sustaining,
exothermic chemical reactions.

Classification as an explosive and allocation to a division is a three-step process:
• Ascertain if the material has explosive effects (Test Series 1);
• Acceptance procedure (Test Series 2 to 4);
• Assignment to one of six hazard divisions (Test Series 5 to 7).

Explosive properties are associated with certain chemical groups that can react to give very rapid
increases in temperature or pressure.
The GHS provides a screening
procedure that is aimed at identifying
the presence of such reactive groups
and the potential for rapid energy
release. If the screening procedure
identifies the substance or mixture to
be a potential explosive, the
acceptance procedure has to be

Figure 3.2

Physical Hazards

• Explosives
• Flammable Gases
• Flammable Aerosols
• Oxidizing Gases
• Gases Under Pressure
• Flammable Liquids
• Flammable Solids
• Self-Reactive Substances
• Pyrophoric Liquids
• Pyrophoric Solids
•

Self-Heating Substances

• Substances which, in contact with

water, emit flammable gases
• Oxidizing Liquids
• Oxidizing Solids
• Organic Peroxides
• Corrosive to Metals

Division Characteristics
1.1 Mass explosion hazard
1.2 Projection hazard
1.3 Fire hazard or minor projection hazard
1.4 No significant hazard
1.5 Very insensitive substances with mass explosion hazard
1.6 Extremely insensitive articles with no mass explosion hazard

Table 3.1 Explosives

performed.

Substances, mixtures and articles are assigned to one of six divisions, 1.1 to 1.6, depending on
the type of hazard they present. See, UN Manual of Tests and Criteria Part I Test Series 2 to 7.
Currently, only the transport sector uses six categories for explosives.

3.1.2 Flammable Gases

Flammable gas means a gas having a flammable range in air at 20°C and a standard pressure
of 101.3 kPa. Substances and mixtures of this hazard class are assigned to one of two hazard
categories on the basis of the outcome of the test or calculation method (ISO 10156:1996).

3.1.3 Flammable Aerosols
Aerosols are any gas compressed, liquefied or dissolved under pressure within a non-refillable
container made of metal, glass or plastic, with or without a liquid, paste or powder. The
container is fitted with a release device allowing the contents to be ejected as solid or liquid
particles in suspension in a gas, as a foam, paste or powder or in a liquid or gaseous state.

Aerosols should be considered for classification as either a Category 1 or Category 2 Flammable
Aerosol if they contain any component classified as flammable according to the GHS criteria for
flammable liquids, flammable gases, or flammable solids. Classification is based on:

• Concentration of flammable components;
• Chemical heat of combustion (mainly for transport/storage);
• Results from the foam test (foam aerosols) (mainly for worker/consumer);
• Ignition distance test (spray aerosols) (mainly for worker/consumer);
• Enclosed space test (spray aerosols) (mainly for worker/consumer).

Aerosols are considered:
• Nonflammable, if the concentration of the flammable components ≤ 1% and the heat of

combustion is < 20 kJ/g. • Extremely flammable, if the concentration of the flammable components >85% and the

heat of combustion is ≥ 30 kJ/g to avoid excessive testing.

See the UN Manual of Tests and Criteria for the test method.

3.1.4 Oxidizing Gases
Oxidizing gas means any gas which may, generally by providing oxygen, cause or contribute to
the combustion of other material more than air does. Substances and mixtures of this hazard class
are assigned to a single hazard category on the basis that, generally by providing oxygen, they
cause or contribute to the combustion of other material more than air does. The test method is
ISO 10156:1996. Currently, several workplace hazard communication systems cover oxidizers
(solids, liquids, gases) as a class of chemicals.

3.1.5 Gases under Pressure
Gases under pressure are gases that are contained in a receptacle at a pressure not less than 280
Pa at 20°C or as a refrigerated liquid. This endpoint covers four types of gases or gaseous
mixtures to address the effects of sudden release of pressure or freezing which may lead to
serious damage to people, property, or the environment independent of other hazards the gases
may pose.

For this group of gases, the following information is required:
• vapor pressure at 50°C;
• physical state at 20°C at standard ambient pressure;
• critical temperature.

Criteria that use the physical state or
compressed gases will be a different
classification basis for some
workplace systems.

Data can be found in the literature,
and calculated or determined by testing. Most pure gases are already classified in the UN Model
Regulations. Gases are classified, according to their physical state when packaged, into one of
four groups as shown in Table 3.2.

3.1.6 Flammable Liquids
Flammable liquid means a
liquid having a flash point of
not more than 93°C.
Substances and mixtures of
this hazard class are assigned
to one of four hazard
categories on the basis of the
flash point and boiling point (See Table 3.3). Flash Point is determined by closed cup methods
as provided in the GHS document, Chapter 2.5, paragraph 11.

3.1.7 Flammable Solids

Flammable solids are solids that are
readily combustible, or may cause or
contribute to fire through friction. Readily
combustible solids are powdered,
granular, or pasty substances which are
dangerous if they can be easily ignited by
brief contact with an ignition source, such
as a burning match, and if the flame
spreads rapidly.

Group Criteria
Compressed gas Entirely gaseous at – 50°C
Liquefied gas Partially liquid at temperatures > – 50°C
Refrigerated liquefied gas Partially liquid because of its low

temperature

Dissolved gas Dissolved in a liquid phase solvent

Category Criteria

1 Flash point < 23°C (73°F) and initial boiling point ≤ 35°C (95°F)

2 Flash point < 23 °C (73°F) and initial boiling point > 35°C (95°F)

3 Flash point ≥ 23 °C (73°F) and ≤ 60 °C (140°F)

4 Flash point > 60 °C (140°F) and ≤ 93 °C (200°F)

Category Criteria
1 Metal Powders: burning time ≤ 5 minutes

Others: wetted zone does not stop fire &
burning time < 45 seconds or burning > 2.2 mm/second

2 Metal Powders: burning time > 5 and ≤ 10 minutes

Others: wetted zone stop fire for at least 4 minutes &
burning time < 45 seconds or burning rate > 2.2 mm/second

Table 3.2 Gases under Pressure

Table 3.3 Flammable Liquids

Table 3.4 Flammable Solids

Substances and mixtures of this hazard class are assigned to one of two hazard categories (Table
3.4) on the basis of the outcome of the UN Test N.1 (UN Manual of Tests and Criteria). The
tests include burning time, burning rate and behavior of fire in a wetted zone of the test sample.

3.1.8 Self-Reactive Substances
Self-reactive substances are thermally unstable liquids or solids liable to undergo a strongly
exothermic thermal decomposition even without participation of oxygen (air). This definition
excludes materials classified under the GHS as explosive, organic peroxides or as oxidizing.
These materials may have similar properties, but such hazards are addressed in their specific
endpoints. There are exceptions to the self-reactive classification for material: (i) with heat of
decomposition <300 J/g or (ii) with self-accelerating decomposition temperature (SADT) > 75°C
for a 50 kg package.

Substances and mixtures of this hazard class are assigned to one of the seven ‘Types’, A to G, on
the basis of the outcome of the UN Test Series A to H (UN Manual of Tests and Criteria).
Currently, only the transport sector uses seven categories for self-reactive substances (Table 3.5).

Pyrophorics

3.1.9 Pyrophoric Liquids
A pyrophoric liquid is a liquid which, even in small quantities, is liable to ignite within five
minutes after coming into contact with air. Substances and mixtures of this hazard class are
assigned to a single hazard category on the basis of the outcome of the UN Test N.3 (UN Manual
of Tests and Criteria).

Type Criteria
A Can detonate or deflagrate rapidly, as packaged.
B Possess explosive properties and which, as packaged, neither detonates nor deflagrates rapidly, but is liable to undergo a

thermal explosion in that package.
C Possess explosive properties when the substance or mixture as packaged cannot detonate or deflagrate rapidly or undergo

thermal explosion.
D • Detonates partially, does not deflagrate rapidly and shows no violent effect when heated under confinement; or

• Does not detonate at all, deflagrates slowly and shows no violent effect when heated under confinement; or
• Does not detonate or deflagrate at all and shows a medium effect when heated under confinement.

E Neither detonates nor deflagrates at all and shows low or no effect when heated under confinement.
F Neither detonates in the cavitated bubble state nor deflagrates at all and shows only a low or no effect when heated under

confinement as well as low or no explosive power.
G Neither detonates in the cavitated state nor deflagrates at all and shows no effect when heated under confinement nor any

explosive power, provided that it is thermally stable (self-accelerating decomposition temperature is 60°C to 75°C for a 50 kg
package), and, for liquid mixtures, a diluent having a boiling point not less than 150°C is used for desensitization.

Table 3.5 Self-Reactive Substances

3.1.10 Pyrophoric Solids
A pyrophoric solid is a solid which, even in small quantities, is liable to ignite within five
minutes after coming into contact with air. Substances and mixtures of this hazard class are
assigned to a single hazard category on the basis of the outcome of the UN Test N.2 (UN Manual
of Tests and Criteria).

3.1.11 Self-Heating Substances
A self-heating substance is a solid or liquid, other than a pyrophoric substance, which, by
reaction with air and without energy supply, is liable to self-heat. This endpoint differs from a
pyrophoric substance in that it will ignite only when in large amounts (kilograms) and after long
periods of time (hours or days). Substances and mixtures of this hazard class are assigned to one
of two hazard categories on the basis of the outcome of the UN Test N.4 (UN Manual of Tests
and Criteria).

3.1.12 Substances which on Contact with Water Emit Flammable Gases
Substances that, in contact with water, emit flammable gases are solids or liquids which, by
interaction with water, are liable to become
spontaneously flammable or to give off
flammable gases in dangerous quantities.
Substances and mixtures of this hazard class
are assigned to one of three hazard categories
on the basis of test results (UN Test N.5 UN
Manual of Tests and Criteria) which measure
gas evolution and speed of evolution.

3.1.13 Oxidizing Liquids
An oxidizing liquid is a liquid which, while in itself not necessarily combustible, may, generally
by yielding oxygen, cause or contribute to the combustion of other material. Substances and
mixtures of this hazard class are assigned to one of three hazard categories on the basis of test
results (UN Test O.2 UN Manual of Tests and Criteria) which measure ignition or pressure rise
time compared to defined mixtures.

3.1.14 Oxidizing Solids
An oxidizing solid is a solid which, while in itself not necessarily combustible, may, generally by
yielding oxygen, cause or contribute to the combustion of other material. Substances and
mixtures of this hazard class are assigned to one of three hazard categories on the basis of test
results (UN Test O.1 UN Manual of Tests and Criteria) which measure mean burning time and
are compared to defined mixtures. Currently, several workplace hazard communication systems
cover oxidizers (solids, liquids, gases) as a class of chemicals.

Table 3.6 Substances which on Contact with Water Emit
Flammable Gases

Category Criteria
1 ≥10 L/kg/1 minute
2 ≥20 L/kg/1 hour + < 10 L/kg/1 min 3 ≥1 L/kg/1 hour + < 20 L/kg/1 hour

Not classified < 1 L/kg/1 hour

3.1.15 Organic Peroxides
An organic peroxide is an organic liquid or solid which contains the bivalent -0-0- structure and
may be considered a derivative of hydrogen peroxide, where one or both of the hydrogen atoms
have been replaced by organic radicals. The term also includes organic peroxide formulations
(mixtures). Such substances and mixtures may:

• be liable to explosive decomposition;
• burn rapidly;
• be sensitive to impact or friction;
• react dangerously with other substances.

Substances and mixtures of this hazard class are assigned to one of seven ‘Types’, A to G, on the
basis of the outcome of the UN Test Series A to H (UN Manual of Tests and Criteria). Currently,
only the transport sector uses seven categories for organic peroxides.

3.1.16 Substances Corrosive to Metal
A substance or a mixture that by chemical action will materially damage, or even destroy, metals
is termed ‘corrosive to metal’. These substances or mixtures are classified in a single hazard
category on the basis of tests (Steel: ISO 9328 (II): 1991 – Steel type P235; Aluminum: ASTM
G31-72 (1990) – non-clad types 7075-T6 or AZ5GU-T66). The GHS criteria are a corrosion rate
on steel or aluminum surfaces exceeding 6.25 mm per year at a test temperature of 55°C.

The concern in this case is the protection of metal equipment or installations in case of leakage
(e.g., plane, ship, tank), not material compatibility between the container/tank and the product.
This hazard is not currently covered in all systems.

Type Criteria
A Can detonate or deflagrate rapidly, as packaged.
B Possess explosive properties and which, as packaged, neither detonates nor deflagrates rapidly, but is liable to undergo a

thermal explosion in that package.
C Posses explosive properties when the substance or mixture as packaged cannot detonate or deflagrate rapidly or undergo a

thermal explosion.
D • Detonates partially, does not deflagrate rapidly and shows no violent effect when heated under confinement; or
• Does not detonate at all, deflagrates slowly and shows no violent effect when heated under confinement; or
• Does not detonate or deflagrate at all and shows a medium effect when heated under confinement.
E Neither detonates nor deflagrates at all and shows low or no effect when heated under confinement.
F Neither detonates in the cavitated bubble state nor deflagrates at all and shows only a low or no effect when heated under
confinement as well as low or no explosive power.
G Neither detonates in the cavitated state nor deflagrates at all and shows no effect when heated under confinement nor any
explosive power, provided that it is thermally stable (self-accelerating decomposition temperature is 60°C to 75°C for a 50 kg
package), and, for liquid mixtures, a diluent having a boiling point not less than 150°C is used for desensitization.

Table 3.7 Organic Peroxides

3.2 What are the GHS Health and Environmental Hazards?
The GHS health and environmental hazard criteria represent a harmonized approach for existing
classification systems (see Figure 3.3). The work at the OECD to develop the GHS criteria
included:

• A thorough analysis of existing classification systems, including the scientific basis for a
system and its criteria, its rationale and an explanation of the mode of use;

• A proposal for harmonized criteria for each category. For some categories the
harmonized approach was easy to develop because the existing systems had similar
approaches. In cases where the approach was different, a compromise consensus proposal
was developed.

• Health and environmental criteria were established for substances and mixtures.

The GHS Health and Environmental Endpoints
The following paragraphs briefly describe the GHS health and environmental endpoints. The
criteria for classifying substances are presented first. Then the GHS approach to classifying
mixtures is briefly discussed. It is recommended that the person responsible for GHS
implementation consult the GHS Document or “Purple Book” for more complete information.

Figure 3.3

Health Hazards

• Acute Toxicity
• Skin Corrosion/Irritation
• Serous Eye Damage/Eye Irritation
• Respiratory or Skin Sensitization
• Germ Cell Mutagenicity
• Carcinogenicity
• Reproductive Toxicology
• Target Organ Systemic Toxicity – Single Exposure
• Target Organ Systemic Toxicity – Repeated Exposure
• Aspiration Toxicity

Environmental Hazards

• Hazardous to the Aquatic Environment

o Acute aquatic toxicity
o Chronic aquatic toxicity

Bioaccumulation potential
Rapid degradability

3.2.1 Acute Toxicity
Five GHS categories have been included in the GHS Acute Toxicity scheme from which the
appropriate elements relevant to transport, consumer, worker and environment protection can be
selected. Substances are assigned to one of the five toxicity categories on the basis of LD50 (oral,
dermal) or LC50 (inhalation). The LC50 values are based on 4-hour tests in animals. The GHS
provides guidance on
converting 1-hour
inhalation test results to a 4-
hour equivalent. The five
categories are shown in the
Table 3.8 Acute Toxicity.

Category 1, the most severe
toxicity category, has cut-off
values currently used
primarily by the transport
sector for classification for
packing groups. Some
Competent Authorities may
consider combining Acute
Categories 1 and 2.
Category 5 is for chemicals
which are of relatively low
acute toxicity but which, under certain circumstances, may pose a hazard to vulnerable
populations. Criteria other than LD50/LC50 data are provided to identify substances in Category
5 unless a more hazardous class is warranted.

3.2.2 Skin Corrosion
Skin corrosion means the production of irreversible damage to the skin following the application
of a test substance for up to 4 hours. Substances and mixtures in this hazard class are assigned to
a single harmonized corrosion category. For Competent Authorities, such as transport packing
groups, needing more than one designation for corrosivity, up to three subcategories are provided
within the corrosive category. See the Skin Corrosion/Irritation Table 3.9.

Several factors should be considered in determining the corrosion potential before testing is
initiated:

• Human experience showing irreversible damage to the skin;

• Structure/activity or structure property relationship to a substance or mixture already
classified as corrosive;

• pH extremes of ≤ 2 and ≥ 11.5 including acid/alkali reserve capacity.

Acute
toxicity

Cat. 1 Cat. 2 Cat. 3 Cat. 4 Category 5

Oral
(mg/kg)

≤ 5 > 5
≤ 50

> 50
≤ 300

> 300
≤ 2000

Dermal
(mg/kg)

≤ 50 > 50
≤ 200

> 200
≤ 1000

> 1000
≤ 2000

Gases
(ppm)

≤ 100 > 100
≤ 500

> 500
≤ 2500

> 2500
≤ 5000

Vapors
(mg/l)

≤ 0.5 > 0.5
≤ 2.0

> 2.0
≤ 10

> 10
≤ 20

Dust &
mists (mg/l)

≤ 0.05 > 0.05
≤ 0.5

> 0.5
≤ 1.0

> 1.0
≤ 5

Criteria:
• Anticipated oral
LD50 between 2000
and 5000 mg/kg;
• Indication of
significant effect in
humans;*
• Any mortality at
class 4;*
• Significant clinical
signs at class 4;*
• Indications from
other studies.*
*If assignment to a
more hazardous class
is not warranted.

Table 3.8 Acute Toxicity

Category 1
Serious eye damage

Category 2
Eye Irritation

Reversible adverse effects on cornea, iris,
conjunctiva

Draize score:
Corneal opacity ≥ 1
Iritis ≥ 1
Redness ≥ 2
Chemosis ≥ 2

Irreversible damage 21
days after exposure

Draize score:
Corneal opacity ≥ 3
Iritis > 1.5

Irritant
Subcategory 2A

Reversible in 21 days

Mild Irritant
Subcategory 2B

Reversible in 7 days

3.2.3 Skin Irritation
Skin irritation means the production of reversible damage to the skin following the application of
a test substance for up to 4 hours. Substances and mixtures in this hazard class are assigned to a
single irritant category. For those authorities, such as pesticide regulators, wanting more than one
designation for skin irritation, an additional mild irritant category is provided. See the Skin
Corrosion/Irritation Table 3.9.

Several factors should be considered in determining the irritation potential before testing is
initiated:

• Human experience or data showing reversible damage to the skin following exposure of
up to 4 hours;

• Structure/activity or structure property relationship to a substance or mixture already
classified as an irritant.

3.2.4 Eye Effects
Several factors should be considered in determining the serious eye damage or eye irritation
potential before testing is initiated:

• Accumulated human and animal experience;

• Structure/activity or structure property relationship to a substance or mixture already
classified;

• pH extremes like ≤ 2 and ≥ 11.5
that may produce serious eye
damage.

Serious eye damage means the
production of tissue damage in the eye,
or serious physical decay of vision,
following application of a test substance
to the front surface of the eye, which is
not fully reversible within 21 days of
application. Substances and mixtures in
this hazard class are assigned to a single
harmonized category.

Skin Corrosion
Category 1

Skin Irritation
Category 2

Mild Skin Irritation
Category 3

Destruction of dermal tissue: visible necrosis in at least one
animal

Subcategory 1A
Exposure < 3 min. Observation < 1 hr,

Subcategory 1B
Exposure < 1 hr. Observation < 14 days

Subcategory 1C
Exposure < 4 hrs. Observation < 14 days

Reversible adverse effects
in dermal tissue

Draize score: ≥ 2.3 < 4.0 or persistent inflammation

Reversible adverse
effects in dermal tissue

Draize score: ≥ 1.5 < 2.3

Table 3.9 Skin Corrosion/Irritation

Table 3.10 Eye Effects

Eye irritation means changes in the eye following the application of a test substance to the front
surface of the eye, which are fully reversible within 21 days of application. Substances and
mixtures in this hazard class are assigned to a single harmonized hazard category. For
authorities, such as pesticide regulators, wanting more than one designation for eye irritation, one
of two subcategories can be selected, depending on whether the effects are reversible in 21 or 7
days.

3.2.5 Sensitization
Respiratory sensitizer means a substance that induces hypersensitivity of the airways following
inhalation of the substance. Substances and mixtures in this hazard class are assigned to one
hazard category.

Skin sensitizer means a substance that will induce an allergic response following skin contact.
The definition for “skin sensitizer” is equivalent to “contact sensitizer”. Substances and mixtures
in this hazard class are assigned to one hazard category. Consideration should be given to
classifying substances which cause immunological contact urticaria (an allergic disorder) as
contact sensitizers.

3.2.6 Germ Cell Mutagenicity
Mutagen means an agent giving rise to an increased occurrence of mutations in populations of
cells and/or organisms. Substances and mixtures in this hazard class are assigned to one of two
hazard categories. Category 1 has two subcategories. See the Germ Cell Mutagenicity (Table
3.11) below.

3.2.7 Carcinogenicity
Carcinogen means a chemical substance or a mixture of chemical substances which induce
cancer or increase its incidence. Substances and mixtures in this hazard class are assigned to one
of two hazard categories. Category 1 has two subcategories. The Carcinogenicity Guidance
Section in the GHS Document includes comments about IARC.

Category 1
Known / Presumed

Category 2
Suspected / Possible

Known to produce heritable mutations in human germ cells
Subcategory 1A

Positive evidence from
epidemiological studies

Subcategory 1B
Positive results in:
• In vivo heritable germ cell tests in
mammals
• Human germ cell tests
• In vivo somatic mutagenicity tests,
combined with some evidence of germ cell
mutagenicity

• May induce heritable mutations in human
germ cells
• Positive evidence from tests in mammals and
somatic cell tests
• In vivo somatic genotoxicity supported by in
vitro mutagenicity

Table 3.11 Germ Cell Mutagenicity

3.2.8 Reproductive Toxicity
Reproductive toxicity includeds adverse effects on sexual function and fertility in adult males
and females, as well as developmental toxicity in offspring. Substances and mixtures with
reproductive and/or developmental
effects are assigned to one of two
hazard categories, ‘known or
presumed’ and ‘suspected’. Category 1
has two subcategories for reproductive
and developmental effects. Materials
which cause concern for the health of
breastfed children have a separate
category, Effects on or Via Lactation.

3.2.9 Target Organ Systemic Toxicity (TOST): Single Exposure & Repeated Exposure
The GHS distinguishes between single and repeat exposure for Target Organ Effects. Some
existing systems distinguish between single and repeat exposure for these effects and some do
not. All significant health effects, not otherwise specifically included in the GHS, that can impair
function, both reversible and irreversible, immediate and/or delayed are included in the non-
lethal target organ/systemic toxicity class (TOST). Narcotic effects and respiratory tract irritation
are considered to be target organ systemic effects following a single exposure.

Substances and mixtures of the single exposure target organ toxicity hazard class are assigned to
one of three hazard categories in Table 3.14.

Category 1
Known or Presumed Carcinogen

Category 2
Suspected Carcinogen

Subcategory 1A
Known Human Carcinogen
Based on human evidence

Subcategory 1B
Presumed Human Carcinogen
Based on demonstrated animal
carcinogenicity

Limited evidence of human or animal
carcinogenicity

Table 3.12 Carcinogenicity

Table 3.14 TOST: Single Exposure
Category 1

Significant toxicity in humans

– Reliable, good quality human case
studies or epidemiological studies

Presumed significant toxicity in humans

• Animal studies with significant and/or
severe toxic effects relevant to humans
at generally low exposure (guidance)

Category 2

Presumed to be harmful to human
health

– Animal studies with significant
toxic effects relevant to humans
at generally moderate exposure
(guidance)

– Human evidence in exceptional
cases

Category 3

Transient target organ effects
– Narcotic effects
– Respiratory tract irritation

Table 3.13 Reproductive Toxicity
Category 1 Category 2

Suspected
Additional
Category

Known or presumed to cause effects on
human reproduction or on development

Category 1A
Known

Based on human
evidence

Category 1B
Presumed
Based on

experimental
animals

Human or
animal

evidence
possibly with

other
information

Effects on or
via lactation

Table 3.16 Aspiration Toxicity
Category 1: Known (regarded) human

– human evidence
– hydrocarbons with kinematic

viscosity ≤ 20.5 mm2/s at 40° C.

Category 2: Presumed human
– Based on animal studies
– surface tension, water solubility, boiling

point
– kinematic viscosity ≤ 14 mm2/s at 40º C

& not Category 1

Substances and mixtures of the repeated exposure target organ toxicity hazard class are assigned
to one of two hazard
categories in Table 3.15.

In order to help reach a
decision about whether a
substance should be
classified or not, and to what
degree it would be classified
(Category 1 vs. Category 2),
dose/concentration ‘guidance
values’ are provided in the
GHS. The guidance values and ranges for single and repeated doses are intended only for
guidance purposes. This means that they are to be used as part of the weight of evidence
approach, and to assist with decisions about classification. They are not intended as strict
demarcation values. The guidance value for repeated dose effects refer to effects seen in a
standard 90-day toxicity study conducted in rats. They can be used as a basis to extrapolate
equivalent guidance values for toxicity studies of greater or lesser duration.

3.2.10 Aspiration Hazard
Aspiration toxicity includes severe acute effects such as chemical pneumonia, varying degrees of
pulmonary injury or death following aspiration. Aspiration is the entry of a liquid or solid
directly through the oral or nasal cavity, or indirectly from vomiting, into the trachea and lower
respiratory system. Some
hydrocarbons (petroleum
distillates) and certain
chlorinated hydrocarbons
have been shown to pose
an aspiration hazard in
humans. Primary
alcohols, and ketones
have been shown to pose an aspiration hazard only in animal studies.

Substances and mixtures of this hazard class are assigned to one of two hazard categories this
hazard class on the basis of viscosity.

Category 1

Significant toxicity in humans
– Reliable, good quality human case studies

or epidemiological studies

Presumed significant toxicity in humans
– Animal studies with significant and/or severe

toxic effects relevant to humans at generally
low exposure (guidance)

Category 2

Presumed to be harmful to human health
– Animal studies with significant toxic

effects relevant to humans at
generally moderate exposure
(guidance)

– Human evidence in exceptional
cases

Table 3.15 TOST: Repeated Exposure

3.3 Environmental Hazards

3.3.1 Hazardous to the Aquatic Environment
The harmonized criteria are considered suitable for packaged goods in both supply and use in
multi-modal transport schemes. Elements of it may be used for bulk land transport and bulk
marine transport under MARPOL (International Convention for the Prevention of Pollution from
Ships) insofar as this uses aquatic toxicity. Two Guidance Documents (Annexes 8 and 9 of the
GHS Document) cover issues such as data interpretation and the application of the criteria to
special substances. Considering the complexity of this endpoint and the breadth of the
application, the Guidance Annexes are important in the application of the harmonized criteria.

3.3.1.1 Acute Aquatic Toxicity
Acute aquatic toxicity means the intrinsic property of a material to cause injury to an aquatic
organism in a short-term exposure. Substances and mixtures of this hazard class are assigned to
one of three toxicity categories on the basis of acute toxicity data: LC50 (fish) or EC50 (crustacea)
or ErC50 (for algae or other aquatic plants). In some regulatory systems these acute toxicity
categories may be subdivided or extended for certain sectors.

3.3.1.2 Chronic Aquatic Toxicity
Chronic aquatic toxicity means the potential or actual properties of a material to cause adverse
effects to aquatic organisms during exposures that are determined in relation to the lifecycle of
the organism. Substances and mixtures in this hazard class are assigned to one of four toxicity
categories on the basis of acute data and environmental fate data: LC50 (fish) or EC50 (crustacea)
or ErC50 (for algae or other aquatic plants) and degradation/bioaccumulation.

While experimentally derived test data are preferred, where no experimental data are available,
validated Quantitative Structure Activity Relationships (QSARs) for aquatic toxicity and log
KOW may be used in the classification process. The log KOW is a surrogate for a measured
Bioconcentration Factor (BCF), where such a measured BCF value would always take
precedence.

Chronic Category IV is considered a “safety net” classification for use when the available data
do not allow classification under the formal criteria, but there are some grounds for concern.

Acute Cat. I
Acute toxicity ≤1.00 mg/l

Acute Cat. II
Acute toxicity > 1.00 but ≤ 10.0 mg/l

Acute Cat. III
Acute toxicity > 10.0 but < 100 mg/l

Chronic Cat. I
Acute toxicity

≤ 1.00 mg/l and lack of rapid
degradability and log Kow ≥ 4

unless BCF < 500

Chronic Cat. II
Acute toxicity

> 1.00 but ≤ 10.0 mg/l and lack of
rapid degradability and log Kow ≥ 4

unless BCF < 500 and unless

chronic toxicity > 1 mg/l

Chronic Cat. III
Acute toxicity

> 10.0 but ≤ 100.0 mg/l and lack of
rapid degradability and log Kow ≥ 4

unless BCF < 500 and unless chronic toxicity > 1 mg/l

Chronic Cat. IV
Acute toxicity

> 100 mg/l and lack of rapid
degradability and log Kow ≥ 4
unless BCF < 500 and unless

chronic toxicity > 1 mg/l

Table 3.17 Acute & Chronic Aquatic Toxicity

3.4 What is the GHS approach to classifying mixtures?
For consistency and understanding the provisions for classifying mixtures, the GHS defines
certain terms. These working definitions are for the purpose of evaluating or determining the
hazards of a product for classification and labeling.

Substance: Chemical elements and their compounds in the natural state or obtained by
any production process, including any additive necessary to preserve the stability of the
product and any impurities deriving from the process used, but excluding any solvent
which may be separated without affecting the stability of the substance or changing its
composition.

Mixture: Mixtures or solutions composed of two or more substances in which they do
not react.

Alloy: An alloy is a metallic material, homogeneous on a macroscopic scale, consisting
of two or more elements so combined that they cannot be readily separated by
mechanical means. Alloys are considered to be mixtures for the purpose of
classification under the GHS.

Where impurities, additives or individual constituents of a substance or mixture have been
identified and are themselves classified, they should be taken into account during classification if
they exceed the cutoff value/concentration limit for a given hazard class.

As mentioned previously, the GHS physical

hazard criteria apply to mixtures. It is assumed
that mixtures will be tested for physical hazards.
Each health and environmental endpoint chapter
in the GHS contains specific criteria for
classifying mixtures as well as substances. The
GHS Document or “Purple Book” should be
consulted for complete information on
classifying mixtures.

The process established for classifying a mixture
allows the use of (a) available data for the
mixture itself and/or (b) similar mixtures and/or
(c) data for ingredients of the mixture. The GHS approach to the classification of mixtures for
health and environmental hazards is tiered, and is dependent upon the amount of information
available for the mixture itself and for its components. The process for the classification of
mixtures is based on the following steps:

Tier Approach to Classification of Mixtures

Generally, use test data for the mixture, if
available,

Compared to substance hazard criteria

Use bridging principles, if applicable

Estimate hazard(s) based on the known
component information

Figure 3-4

(1) Where test data are available for the mixture itself, the classification of the mixture will be
based on that data (See exception for carcinogens, mutagens & reproductive toxins in the GHS
Document); (2) Where test data are not available for the mixture itself, then the appropriate
bridging principles (as described below) in the specific chapter should be used; (3) If (i) test data
are not available for the mixture itself, and (ii) the bridging principles cannot be applied, then use
the calculation or cutoff values described in the specific endpoint to classify the mixture.

3.5 What are bridging principles?
Bridging principles are an important concept in the GHS for classifying untested mixtures. When
a mixture has not been tested, but there are sufficient data on the components and/or similar
tested mixtures, these data can be used in accordance with the following bridging principles:

• Dilution: If a mixture is diluted with a diluent that has an equivalent or lower toxicity,
then the hazards of the new mixture are assumed to be equivalent to the original.

• Batching: If a batch of a complex substance is produced under a controlled process, then
the hazards of the new batch are assumed to be equivalent to the previous batches.

• Concentration of Highly Toxic Mixtures: If a mixture is severely hazardous, then a
concentrated mixture is also assumed to be severely hazardous

• Interpolation within One Toxic Category: Mixtures having component concentrations
within a range where the hazards are known are assumed to have those known hazards.

• Substantially Similar Mixtures: Slight changes in the concentrations of components are
not expected to change the hazards of a mixture and substitutions involving
toxicologically similar components are not expected to change the hazards of a mixture

• Aerosols: An aerosol form of a mixture is assumed to have the same hazards as the
tested, non-aerosolized form of the mixture unless the propellant affects the hazards upon
spraying.

All bridging principles do not apply to every health and environmental endpoint. Consult each
endpoint to determine which bridging principles apply.

When the bridging principles do not apply or ca not be used, the health and environmental
hazards of mixtures are estimated based on component information. In the GHS, the
methodology used to estimate these hazards varies by endpoint. The GHS Document or “Purple
Book” should be consulted for more complete information on classifying mixtures. Figure 3.5
summarizes the GHS mixtures approach for the various health and environmental endpoints.

3.6 What testing is required?
The GHS itself does not include requirements for testing substances or mixtures. Therefore, there
is no requirement under the GHS to generate test data for any hazard class. Some parts of
regulatory systems may require data to be generated (e.g., for pesticides), but these requirements
are not related specifically to the GHS. The GHS criteria for determining health and
environmental hazards are test method neutral, allowing different approaches as long as they are
scientifically sound and validated according to international procedures and criteria already

referred to in existing systems. Test data already generated for the classification of chemicals
under existing systems should be accepted when classifying these chemicals under the GHS,
thereby avoiding duplicative testing and the unnecessary use of test animals. The GHS physical
hazard criteria are linked to specific test methods. It is assumed that mixtures will be tested for
physical hazards.

Hazard Endpoint Classification Approach Bridging Principles Comments
Acute toxicity Acute Toxicity Estimate

(ATE): 2 formulas
All Conversion values, relevant components

usually at ≥ 1%

Serious Eye
Damage & Eye
Irritation

Mostly additivity approach,
sometimes cutoffs

All Relevant components usually at ≥ 1%,
exceptions for certain chemical classes

Skin corrosion &
Skin Irritation

Mostly additivity approach,
sometimes cutoffs

All Relevant components usually at ≥ 1%,
exceptions for certain chemical classes

Skin Sensitization

Cutoffs with CA options Dilution, Batching, Substantially
similar mixtures, Aerosols

Respiratory
Sensitization

Cutoffs with CA options Dilution, Batching, Substantially
similar mixtures, Aerosols

Germ Cell
Mutagenicity

Cutoffs Dilution, Batching, Substantially
similar mixtures

Mixture test data only case-by case

Carcinogenicity

Cutoffs with CA options Dilution, Batching, Substantially
similar mixtures

Mixture test data only case-by-case

Reproductive
Toxicity

Cutoffs with CA options Dilution, Batching, Substantially
similar mixtures
Mixture test data only case-by-case

Target Organ
Systemic Toxicity

Cutoffs with CA options All

Aspiration
Toxicity

Cutoffs

Dilution, Batching,
Concentration of highly toxic
mixtures, Interpolation within
one toxicity category,
Substantially similar mixtures

Figure 3.5 GHS Mixtures

Hazard Endpoint Classification Approach Bridging Principles Comments
Hazardous to the
Aquatic
Environment

Additivity Formula (Acute
only); Summation Method
(Acute or Chronic);
Combination of Additivity
Formula & Summation
Method

Dilution, Batching,
Concentration of highly toxic
mixtures, Interpolation within
one toxicity category,
Substantially similar mixtures

Relevant components usually at ≥ 1%,
Mixture test data only case-by-case for
chronic

4. HAZARD COMMUNICATION
Section 3, explained that classification is the starting point for the GHS. Once a chemical has
been classified, the hazard(s) must be communicated to target audiences. As in existing systems,
labels and Safety Data Sheets are the main tools for chemical hazard communication. They
identify the hazardous properties of chemicals that may pose a health, physical or environmental
hazard during normal handling or use. The goal of the GHS is to identify the intrinsic hazards
found in chemical substances and mixtures, and to convey information about these hazards.

The international mandate for the GHS included the development of a harmonized hazard
communication system, including labeling, Safety Data Sheets and easily understandable
symbols, based on the classification criteria developed for the GHS.

4.1 What factors influenced development of the GHS communication tools?
Early in the process of developing the GHS communication tools, several significant issues were
recognized. One of the most important was comprehensibility of the information provided.
After all, the aim of the system is to present hazard information in a manner that the intended
audience can easily understand and that will thus minimize the possibility of adverse effects
resulting from exposure. The GHS identifies some guiding principles to assist in this process:

• Information should be conveyed in more than one way, e.g., text and symbols;
• The comprehensibility of the components of the system should take account of existing

studies and literature as well as any evidence gained from testing;
• The phrases used to indicate degree (severity) of hazard should be consistent across the

health, physical and environmental hazards.

Comprehensibility is challenging for a single culture and language. Global harmonization has
numerous complexities. Some factors that affected the work include:

• Different philosophies in existing systems on how and what should be communicated;
• Language differences around the world;
• Ability to translate phrases meaningfully;
• Ability to understand and appropriately respond to symbols/pictograms.

These factors were considered in developing the GHS communication tools. The GHS Purple
Book includes a comprehensibility-testing instrument in Annex 6.

4.2 Labels

4.2.1 What does a label look like?

Existing systems have labels that look different for the same product. We know that this leads to
worker confusion, consumer uncertainty and the need for additional resources to maintain
different systems. In the U.S. as well as in other countries, chemical products are regulated by
sector/target audience. Different agencies regulate the workplace, consumers, agricultural
chemicals and transport. Labels for these sectors/target audiences vary both in the U.S. and
globally.

In order to understand the value of the GHS and its benefits to all stakeholders, it is instructive to
look at the different labels for one fictional product. In the U.S. the product, ToxiFlam, which
has a flash point of 120°F and has an oral LD50 of 275 mg/kg, has different labels for different
sectors/target audiences. Label examples as seen in the U.S.A. are shown first, followed by
international examples.

44..22..22 UUSSAA EExxaammpplleess::

WWoorrkkppllaaccee aanndd WWoorrkkeerrss

In the U.S., regulatory requirements for
workplace labels are ‘performance oriented’.
This results at a minimum in a straightforward
label that has a product identity, hazard statement
and supplier identification (Figure 4.1). Some
products can also have additional labeling
requirements depending on their end use.

However, many companies follow the voluntary
ANSI Z129.1 Precautionary Labeling Standard
for workplace labeling and often use it also for
labeling consumer products. The American National Standards Institute (ANSI) standard
includes several label elements that are core to the GHS as well as other helpful elements to
assist users in safe handling (Figure 4.2).

ToxiFlam
TOXIC

COMBUSTIBLE LIQUID AND
VAPOR

My Company, My Street, MyTown NJ
00000

Tel: 444 999 9999

ToxiFlam (Contains XYZ)

WARNING ! HARMFUL IF SWALLOWED, FLAMMABLE LIQUID AND
VAPOR

Do not taste or swallow. Do not take internally. Wash thoroughly after handling. Keep
away from heat, sparks and flame. Keep container closed. Use only with adequate

ventilation.

FIRST AID:

If swallowed, do NOT induce vomiting unless directed to do so by medical
personnel. Never give anything by mouth to an unconscious person.

In Case of Fire, use water fog, dry chemical, CO2, or alcohol foam. Water may be
ineffective.
Flash Point = 120°F. Residue vapor may explode or ignite on ignition; do not cut, drill,
grind, or weld on or near this container.

See Material Safety Data Sheet for further details regarding safe use of this product.

My Company, My Street, MyTown NJ 00000, Tel: 444 999 9999

Figure 4.1

Figure 4.2

CCoonnssuummeerr PPrroodduuccttss aanndd CCoonnssuummeerrss

In several countries
consumer products are
regulated separately
from workplace
chemicals. In the U.S.
the CPSC regulates
consumer

products.

Consumer products have
required label elements,
but only the signal
words are specified. The
ANSI labeling standard
is often used in
developing consumer
labels.

TTrraannssppoorrtt aanndd EEmmeerrggeennccyy RReessppoonnddeerrss

For hazardous products being transported, outer containers have required label elements, product
identifier and hazard symbols. Transportation requirements are in addition to workplace or end
use label requirements.

AAggrriiccuullttuurraall CChheemmiiccaallss aanndd PPeessttiicciiddeess

In many systems, agricultural chemicals often have special label requirements. In the U.S. the
EPA is the agency covering these chemicals. A pesticide product with the same hazards as
ToxiFlam would have a label developed using FIFRA requirements. FIFRA has requirements for
product identity, chemical identity, signal word, hazard statements, and precautionary measures
including first aid.

ToxiFlam
(Contains XYZ)

WARNING! TOXIC, COMBUSTIBLE LIQUID AND VAPOR

Do not taste or swallow. Do not take internally. Wash thoroughly after
handling. Keep away from heat, sparks and flame. Keep container closed.

Use only with adequate ventilation.
FIRST AID

If swallowed, do NOT induce vomiting unless directed to do so by medical
personnel. Never give anything by mouth to an unconscious person.

Keep out of the reach of children.

My Company, My Street, MyTown NJ 00000, Tel: 444 999 9999

Figure 4.3

Figure 4.4

Flammable liquids, toxic, n.o.s. (contains XYZ)
UN 1992

MyCompany, MyStreet NJ 00000

44..22..33 IInntteerrnnaattiioonnaall EExxaammpplleess
All the previous examples are specific to the U.S. Many companies do business globally. So in
addition to the U.S. regulations, these companies would need to comply with the corresponding
regulations in the countries to which they export products. Canada and the EU are two existing
systems that were considered in the development of the GHS. To illustrate the differences in
labeling, it is interesting to examine an EU and Canadian label for ToxiFlam.

EEuurrooppeeaann UUnniioonn LLaabbeell

Labels in the EU have chemical identity, symbols, and R/S (Risk and Safety) phrases which are
hazard statements, precautionary measures and first aid.

Figure 4.5

Figure 4.6

ToxiFlam
Active/ Inerts : Contains XYZ %

KEEP OUT OF THE REACH OF CHILDREN

PRECAUTIONARY STATEMENTS – HAZARDS TO HUMANS AND DOMESTIC ANIMALS:
WARNING: May be fatal if swallowed. Wash thoroughly with soap and water after handling and before eating, drinking
or using tobacco .
PHYSICAL AND CHEMICAL HAZARDS: Combustible. Do not use or store near heat or open flame.
FIRST AID:
If swallowed – Call a poison control center or doctor immediately for treatment advice.

-Have person sip a glass of water if able to swallow.
-Do not induce vomiting unless told to do so by a poison control center or doctor.
-Do not give anything by mouth to an unconscious person.

My Company, My Street, MyTown AZ 00000, Tel: 444 999 9999
EPA Est . No. 5840-AZ-1 EPA Reg. No. 3120-280

ToxiFlam (contains XYZ)

Harmful If Swallowed. (R22)
Flammable. (R10)

Keep away from food, drink and animal feedingstuffs. (S13)
Wear suitable protective clothing. (S36)
If swallowed, seek medical advice immediately and show this
Container label. (S46)
In case of fire, use water, fog, CO2, or alcohol foam. (S43)

My Company, My Street, MyTown XX 00000 Tel: 44 22 999 9999

CCaannaaddiiaann WWoorrkkppllaaccee HHaazzaarrddoouuss MMaatteerriiaallss IIddeennttiiffiiccaattiioonn SSyysstteemm ((WWHHMMIISS)) LLaabbeell

The WHMIS label requires product identifier, hazard symbol, hazard statement, precautionary
measures, first aid, MSDS statement and supplier identification. In addition to these common
label elements, WHMIS requires a hatched border.

4.3 What are the GHS label elements?
Some GHS label elements have been standardized (identical with no variation) and are directly
related to the endpoints and hazard level. Other label elements are harmonized with common
definitions and/or principles. See Figure 4.8 for an illustration of the GHS label elements.

The standardized label elements included in the GHS are:

• Symbols (hazard pictograms): Convey health, physical and environmental hazard
information, assigned to a GHS hazard class and category.

• Signal Words: “Danger” or “Warning” are used to emphasize hazards and indicate the
relative level of severity of the hazard, assigned to a GHS hazard class and category.

• Hazard Statements: Standard phrases assigned to a hazard class and category that
describe the nature of the hazard.

The symbols, signal words, and hazard statements have all been standardized and assigned to
specific hazard categories and classes, as appropriate. This approach makes it easier for
countries to implement the system and should make it easier for companies to comply with
regulations based on the GHS. The prescribed symbols, signal words, and hazard statements can
be readily selected from Annex 1 of the GHS Purple Book. These standardized elements are not
subject to variation, and should appear on the GHS label as indicated in the GHS for each hazard
category/class in the system. The use of symbols, signal words or hazard statements other than
those that have been assigned to each of the GHS hazards would be contrary to harmonization.

Figure 4.7

ToxiFlam

TOXIC
COMBUSTIBLE LIQUID AND VAPOR

Do not taste or swallow. Do not take internally. Wash thoroughly after handling. Keep away from heat,
sparks and flame. Keep container closed. Use only with adequate ventilation.

FIRST AID
If swallowed, do NOT induce vomiting unless directed to do so by medical personnel. Never give anything
by mouth to an unconscious person.

See Material Safety Data Sheet for further details regarding safe use of this product.
My Company, My Street, MyTown NJ 00000, Tel: 444 999 9999

See
1.4.10.5.2 (c)
and Annex 3

See 1.4.10.5.2 (e)

See 1.4.10.5.2
(c) and Annex 3

See 1.4.10.5.4.2

GHS Label Elements
Product Name or Identifier

(Identify Hazardous Ingredients, where appropriate)

Signal Word

Physical, Health, Environmental
Hazard Statements

Supplemental Information

Precautionary Measures & Pictograms

First Aid Statements

Name and Address of Company

Telephone Number

See 1.4.10.5.2 (d)

See 1.4.10.5.2 (a)

See 1.4.10.5.2 (c)
and Annexes 1, 2

See 1.4.10.5.2 (b)
and Annexes 1, 2

Figure 4.8

The Section numbers refer to the sections in the GHS Document or “Purple Book”.

4.3.1 Symbols/Pictograms
The GHS symbols have been incorporated into pictograms for use on the GHS label. Pictograms
include the harmonized hazard symbols plus other graphic elements, such as borders,
background patterns or colors which are intended to convey specific information. For transport,
pictograms (Table 4.10) will have the background, symbol and colors currently used in the UN
Recommendations on the Transport of Dangerous Goods, Model Regulations. For other sectors,
pictograms (Table 4.9) will have a black symbol on a white background with a red diamond
frame. A black frame may be used for shipments within one country. Where a transport
pictogram appears, the GHS pictogram for the same hazard should not appear.

4.3.2 Signal Words
The signal word indicates the relative degree of severity a hazard. The signal words used in the
GHS are

“Danger” for the more severe hazards, and

“Warning” for the less severe hazards.

Signal words are standardized and assigned to the hazard categories within endpoints. Some
lower level hazard categories do not use signal words. Only one signal word corresponding to the
class of the most severe hazard should be used on a label.

4.3.3 Hazard Statements
Hazard statements are standardized and assigned phrases that describe the hazard(s) as
determined by hazard classification. An appropriate statement for each GHS hazard should be
included on the label for products possessing more than one hazard.

The assigned label elements are provided in each hazard chapter of the Purple Book as well as in
Annexes 1 & 2. Figure 4-11 illustrates the assignment of standardized GHS label elements for
the acute oral toxicity categories.

Figure 4.9

GHS Pictograms and Hazard Classes

• Oxidizers

• Flammables
• Self Reactives
• Pyrophorics
• Self-Heating
• Emits Flammable Gas
• Organic Peroxides

• Explosives
• Self Reactives
• Organic Peroxides

• Acute toxicity (severe) • Corrosives • Gases Under Pressure

• Carcinogen
• Respiratory Sensitizer
• Reproductive Toxicity
• Target Organ Toxicity
• Mutagenicity
• Aspiration Toxicity

• Environmental
Toxicity

• Irritant
• Dermal Sensitizer
• Acute toxicity (harmful)
• Narcotic Effects
• Respiratory Tract
Irritation

Figure 4.10

Transport “Pictograms”

Flammable Liquid
Flammable Gas

Flammable Aerosol

Flammable solid
Self-Reactive Substances

Pyrophorics
(Spontaneously
Combustible)

Self-Heating Substances

Substances, which in
contact with water, emit

flammable gases
(Dangerous When Wet)

Oxidizing Gases
Oxidizing Liquids
Oxidizing Solids

Explosive
Divisions 1.1, 1.2, 1.3

Explosive Division 1.4 Explosive Division 1.5 Explosive Division 1.6

Compressed Gases Acute Toxicity (Poison):
Oral, Dermal, Inhalation

Corrosive

Marine Pollutant Organic Peroxides

ACUTE ORAL TOXICITY – Annex 1
Category 1 Category 2 Category 3 Category 4 Category 5

LD50

Pictogram

Signal word

Hazard
statement

≤ 5 mg/kg

Danger

Fatal if swallowed

> 5 < 50 mg/kg

Danger

Fatal if swallowed

≥ 50 < 300 mg/kg

Danger

Toxic if swallowed

≥ 300 < 2000 mg/kg

Warning

Harmful if
swallowed

≥ 2000 < 5000 mg/kg

No symbol

Warning

May be
harmful if
swallowed

Other GHS label elements include:

• Precautionary Statements and Pictograms: Measures to minimize or prevent adverse
effects.

• Product Identifier (ingredient disclosure): Name or number used for a hazardous
product on a label or in the SDS.

• Supplier identification: The name, address and telephone number should be provided on
the label.

• Supplemental information: non-harmonized information.

4.3.4 Precautionary Statements and Pictograms
Precautionary information supplements the hazard information by briefly providing measures to
be taken to minimize or prevent adverse effects from physical, health or environmental hazards.
First aid is included in precautionary information. The GHS label should include appropriate
precautionary information. Annex 3 of the GHS Purple Book includes precautionary statements
and pictograms that can be used on labels.

Annex 3 includes four types of precautionary statements covering: prevention, response in cases
of accidental spillage or exposure, storage, and disposal. The precautionary statements have been
linked to each GHS hazard statement and type of hazard. The goal is to promote consistent use of
precautionary statements. Annex 3 is guidance and is expected to be further refined and
developed over time.

Figure 4.11

4.3.5 Product Identifier (Ingredient Disclosure)
A product identifier should be used on a GHS label and it should match the product identifier
used on the SDS. Where a substance or mixture is covered by the UN Model Regulations on the
Transport of Dangerous Goods, the UN proper shipping name should also be used on the
package.

The GHS label for a substance should include the chemical identity of the substance (name as
determined by IUPAC, ISO, CAS or technical name). For mixtures/alloys, the label should
include the chemical identities of all ingredients that contribute to acute toxicity, skin corrosion
or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, skin or
respiratory sensitization, or Target Organ Systemic Toxicity (TOST), when these hazards appear
on the label. Where a product is supplied exclusively for workplace use, the Competent
Authority may give suppliers discretion to include chemical identities on the SDS, in lieu of
including them on labels. The Competent Authority rules for confidential business information
(CBI) take priority over the rules for product identification.

4.3.6 Supplier Identification
The name, address and telephone number of the manufacturer or supplier of the product should
be provided on the label.

4.3.7 Supplemental Information
Supplemental label information is non-harmonized information on the container of a hazardous
product that is not required or specified under the GHS. In some cases this information may be
required by a Competent Authority or it may be additional information provided at the discretion
of the manufacturer/distributor. The GHS provides guidance to ensure that supplemental
information does not lead to wide variation in information or undermine the GHS information.
Supplemental information may be used to provide further detail that does not contradict or cast
doubt on the validity of the standardized hazard information. It also may be used to provide
information about hazards not yet incorporated into the GHS. The labeler should have the option
of providing supplementary information related to the hazard, such as physical state or route of
exposure, with the hazard statement.

4.4 How are multiple hazards handled on labels?
Where a substance or mixture presents more than one GHS hazard, there is a GHS precedence
scheme for pictograms and signal words. For substances and mixtures covered by the UN
Recommendations on the Transport of Dangerous Goods, Model Regulations, the precedence of
symbols for physical hazards should follow the rules of the UN Model Regulations. For health
hazards the following principles of precedence apply for symbols:

(a) if the skull and crossbones applies, the exclamation mark should not appear;

(b) if the corrosive symbol applies, the exclamation mark should not appear where it is
used for skin or eye irritation;

(c) if the health hazard symbol appears for respiratory sensitization, the exclamation mark
should not appear where it is used for skin sensitization or for skin or eye irritation.

If the signal word ‘Danger’ applies, the signal word ‘Warning’ should not appear. All assigned
hazard statements should appear on the label. The Competent Authority may choose to specify
the order in which they appear.

4.5 Is there a specific GHS label format / layout?
The GHS hazard pictograms, signal word and hazard statements should be located together on
the label. The actual label format or layout is not specified in the GHS. National authorities may
choose to specify where information should appear on the label or allow supplier discretion.

Figure 4.12 shows an example of a GHS label for the fictional product ‘ToxiFlam’. The core
GHS label elements are expected to replace the need for the array of different labels shown
earlier for ToxiFlam. (Figure 4.8 also illustrates the GHS label elements.)

There has been discussion about the size of GHS pictograms and that a GHS pictogram might be
confused with a transport pictogram or “diamond”. Transport pictograms (Table 4.10) are
different in appearance than the GHS pictograms (Table 4.9). Annex 7 of the Purple Book
explains how the GHS pictograms are expected to be proportional to the size of the label text. So
that generally the GHS pictograms would be smaller than the transport pictograms.

Several arrangements for GHS labels are
also provided in Annex 7 of the Purple
Book. Figure 4.13 shows an arrangement
for a combination packaging with an
outer shipping box and inner bottles.
The shipping box has a transportation

Figure 4.12 Example GHS Inner Container Label (e.g., bottle inside a shipping box)

Figure 4.13 Combination Packaging (Outer box
with inner bottles)

pictogram. The inner bottles have a GHS label with a GHS pictogram.

For a container such as a 55 gallon drum, the transport required markings and pictograms may be
combined with the GHS label elements or presented separately. In Figure 4.14 a
label arrangement for a single
packaging such as a 55 gallon drum is
shown. Pictograms and markings
required by the transport regulations
as well as GHS label and non-duplicative
GHS pictogram are shown on the drum.

A label merging the transportation requirements and the GHS requirements into one label for the
fictional product “ToxiFlam” is shown in Figure 4.15. This combined type label could also be
used on a 55 gallon drum.

Figure 4.15 Example GHS Outer Container Label (55 gallon/200 liter drum)

4.6 What about risk?

Competent Authorities may vary the application of the components of the GHS by the type of
product (industrial, pesticide, consumer, etc.) or the stage in the lifecycle (workplace, farm, retail
store, etc.). Once a chemical is classified, the likelihood of adverse effects may be considered in
deciding what informational or other steps should be taken for a given product or use setting.
Annex 5 of the GHS Purple Book includes a discussion of an example of how risk-based labeling
could be considered for chronic health effects of consumer products in the consumer use setting.

Figure 4.14 Combination Packaging (Outer box
with inner bottles)

4.7 Are workplace containers covered in the GHS ?
Products falling within the scope of the GHS will carry the GHS label at the point where they are
supplied to the workplace, and that label should be maintained on the supplied container in the
workplace. The GHS label or label elements can also be used for workplace containers (e.g.,
storage tanks). However, the Competent Authority can allow employers to use alternative means
of giving workers the same information in a different written or displayed format when such a
format is more appropriate to the workplace and communicates the information as effectively as
the GHS label. For example, label information could be displayed in the work area, rather than
on the individual containers. Some examples of workplace situations where chemicals may be
transferred from supplier containers include: containers for laboratory testing, storage vessels,
piping or process reaction systems or temporary containers where the chemical will be used by
one worker within a short timeframe.

4.8 What is the GHS Safety Data Sheet (SDS)?
The (Material) Safety Data Sheet (SDS) provides comprehensive information for use in
workplace chemical management. Employers and workers use the SDS as sources of
information about hazards and to obtain advice on safety precautions. The SDS is product
related and, usually, is not able to provide information that is specific for any given workplace
where the product may be used. However, the SDS information enables the employer to develop
an active program of worker protection measures, including training, which is specific to the
individual workplace and to consider any measures that may be necessary to protect the
environment. Information in a SDS also provides a source of information for other target
audiences such as those involved with the transport of dangerous goods, emergency responders,
poison centers, those involved with the professional use of pesticides and consumers.

The SDS should contain 16 headings (Figure 4.14). The GHS MSDS headings, sequence and
content are similar to the ISO, EU and ANSI MSDS/SDS requirements, except that the order of
sections 2 and 3 have been reversed. The SDS should provide a clear description of the data
used to identify the hazards. Figure 4.14 and the GHS Purple Book provide the minimum
information that is required in each section of the SDS. Examples of draft GHS SDSs are
provided in Appendix B of this guidance document.

The revised Purple Book contains guidance on developing a GHS SDS (Annex 4). Other
resources for SDSs include:

• ILO Standard under the Recommendation 177 on Safety in the Use of Chemicals at
Work,

• International Standard 11014-1 (1994) of the International Standard Organization (ISO)
and ISO Safety Data Sheet for Chemical Products 11014-1: 2003 DRAFT,

• American National Standards Institute (ANSI) Standard Z400.1,
• European Union SDS Directive 91/155/-EEC.

Figure 4.14

Minimum information for an SDS

1. Identification of the substance
or mixture and of the supplier

• GHS product identifier.
• Other means of identification.
• Recommended use of the chemical and

restrictions on use.
• Supplier’s details (including name, address, phone

number, etc.).
• Emergency phone number.

Hazards identification • GHS classification of the substance/mixture and
any national or regional information.

• GHS label elements, including precautionary
statements. (Hazard symbols may be provided as a
graphical reproduction of the symbols in black and
white or the name of the symbol, e.g., flame, skull
and crossbones.)

• Other hazards which do not result in classification
(e.g., dust explosion hazard) or are not covered by
the GHS.

3. Composition/information on
ingredients

Substance
• Chemical identity.
• Common name, synonyms, etc.
• CAS number, EC number, etc.
• Impurities and stabilizing additives which are

themselves classified and which contribute to the
classification of the substance.

Mixture
• The chemical identity and concentration or

concentration ranges of all ingredients which are
hazardous within the meaning of the GHS and are
present above their cutoff levels.

NOTE: For information on ingredients, the competent
authority rules for CBI take priority over the rules for
product identification.

4. First aid measures

• Description of necessary measures, subdivided
according to the different routes of exposure, i.e.,
inhalation, skin and eye contact, and ingestion.

• Most important symptoms/effects, acute and
delayed.

• Indication of immediate medical attention and
special treatment needed, if necessary.

5. Firefighting measures • Suitable (and unsuitable) extinguishing media.
• Specific hazards arising from the chemical (e.g.,

nature of any hazardous combustion products).
• Special protective equipment and precautions for

firefighters.
6. Accidental release measures • Personal precautions, protective equipment and

emergency procedures.
• Environmental precautions.
• Methods and materials for containment and

cleaning up.
7. Handling and storage • Precautions for safe handling.

• Conditions for safe storage, including any
incompatibilities.

8. Exposure controls/personal
protection.

• Control parameters, e.g., occupational exposure
limit values or biological limit values.

• Appropriate engineering controls.
• Individual protection measures, such as personal

protective equipment.
9. Physical and chemical

properties
• Appearance (physical state, color, etc.).
• Odor.
• Odor threshold.
• pH.
• melting point/freezing point.
• initial boiling point and boiling range.
• flash point.
• evaporation rate.
• flammability (solid, gas).
• upper/lower flammability or explosive limits.
• vapor pressure.
• vapor density.
• relative density.
• solubility(ies).
• partition coefficient: n-octanol/water.
• autoignition temperature.
• decomposition temperature.

10. Stability and reactivity • Chemical stability.
• Possibility of hazardous reactions.
• Conditions to avoid (e.g., static discharge, shock

or vibration).
• Incompatible materials.
• Hazardous decomposition products.

11. Toxicological information Concise but complete and comprehensible description
of the various toxicological (health) effects and the
available data used to identify those effects, including:

• information on the likely routes of exposure

(inhalation, ingestion, skin and eye contact);
• Symptoms related to the physical, chemical and

toxicological characteristics;
• Delayed and immediate effects and also chronic

effects from short- and long-term exposure;
• Numerical measures of toxicity (such as acute

toxicity estimates).
12. Ecological information • Ecotoxicity (aquatic and terrestrial, where

available).
• Persistence and degradability.
• Bioaccumulative potential.
• Mobility in soil.
• Other adverse effects.

13. Disposal considerations • Description of waste residues and information on
their safe handling and methods of disposal,
including the disposal of any contaminated
packaging.

14. Transport information • UN Number.
• UN Proper shipping name.
• Transport Hazard class(es).
• Packing group, if applicable.
• Marine pollutant (Yes/No).
• Special precautions which a user needs to be

aware of or needs to comply with in connection
with transport or conveyance either within or
outside their premises.

15. Regulatory information • Safety, health and environmental regulations
specific for the product in question.

16. Other information including
information on preparation
and revision of the SDS

4.9 What is the difference between the GHS SDS and existing MSDSs/SDSs?

SDSs are in use globally. So it is useful to have an understanding of the similarities and
differences in the existing MSDS/SDS content and format and the GHS SDS content and format.
A table comparing MSDS/SDS content/format is provided in Appendix A of this guidance
document.

4.10 When should SDSs and labels be updated?
All hazard communication systems should specify a means of responding in an appropriate and
timely manner to new information and updating labels and SDS information accordingly.
Updating should be carried out promptly on receipt of the information that necessitates the
revision. The Competent Authority may choose to specify a time limit within which the
information should be revised.

Suppliers should respond to “new and significant” information they receive about a chemical
hazard by updating the label and safety data sheet for that chemical. New and significant
information is any information that changes the GHS classification and leads to a change in the
label information or information that may affect the SDS.

4.11 How does the GHS address Confidential Business Information (CBI)?
Confidential business information (CBI) will not be harmonized under the GHS. National
authorities should establish appropriate mechanisms for CBI protection. The GHS established
CBI principles which include:

• CBI provisions should not compromise the health and safety of users;
• CBI claims should be limited to the names of chemicals and their concentrations in

mixtures;
• Mechanisms should be established for disclosure in emergency and non-emergency

situations.

4.12 Does the GHS address training?
The GHS states in Chapter 1.4, Section1.4.9, the importance of training all target audiences to
recognize and interpret label and/or SDS information, and to take appropriate action in response
to chemical hazards. Training requirements should be appropriate for and commensurate with
the nature of the work or exposure. Key target audiences include workers, emergency
responders and also those responsible for developing labels and SDSs. To varying degrees, the
training needs of additional target audiences have to be addressed. These should include training
for persons involved in transport and strategies required for educating consumers in interpreting
label information on products that they use.

5. REFERENCES
References for Section 1.

ANSI Z129.1: American National Standard for Hazardous Industrial Chemicals-Precautionary
Labeling.

Australia: Australia Worksafe, National Occupational Health and Safety Commission, Approved
Criteria for Classifying Hazardous Substances (1994).

CPSC FHSA: U.S. CPSC, 16 CFR 1500, FHSA regulations.

DOT: U.S. DOT, 49 CFR Part 173, Subpart D.

EPA FIFRA: U.S. EPA, 40 CFR Part 156, FIFRA regulations.

EU: Council Directive 92/32/European Economic Community, amending for the 7th time,
Directive 67/548/European Economic Community, approximation of the laws, regulations
and administrative provisions on the classification, packaging and labeling of dangerous
preparations.

GHS: Globally Harmonized System of Classification and Labelling of Chemicals, United
Nations, 1st Revised Edition 2005.

IATA: International Air Transport Association’s Dangerous Goods Regulations.

ICAO: International Civil Aviation Organization’s Technical Instructions for the Safe Transport
Of Dangerous Goods By Air.

IMO: International Maritime Organization’s International Maritime Dangerous Goods (IMDG)
Code.

Japan: Japanese Official Notice of Ministry of Labor No. 60 “Guidelines for Labeling of the

Danger and Hazards of Chemical Substances”.

Korea: Korean Ministry of Labor Notice 1997-27 “Preparation of MSDS and Labelling
Regulation”.

Malaysia: Malaysian Occupational Safety and Health Act (1994), Act 514 and Regulations
(1994).

Mexico: Dario Oficial (March 30, 1996) NORMA Oficial Mexicana NOM-114-STPS-1994.

NFPA: National Fire Protection Association, 704 Standard, System for the Identification of Fire
Hazards of Materials, 2001.

NPCA HMIS: National Paint and Coatings Association, Hazardous Materials Identification
System, 2001.

OSHA HCS: U.S. DOL, OSHA, 29 CFR 1910.1200.

WHMIS: Controlled Products Regulation, Hazardous Products Act, Canada Gazette, Part II, Vol.
122, No. 2, 1987.

References for Section 2.0:

GHS Chapter 1.1 Purpose, Scope and Application of the GHS.

GHS Chapter 1.3 Classification of Hazardous Substances and Mixtures.

References for Section 3.0:

GHS Chapter 1.3. Classification of Hazardous Substances and Mixtures.

GHS Part 2. Physical Hazards.

GHS Part 3. Health Hazards.

GHS Part 4. Environmental Hazards

GHS Annex 8. An Example of Classification in the GHS.

GHS Annex 9. Guidance on Hazards to the Aquatic Environment.

GHS Annex 10. Guidance on Transformation/Dissolution of Metals and Metal

Compounds in Aqueous Media

References for Section 4:

GHS Chapter 1.4. Hazard Communication: Labelling.

GHS Chapter 1.5. Hazard Communication: Safety Data Sheets.

GHS Annex 1 Allocation of Label Elements.

GHS Annex 2 Classification and Labelling Summary Tables.

GHS Annex 3 Precautionary Statements and Precautionary Pictograms.

GHS Annex 4 Guidance on the preparation of Safety Data Sheets

GHS Annex 5 Consumer Product Labelling Based on the Likelihood of Injur.

GHS Annex 6 Comprehensibility Testing Methodology.

GHS Annex 7 Examples of Arrangements of GHS Label Elements.

References for Government and Private Standards:
Canada

Hazardous Products Act: Controlled Products Regulations; Consumer Chemical and Container
Regulations, 2001 Pest Control Products Act; Transportation of Dangerous Goods Act.

Health Canada GHS Website: www.healthcanada.ca/ghs;

European Union (EU)

Directive 67/548/EEC (consolidated, 7th revision).

Directive 2001/59/EC adapting to technical progress for the 28th time Council Directive
67/548/EEC.

Manual of decisions, implementation for the sixth and seventh amendments to Directive
67/548/EEC on dangerous substances.

Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 related to
the classification, packaging and labelling of dangerous preparations.

Commission Directive 91/155/EEC defining and laying down the detailed arrangements for the
system of specific information relating to dangerous preparations (SDS.)

Directive 2001/58/EC (amending Directive 91/155/EEC) defining and laying down the detailed
arrangements for the system of specific information relating to dangerous preparations (SDS).

EU GHS web site: http://europa.eu.int/comm/enterprise/reach/ghs_en.htm

Standards

American National Standard for Hazardous Industrial Chemicals – Precautionary Labeling
(ANSI Z-129.1-2000).

American National Standard for Hazardous Industrial Chemicals – MSDS
Preparation (ANSI Z400.1-2004).

ISO 11014-1:2003 DRAFT Safety Data Sheet for Chemical Products.

UN GHS

Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
(“The Purple Book”), United Nations, 2005 First Revised Edition, available at
www.unece.org/trans/danger/publi/ghs/ghs_rev01/01files_e.html or from
United Nations Publications (publications@un.org)

UN GHS website: www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.htm

UN TRANSPORT

UN Recommendations on the Transport of Dangerous Goods, Model Regulations (14th Revised
Edition 2005).

UN Recommendations on the Transport of Dangerous Goods, Manual of Tests
and Criteria, 4th Revised Edition

USA

OSHA Hazard Communication Standard 29 CFR 1910.1200.

CPSC Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances
Act (15 U.S.C. 1261 et seq.).

(FIFRA) Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136 et seq.).

US EPA Label Review Manual (3rd Edition, August 2003) EPA 735-B-03-001.

Federal Hazardous Materials Transportation Law (49 U.S.C. 5101 et seq.).

USA websites:

www.osha.gov/SLTC/hazardcommunications/global.html

www.epa.gov/oppfead1/international/globalharmon.htm

http://hazmat.dot.gov/regs/intl/globharm.htm

GHS Focal Point websites:
ILO – www.ilo.org/public/english/protection/safework/ghs/index.htm

OECD – www.oecd.org/department/0,2688,en_2649_34371_1_1_1_1_1,00.html

6.0 GLOSSARY

Aerosols means any non-refillable receptacles made of metal, glass or plastics and containing a
gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder,
and fitted with a release device allowing the contents to be ejected as solid or liquid particles in
suspension in a gas, as a foam, paste or powder or in a liquid state or in a gaseous state. Aerosol
includes aerosol dispensers.

Alloy means a metallic material, homogeneous the naked eye, consisting of two or more
elements so combined that they cannot be readily separated by mechanical means. Alloys are
considered to be mixtures for the purpose of classification under the GHS.

Aspiration means the entry of a liquid or solid chemical product into the trachea and lower
respiratory system directly through the oral or nasal cavity, or indirectly from vomiting;

ASTM means the “American Society of Testing and Materials”.

BCF means “bioconcentration factor”.

BOD/COD means “biochemical oxygen demand/chemical oxygen demand”.

CA means “competent authority”.

Carcinogen means a chemical substance or a mixture of chemical substances which induce
cancer or increase its incidence.

CAS means “Chemical Abstract Service”.

CBI means “confidential business information”.

Chemical identity means a name that will uniquely identify a chemical. This can be a name that
is in accordance with the nomenclature systems of the International Union of Pure and Applied
Chemistry (IUPAC) or the Chemical Abstracts Service (CAS), or a technical name.

Competent authority means any national body(ies) or authority(ies) designated or otherwise
recognized as such in connection with the Globally Harmonized System of Classification and
Labelling of Chemicals (GHS).

Compressed gas means a gas which when packaged under pressure is entirely gaseous at -50°C;
including all gases with a critical temperature ≤ -50°C.

Contact sensitizer means a substance that will induce an allergic response following skin
contact. The definition for “contact sensitizer” is equivalent to “skin sensitizer”.

Corrosive to metal means a substance or a mixture which by chemical action will materially
damage, or even destroy, metals.

Criteria means the technical definition for the physical, health and environmental hazards;

Critical temperature means the temperature above which a pure gas cannot be liquefied,
regardless of the degree of compression.

Dermal Corrosion: see skin corrosion; Dermal irritation: see skin irritation.

Dissolved gas means a gas which when packaged under pressure is dissolved in a liquid phase
solvent.

EC50 means the effective concentration of a substance that causes 50% of the maximum
response.

EC Number or (ECN°) is a reference number used by the European Communities to identify
dangerous substances, in particular those registered under EINECS.

ECOSOC means the “Economic and Social Council of the United Nations”.

EINECS means “European Inventory of Existing Commercial Chemical Substances”.

End Point means physical, health and environmental hazards;

ErC50 means EC50 in terms of reduction of growth rate.

EU means “European Union”.

Explosive article means an article containing one or more explosive substances.

Explosive substance means a solid or liquid substance (or mixture of substances) which is in
itself capable by chemical reaction of producing gas at such a temperature and pressure and at
such a speed as to cause damage to the surroundings. Pyrotechnic substances are included even
when they do not emit gases.

Eye irritation means the production of changes in the eye following the application of test
substance to the front surface of the eye, which are fully reversible within 21 days of application.

Flammable gas means a gas having a flammable range with air at 20°C and a standard pressure
of 101.3 kPa.

Flammable liquid means a liquid having a flash point of not more than 93°C.

Flammable solid means a solid which is readily combustible, or may cause or contribute to fire
through friction.

Flash point means the lowest temperature (corrected to a standard pressure of 101.3 kPa) at
which the application of an ignition source causes the vapors of a liquid to ignite under specified
test conditions.

Gas means a substance which (i) at 50 °C has a vapor pressure greater than 300 kPa; or (ii) is
completely gaseous at 20 °C at a standard pressure of 101.3 kPa.

GESAMP means “the Joint Group of Experts on the Scientific Aspects of Marine Environmental
Protection of IMO/FAO/UNESCO/WMO/WHO/IAEA/UN/UNEP.”

GHS means “the Globally Harmonized System of Classification and # Labeling of Chemicals”.

Hazard category means the division of criteria within each hazard class, e.g., oral acute toxicity
includes five hazard categories and flammable liquids includes four hazard categories. These
categories compare hazard severity within a hazard class and should not be taken as a
comparison of hazard categories more generally.

Hazard class means the nature of the physical, health or environmental hazard, e.g., flammable
solid carcinogen, oral acute toxicity.

Hazard statement means a statement assigned to a hazard class and category that describes the
nature of the hazards of a hazardous product, including, where appropriate, the degree of hazard;

IARC means the “International Agency for the Research on Cancer”.

ILO means the “International Labor Organization”.

IMO means the “International Maritime Organization”.

Initial boiling point means the temperature of a liquid at which its vapor pressure is equal to the
standard pressure (101.3 kPa), i.e., the first gas bubble appears.

IOMC means the “Inter-organization Program on the Sound Management of Chemicals”.

IPCS means the “International Program on Chemical Safety”.

ISO means International Standards Organization.

IUPAC means the “International Union of Pure and Applied Chemistry”.

Label means an appropriate group of written, printed or graphic information elements
concerning a hazardous product, selected as relevant to the target sector(s), that is affixed to,
printed on, or attached to the immediate container of a hazardous product, or to the outside
packaging of a hazardous product.

Label element means one type of information that has been harmonized for use in a label, e.g.,
pictogram, signal word.

LC50 (50% lethal concentration) means the concentration of a chemical in air or of a chemical
in water which causes the death of 50% (one-half) of a group of test animals.

LD50 means the amount of a chemical, given all at once, which causes the death of 50% (one
half) of a group of test animals.

L(E)C50 means LC50 or EC50.

Liquefied gas means a gas which when packaged under pressure, is partially liquid at
temperatures above –50°C. A distinction is made between.

(i) High pressure liquefied gas: a gas with a critical temperature between -50°C
and +65°C; and

(ii) Low pressure liquefied gas: a gas with a critical temperature above +65°C.

Liquid means a substance or mixture which at 50°C has a vapor pressure of not more than
300 kPa (3 bar), which is not completely gaseous at 20 °C and at a standard pressure of
101.3 kPa, and which has a melting point or initial melting point of 20°C or less at a standard
pressure of 101.3 kPa. A viscous substance or mixture for which a specific melting point cannot
be determined shall be subjected to the ASTM D 4359-90 test; or to the test for determining
fluidity (penetrometer test) prescribed in section 2.3.4 of Annex A of the European Agreement
concerning the International Carriage of Dangerous Goods by Road (ADR).

MARPOL means the “International Convention for the Prevention of Pollution from Ships”.

Mixture means a mixture or a solution composed of two or more substances in which they do not
react.

MSDS means “Material Safety Data Sheet” and in this document is used interchangeably with
Safety Data Sheet (SDS).

Mutagen means an agent giving rise to an increased occurrence of mutations in populations of
cells and /or organisms.

Mutation means a permanent change in the amount or structure of the genetic material in a cell;

NGO means “non-governmental organization”.

NOEC means the “no observed effect concentration”.

OECD means “The Organization for Economic Cooperation and Development”.

Organic peroxide means a liquid or solid organic substance which contains the bivalent -0-0-
structure and may be considered a derivative of hydrogen peroxide, where one or both of the
hydrogen atoms have been replaced by organic radicals. The term also includes organic peroxide
formulation (mixtures).

Oxidizing gas means any gas which may, generally by providing oxygen, cause or contribute to
the combustion of other material more than air does.

Oxidizing liquid means a liquid which, while in itself not necessarily combustible, may,
generally by yielding oxygen, cause, or contribute to, the combustion of other material.

Oxidizing solid means a solid which, while in itself not necessarily combustible, may, generally
by yielding oxygen, cause, or contribute to, the combustion of other material.

QSAR means “quantitative structure-activity relationships”.

Pictogram means a graphical composition that may include a symbol plus other graphic
elements, such as a border, background pattern or color that is intended to convey specific
information.

Precautionary statement means a phrase (and/or pictogram) that describes recommended
measures that should be taken to minimize or prevent adverse effects resulting from exposure to
a hazardous product, or improper storage or handling of a hazardous product.

Product identifier means the name or number used for a hazardous product on a label or in the
SDS. It provides a unique means by which the product user can identify the substance or
mixture within the particular use setting (e.g. transport, consumer or workplace).

Pyrophoric liquid means a liquid which, even in small quantities, is liable to ignite within five
minutes after coming into contact with air.

Pyrophoric solid means a solid which, even in small quantities, is liable to ignite within five
minutes after coming into contact with air.

Pyrotechnic article means an article containing one or more pyrotechnic substances;

Pyrotechnic substance means a substance or mixture of substances designed to produce an effect
by heat, light, sound, gas or smoke or a combination of these as the result of non-detonative, self-
sustaining exothermic (heat-related) chemical reactions.

Readily combustible solid means powdered, granular, or pasty substance or mixture which is
dangerous if it can be easily ignited by brief contact with an ignition source, such as a burning
match, and if the flame spreads rapidly.

Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria means
the latest revised edition of the United Nations publication bearing this title, and any published
amendment thereto.

Recommendations on the Transport of Dangerous Goods, Model Regulations means the latest
revised edition of the United Nations publication bearing this title, and any published amendment
thereto.

Refrigerated liquefied gas means a gas which when packaged is made partially liquid because of
its low temperature.

Respiratory sensitizer means a substance that induces hypersensitivity of the airways following
inhalation of the substance.

RID means The Regulations concerning the International Carriage of Dangerous Goods by Rail
[Annex 1 to Appendix B (Uniform Rules concerning the Contract for International Carriage of
Goods by Rail) (CIM) of COTIF (Convention concerning international carriage by rail)], as
amended.

SAR means “Structure Activity Relationship”.

SDS means “Safety Data Sheet” and in this document is used interchangeably with Material
Safety Data Sheet (MSDS).

Self-Accelerating Decomposition Temperature (SADT) means the lowest temperature at which
self-accelerating decomposition may occur with substance as packaged.

Self-heating substance means a solid or liquid substance, other than a pyrophoric substance,
which, by reaction with air and without energy supply, is liable to self-heat; this substance differs
from a pyrophoric substance in that it will ignite only when in large amounts (kilograms) and
after long periods of time (hours or days).

Self-reactive substance means a thermally unstable liquid or solid substance liable to undergo a
strongly exothermic decomposition even without participation of oxygen (air). This definition
excludes substances or mixtures classified under the GHS as explosive, organic peroxides or as
oxidizing.

Serious eye damage means the production of tissue damage in the eye, or serious physical decay
of vision, following application of a test substance to the front surface of the eye, which is not
fully reversible within 21 days of application.

Signal word means a word used to indicate the relative level of severity of hazard and alert the
reader to a potential hazard on the label. The GHS uses ‘Danger’ and ‘Warning’ as signal
words.

Skin corrosion means the production of irreversible damage to the skin following the application
of a test substance for up to 4 hours.

Skin irritation means the production of reversible damage to the skin following the application
of a test substance for up to 4 hours.

Skin sensitizer means a substance that will induce an allergic response following skin contact.
The definition for “skin sensitizer” is equivalent to “contact sensitizer”.

Solid means a substance or mixture which does not meet the definitions of a liquid or gas.

SPR means “Structure Property Relationship”.

Substance means chemical elements and their compounds in the natural state or obtained by any
production process, including any additive necessary to preserve the stability of the product and
any impurities deriving from the process used, but excluding any solvent which may be
separated without affecting the stability of the substance or changing its composition.

Substance which, in contact with water, emits flammable gases means a solid or liquid
substance or mixture which, by interaction with water, is liable to become spontaneously
flammable or to give off flammable gases in dangerous quantities.

Supplemental label element means any additional non-harmonized type of information supplied
on the container of a hazardous product that is not required or specified under the GHS. In some
cases this information may be required by other competent authorities or it may be additional
information provided at the discretion of the manufacturer/distributor.

Symbol means a graphical element intended to succinctly convey information.

Technical name means a name that is generally used in commerce, regulations and codes to
identify a substance or mixture, other than the IUPAC or CAS name, and that is recognized by
the scientific community. Examples of technical names include those used for complex mixtures
(e.g., petroleum fractions or natural products), pesticides (e.g., ISO or ANSI systems), dyestuffs
(Color Index system) and minerals.

UNCED means the “United Nations Conference on Environment and Development”.

UNCETDG/GHS means the “United Nations Committee of Experts on the Transport of
Dangerous Goods and on the Globally Harmonized System of Classification and Labelling of
Chemicals”.

UNITAR means the “United Nations Institute for Training and Research”;

UNSCEGHS means the “United Nations Sub-Committee of Experts on the Globally
Harmonized System of Classification and Labelling of Chemicals”.

UNSCETDG means the “United Nations Sub-Committee of Experts on the Transport of
Dangerous Goods”.

7.0 APPENDICES

A. Comparison of MSDS/SDS Elements

B. GHS MSDS Examples

– A-1

Appendix A

Comparison of MSDS/SDS Elements

– A-2

The following tables provide a comparison
of MSDS elements for the following:

♦ Globally Harmonized System1

♦ ISO Safety Data Sheet for Chemical Products
11014-1: 2003 DRAFT 2

♦ ANSI MSDS Preparation Z400.1- 2004 3

♦ OSHA Hazard Communication Standard
29#CFR#1910.12004

– A-3

MSDS Comparison
MSDS Sections GHS SDS1 ISO MSDS2 ANSI MSDS3 OSHA MSDS4
1. Product and
company
identification

– GHS product identifier.
– Other means of

identification.
– Recommended use of the

chemical and restrictions
on use.

– Supplier’s details
(including name, address,
phone number etc).

– Emergency phone number.

– GHS product identifier.
– Other means of identification.
– Recommended use of the

chemical and restrictions on
use.

– Supplier’s details (including
name, address, phone

number

etc).

– Emergency phone number.
.

– Product identity same as on
label

– Product name, product code
– name, address and telephone

number of supplier
– emergency telephone

number

– Product identity same
as on label.

– Name address and
telephone number of
the manufacturer,
distributor, employer
or other responsible
party.

2. Hazards
identification

– GHS classification of the
substance/mixture and any
regional information.

– GHS label elements,
including precautionary
statements. (Hazard
symbols may be provided
as a graphical reproduction
of the symbols in black
and white or the name of
the symbol, e.g., flame,
skull and crossbones.)

– Other hazards which do
not result in classification
(e.g., dust explosion
hazard) or are not covered
by the GHS.

– GHS classification of the
substance/mixture and any
regional information.

– GHS label elements, including
precautionary statements.
(Hazard symbols may be
provided as a graphical
reproduction of the symbols in
black and white or the name of
the symbol, e.g., flame, skull
and crossbones.)

– Other hazards which do not
result in classification (e.g.,
dust explosion hazard) or are
not covered by the GHS.

– Emergency Overview
(description of product and
most significant immediate
physical, health and
environmental concerns)

– OSHA Regulatory Status
– Potential health effects

(information on adverse
human health effects and
symptoms, relevant route(s)
and length of exposure, type
and severity of effects, target
organs, medical symptoms
that are aggravated by
exposure)

– if listed as a carcinogen by
OSHA, IARC, NTP

– environmental effects

– health hazards
including acute and
chronic effects, listing
target organs or
systems

– signs & symptoms of
exposure

– conditions generally
recognized as
aggravated by
exposure

– primary routes of
exposure

– if listed as a
carcinogen by OSHA,
IARC, NTP

– physical hazards,
including the potential
for fire, explosion, and
reactivity

– A-4

MSDS Comparison
MSDS Sections GHS SDS1 ISO MSDS2 ANSI MSDS3 OSHA MSDS4
3. Composition/in-
formation on
ingredients

Substance
– Chemical identity
– Common name,

synonyms, etc.
– CAS number, EC number,

etc.
– Impurities and stabilizing

additives which are
themselves classified and
which contribute to the
classification of the
substance.

Mixture
– The chemical identity and

concentration or
concentration ranges of all
ingredients which are
hazardous within the
meaning of the GHS and
are present above their
cut-off levels.

– Cut-off level for
reproductive toxicity,
carcinogenicity and
category 1 mutagenicity is
≥ 0.1%

– Cut-off level for all other
hazard classes is ≥ 1%

Note: For information on
ingredients, the competent
authority rules for CBI take
priority over the rules for
product identification

Substance
– Chemical identity
– Common name, synonyms etc.
– CAS number, EC number, etc.
– Impurities and stabilizing

additives which are themselves
classified and which contribute
to the classification of the
substance.

Mixture
– The chemical identity and

concentration or concentration
ranges of all ingredients which
are hazardous within the
meaning of the GHS and are
present above their cut-off
levels.

– Cut-off level for reproductive
toxicity, carcinogenicity and
category 1 mutagenicity is ≥
0.1%

– Cut-off level for all other
hazard classes is ≥ 1%

– common chemical name(s)
– generic name(s)
– synonyms
– CAS number(s)
– components or impurities

contributing to the hazard
(name, concentration)

– Chemical and
common name of
ingredients
contributing to known
hazards

– For untested mixtures,
the chemical &
common name of
ingredients at 1% or
more that present a
health hazard and
those that present a
physical hazard in the
mixture

– Ingredients at 0.1% or
greater, if carcinogens

– A-5

MSDS Comparison
MSDS Sections GHS SDS1 ISO MSDS2 ANSI MSDS3 OSHA MSDS4
4. First-aid
measures

– Description of necessary
measures, subdivided
according to the different
routes of exposure, i.e.,
inhalation, skin and eye
contact and ingestion.

– Most important
symptoms/effects, acute
and delayed.

– Indication of immediate
medical attention and
special treatment needed,
if necessary.

– Description of necessary
measures, subdivided according
to the different routes of
exposure, i.e., inhalation, skin
and eye contact and ingestion.

– Most important
symptoms/effects, acute and
delayed.

– Indication of immediate
medical attention and special
treatment needed, if necessary.

– first aid procedures by route
of exposure, i.e., inhalation,
skin contact, eye contact,
ingestion

– important symptoms and
effects useful for diagnostic
treatment

– antidotes
– notes to a physician

– emergency & first aid
procedures

5. Firefighting
measures

– Suitable (and unsuitable)
extinguishing media.

– Specific hazards arising
from the chemical (e.g.,
nature of any hazardous
combustion products).

– Special protective
equipment and precautions
for fire-fighters.

– Suitable (and unsuitable)
extinguishing media.

– Specific hazards arising from
the chemical (e.g., nature of any
hazardous combustion
products).

– Special protective equipment
and precautions for firefighters.

– Qualitative flammable and
reactivity properties

– suitable extinguishing media
– unsuitable extinguishing

media
– Guidance to firefighters
– Specific hazards arising

from the chemical
– Protective equipment and

precautions for firefighters

– generally applicable
control measures

– flammable property
information such as
flashpoint

– physical hazards
including the potential
for fire, explosion, and
reactivity

6. Accidental
release measures

– Personal precautions,
protective equipment and
emergency procedures.

– Environmental
precautions.

– Methods and materials for
containment and cleaning
up.

– Personal precautions, protective
equipment and emergency
procedures.

– Environmental precautions.
– Methods and materials for

containment and cleaning up.

– Clean-up technique
– Personal Precautions
– Environmental Precautions
– containment technique
– regulatory information

– procedures for clean
up of spills and leaks

– A-6

MSDS Comparison
MSDS Sections GHS SDS1 ISO MSDS2 ANSI MSDS3 OSHA MSDS4
7. Handling and
storage

– Precautions for safe
handling.

– Conditions for safe
storage, including any
incompatibilities.

– Precautions for safe handling.
– Conditions for safe storage,

including any incompatibilities.

handling
– measures to prevent

exposure and release,
prevent fire or explosion and
ensure precautions for safe
handling

storage
– storage conditions and

technical measures for safe
storage

– incompatibilities
– suitable/non suitable

packaging material

– Precautions for safe
handling & use,
including appropriate
hygenic practices.

8. Exposure
controls/
personal
protection

– Control parameters (e.g.,
occupational exposure
limit values or biological
limit values).

– Appropriate engineering
controls.

– Individual protection
measures, such as personal
protective equipment.

– Control parameters (e.g.,
occupational exposure limit
values or biological limit
values).

– Appropriate engineering
controls.

– Individual protection measures,
such as personal protective
equipment.

– exposure guidelines (limit
values)

– engineering controls to
minimize hazards

– personal protective
equipment (respiratory,
hand, eye, skin and body
protection)

– General Hygiene
Considerations

– General applicable
control measures

– appropriate
engineering controls
and work practices

– protective measures
during maintenance &
repair

– personal protective
equipment

– permissible exposure
levels, threshold limit
values, listed by
OSHA, ACGIH, or
established company
limits.

– A-7

MSDS Comparison
MSDS Sections GHS SDS1 ISO MSDS2 ANSI MSDS3 OSHA MSDS4
9. Physical and
chemical
properties

– Appearance (physical
state, colour, etc.)

– Odour
– Odour threshold
– pH
– melting point/freezing

point
– initial boiling point and

boiling range
– flash point:
– evaporation rate
– flammability (solid, gas)
– upper/lower flammability

explosive limits
– vapour pressure
– vapour density
– relative density:
– solubility(ies)
– partition coefficient: n-

octanol/water
– auto-ignition temperature
– decomposition

temperature

– Appearance (physical state,
colour, etc.)

– Odour
– Odour threshold
– pH
– melting point/freezing point
– initial boiling point and boiling

range
– flash point:
– evaporation rate
– flammability (solid, gas)
– upper/lower flammability or

explosive limits
– vapour pressure
– vapour density
– relative density:
– solubility(ies)
– partition coefficient: n-

octanol/water:
– auto-ignition temperature
– decomposition temperature

– appearance (color, physical
form, shape)

– odor/odor threshold
– physical state
– pH
– melting/freezing

point(specify which)
– initial boiling point and

boiling range
– flash point
– evaporation rate
– flammability (solid, gas)
– upper/lower flammability or

explosive limits
– vapor pressure
– vapor density
– specific gravity or relative

density
– solubility(ies) (specify

solvent, e.g., water)
– partition coefficient: n-

octanol/water
– auto-ignition temperature
– decomposition temperature.
– other relevant data

– characteristics of
hazardous chemicals
such as vapor pressure
& density.

– physical hazards
including the potential
for fire, explosion, and
reactivity.

10. Stability and
reactivity

– Chemical stability.
– Possibility of hazardous

reactions.
– Conditions to avoid (e.g.,

static discharge, shock or
vibration).

– Incompatible materials,
– Hazardous decomposition

products.
– Chemical stability.
– Possibility of hazardous

reactions.
– Conditions to avoid (e.g., static

discharge, shock or vibration).
– Incompatible materials.
– Hazardous decomposition

products.

– Physical hazards
– chemical stability
– conditions to avoid
– Incompatible Materials
– hazardous decomposition

products
– Possibility of Hazardous

Reactions

– organic peroxides,
pyrophoric, unstable #
(reactive), or water-
reactive hazards

– physical hazards,
including reactivity
and hazardous
polymerization

– A-8

MSDS Comparison
MSDS Sections GHS SDS1 ISO MSDS2 ANSI MSDS3 OSHA MSDS4
11. Toxicological
information

– Concise but complete and
comprehensible
description of the various
toxicological (health)
effects and the available
data used to identify those
effects, including:

– Information on the likely
routes of exposure
(inhalation, ingestion, skin
and eye contact);

– Symptoms related to the
physical, chemical and
toxicological
characteristics;

– Delayed and immediate
effects and also chronic
effects from short- and
long-term exposure;.

– Numerical measures of
toxicity (such as acute
toxicity estimates).

– Concise but complete and
comprehensible description of
the various toxicological
(health) effects and the
available data used to identify
those effects, including:

– Information on the likely routes
of exposure (inhalation,
ingestion, skin and eye contact);

– Symptoms related to the
physical, chemical and
toxicological characteristics;

– Delayed and immediate effects
and also chronic effects from
short- and long-term exposure;

– Numerical measures of toxicity
(such as acute toxicity
estimates).

– Toxicological information:
human, animal, and in
vitro data, SAR

– acute dose effects: single/
short-term exposures. (e.g.,
LD50, LC50).

– Repeated dose effects: (e.g.,
NOAEL)

– Irritation/Corrosivity
– Sensitization (skin and

respiratory)
– Carcinogenicity
– Neurological effects
– Genetic effects (e.g.,

mutagenicity)
– Reproductive effects
– Developmental effects
– Target organ effects

– See also Section 2
[health hazards
Including acute and
chronic effects, listing

target organs or
systems
– signs & symptoms of

exposure
– primary routes of

exposure
– if listed as a

carcinogen by OSHA,
IARC, NTP]

12. Ecological
information

– Ecotoxicity (aquatic and
terrestrial, where
available).

– Persistence and
degradability

– Bioaccumulative potential
– Mobility in soil
– Other adverse effects

– Ecotoxicity (aquatic and
terrestrial, where available).

– Persistence and degradability
– Bioaccumulative potential
– Mobility in soil
– Other adverse effects

– ecotoxicity acute and
longterm (fish, invertebrates)

– persistence / degradability
– bioaccumulation /

bioconcentration
– mobilty: air, soil, water
– Other adverse effects

– No present
requirements.

– A-9

MSDS Comparison
MSDS Sections GHS SDS1 ISO MSDS2 ANSI MSDS3 OSHA MSDS4

13. Disposal
considerations

– Description of waste
residues and information
on their safe handling and
methods of disposal,
including any
contaminated packaging.

– Description of waste residues
and information on their safe
handling and methods of
disposal, including any
contaminated packaging.

– safe and environmentally
preferred waste management
of the material and/or its
container

– classification under
applicable law

– No present
requirements,

– See section 7,

14. Transport
information

– UN number.
– UN Proper shipping name.
– Transport Hazard

class(es).
– Packing group, if

applicable.
– Marine pollutant (Y/N).
– Special precautions which

a user needs to be aware of
or needs to comply with in
connection with transport
or conveyance either
within or outside their
premises.

– UN number.
– UN Proper shipping name.
– Transport Hazard class(es).
– Packing group, if applicable.
– Marine pollutant (Y/N).
– Special precautions which a

user needs to be aware of or
needs to comply with in
connection with transport or
conveyance either within or
outside their premises.

– proper shipping name
– hazard class(es)
– identification number
– packing group
– hazardous substances
– marine pollutants (Y/N)
– IMDG classification
– TDG classification
– ICAO/IATA classification
– RID/ADR classification

– No present
requirements,

15. Regulatory
information

– Safety, health and
environmental regulations
specific for the product in
question.

– U.S .federal regulations
– international regulations
– U.S. state regulations

– No present
requirements.

16. Other
information

– Other information
including information on
preparation and revision of
the SDS.

– Other information including
information on preparation and
revision of the SDS.

– label text
– hazard rating and rating

system
– information on preparation

and revision of safety data
sheet

– Key/legend

– Date of preparation of
MSDS or date of last
change

1. Globally Harmonized System of Classification and Labelling of Chemicals (GHS), United Nations, 2005.
2. ISO 11014-1:2003 DRAFT Safety Data Sheet for Chemical Products.
3. American National Standard for Hazardous Industrial Chemicals-MSDS Preparation (ANSI Z-400.1-2004).
4. U.S. DOL, OSHA, 29 CFR 1910.1200, HAZCOM.

B-1

Appendix B

MSDS Examples
(Fictional Products)

B-1: Bondit

B-2:

Chemical Stuff

B-2

Appendix B-1

Bondit

(GHS MSDS Example)

B-3

Appendix B-1
MSDS for BONDIT

1. Identification

Name of the product: Bondit

Recommended use: General adhesive.

Producer: GHS Ltd., UK –
London, SE, Southwarkbridge 1

Telephone no. +44 171717 555.555 5,
Emergency no. +44 171717 333 333 3

2. Hazard(s) identification

Classification: Flammable liquid, Category 2
Eye irritation, Category 2A
Hazardous to the aquatic environment, Acute Category 3

Labelling:

Symbol: Flame, Exclamation mark
Signal word: Danger

Hazard statement: Highly flammable liquid and vapour.
Causes severe eye irritation.
Harmful to aquatic life.

Precautionary statements: Keep container tightly closed.

Keep away from heat/sparks/open flame. – No smoking.
Wear protective gloves and eye/face protection.
Ground/Bond container and receiving equipment.
Use explosion-proof electrical/ventilating/lighting/
equipment.
Take precautionary measures against static discharge.
Use only non-sparking tools.

Store in cool/well-ventilated place.
Avoid release to the environment.

3. Composition / Information on ingredients

Chemical identity: Component A 70-80%
Common name: Solvent A
Numbers of identity: CAS-Nr.:111111-11-1
Impurities: None

Chemical identity: Component C 20-25%
Common name: Not applicable
Numbers of identity: CAS-Nr.: 44444-44-4
Impurities: none

B-4

4. First-aid measures

Inhalation:
Remove person to fresh air. If respiratory irritation, dizziness, nausea, or unconsciousness occurs, seek
immediate medical assistance. If breathing has stopped, give artificial respiration.

Skin contact:
Wash the contaminated area with soap and water. Remove contaminated clothing and wash before reuse. If
irritation develops, get medical attention.

Eye contact:
Hold eyelids apart and flush eyes with plenty of water for at least 15 minutes. Get medical attention.

Ingestion:
If swallowed, do NOT induce vomiting. Seek immediate medical attention.

5. Firefighting measures

Suitable extinguishing media: Foam, extinguishing powder, carbon dioxide, water fog. In case of fire,
cool endangered containers with water fog.

Unsuitable extinguishing media: High pressure water jet.

Specific hazards in case of fire: None are known.

Special protective equipment and precaution for fire fighters: For fires in enclosed areas, wear
self-contained breathing apparatus. Do not inhale combustion gases.

6. Accidental release measures

Personal precautions:
Depending on extent of release, consider the need for fire fighters/emergency responders with adequate
personal protective equipment for cleaning up.

Do not eat, drink or smoke while cleaning up. Use a self-contained respirator, a mask with filter (type A
class 3) or a filtering mask (e.g., EN 405). Wear protective clothing, safety glasses and impervious gloves
(e.g., neoprene gloves). Ensure adequate ventilation. Avoid all sources of ignition, hot surfaces and open
flames (see also Section 7).

Environmental precautions:
Prevent spills from entering storm sewers or drains and contact with soil.

Methods and materials for containment and cleaning up:
Eliminate all ignition sources. Runoff may create fire or explosion hazard in sewer system. Absorb on fire
retardant, liquid-absorbing material (treated sawdust, diatomaceous earth, sand). Shovel up and dispose of at
an appropriate waste disposal facility in accordance with current applicable laws and regulations, and
product characteristics at time of disposal (see also Section 13).

7. Handling and storage

Precautions for safe handling:
Avoid contact with eyes. Avoid prolonged repeated skin contact and breathing mists/vapours.

B-5

Use in well-ventilated area away from all ignition sources. Switch off all electrical devices such as parabolic
heaters, hotplates, storage heaters etc. in good time for them to have cooled down before commencing work.
Do not smoke; do not weld. Do not empty waste into sanitary drains. Take measures to prevent the build up
of electrostatic charge.

Conditions for safe storage, including incompatibilities:
Storage containers must be grounded and bonded. Store away from all ignition sources in a cool area
equipped with an automatic sprinkling system. Ensure adequate ventilation. Store at temperatures between
+5 and +50°C. Store only in the original container.

8. Exposure controls / personal protection

Information on the system design:
Draw off vapours directly at the point of generation and exhaust from the work area. In the case of regular
work, provide bench-mounted extraction equipment.

Exposure Limits:

TWA STEL
Reference ppm mg/m3 ppm mg/m3

Component Name (CAS-No.)

UK OEL 500 1200 — —

Component C (4444-44-4) German MAK 200 950 — —

Ventilation:
Use in well-ventilated area with local exhaust.

Respiratory protection:
Approved respiratory equipment must be used when airborne concentrations are unknown or exceed the
exposure limits. When processing large amounts, use a light duty construction compressed air line breathing
apparatus (e.g., in accordance with EN1835), a mask with filter (type A class 3, colour brown) or a filtering
half mask (e.g., in accordance with EN 405) when there is inadequate ventilation.

Eye protection:
Safety glasses with side shields or chemical goggles must be worn.

Skin protection:
If prolonged or repeated skin contact is likely, neoprene gloves should be worn. Good personal hygiene
practices should always be followed.

9. Physical and chemical properties

Physical state: Liquid
Colour: Colourless, transparent
Odour: Solvent, ester-like
Odour threshold: Not available
pH-value: Not applicable
Melting point: Not available
Freezing Point: Not available
Initial boiling point: 56°C
Flash point: – 22°C DIN 51755
Evaporation rate: Not available
Flammability (solid, gas): Not applicable

B-6

Explosion limits: lower limit = 1.4 Vol%; upper limit 13.0 Vol% (literature)
Vapour pressure: 240 mbar (highest partial vapour pressure) at 20°C
Vapour density: Not available
Relative density: 0.89 g/cm3 at 20°C
Solubility: Partially soluble in water at 20°C
Partition coefficient: Log Kow = 3.3
Auto-ignition temperature: Not available
Decomposition temperature: Not available

10. Stability and reactivity

Chemical stability: No decomposition, if used according to specifications.
Possibility of hazardous reactions: None are known.
Conditions to avoid: Heat, sparks, flame and build up of static electricity.
Materials to avoid: Halogens, strong acids, alkalies and ozidizers.
Hazardous decomposition products: None are known.

11. Toxicological information

Acute Toxicity:
Test Results Basis

Oral Toxicity (Rats) Not Classified Based on Ingredients

Dermal Toxicity (Rats)

Not Classified Product Test Data

Inhalation Toxicity, Vapor
(Rats)

Not Classified Based on Testing of Similar Materials

Eye Irritation (Rabbits) Eye Irritant Category 2A Based on Testing of Similar Materials

Dermal Irritation (Rabbits)

Not Classified Product Test Data

Summary Comments: May cause severe eye irritation like ocular lesions, which are reversible.

Subchronic/Chronic Toxicity:
Test Results Comments

Dermal Sensitization (Guinea Pig)

Not Classified: Negative response in Bueller,
guinea pig test. 0% animals considered
positive.

Product Test Data

Summary Comments: Component A may have a drying effect on the skin; frequent or prolonged contact
may cause flaking or cracking of the skin.

12. Ecological information

B-7

Persistence and degradability: The total of the organic components contained in the product is not
classified as “readily biodegradable” (OECD-301 A-F). However, this product is expected to be inherently
biodegradable.

Bio-accumulative potential;
There is no evidence to suggest bioaccumulation will occur.

Mobility: Accidental spillage may lead to penetration in the soil and groundwater. However, there is no
evidence that this would cause adverse ecological effects.

Aquatic Toxicity:
Test Results Comments

Acute Toxicity

Acute Category 3: 96 hr. LC50 = 65 mg/L Product Test Data

13. Disposal considerations

Waste Disposal:
Product is suitable for burning in an enclosed, controlled burner for fuel value or disposal by supervised
incineration. Such burning may be limited by local regulation. The product is suitable for processing at an
appropriate government waste disposal facility. Use of these methods is subject to user compliance with
applicable laws and regulations and consideration of product characteristics at time of disposal.

Recommended European waste code (EWC): 080406

14. Transport information

UN-number: 1993
UN proper shipping name: Flammable Liquid, N.O.S. (Contains Component C)
Transport hazard class: 3
Packing group: II
Marine Pollutant: No

15. Regulatory information

Inventory Status:
All components are on TSCA, EINECS/ELINCS, AICS, and DSL.

German:

Regulations governing combustible liquids (German-VbF) class: AI

German water endangering class (WGK) = 1, slightly water-endangering product (manufacturer
classification.)

Australian Regulations:

AS 1940 Class: PGII
Poisons Schedule: S5

B-8

U.S. Regulations:

U.S. Superfund Amendments and Reauthorization Act (SARA) Title III:

SARA (311/312) HAZARD CATEGORIES:
FIRE, ACUTE

SARA 313: This product contains the following SARA 313 Toxic Release Chemicals.

Chemical Name
CAS Number Concentration

Component A 111111-11-1 70-80%
Component C 4444-44-4 20-25%

The following product components are cited on the lists below:

Chemical Name CAS Number List Citations
Component A 111111-11-1 NJ RTK, TSCA 12(b)
Component C 4444-44-4 Prop. 65, NJ RTK

16. Other information

Abbreviations and acronyms:

UK OES = United Kingdom Occupational Exposure Standards
German MAK = Germany Maximum Allowable Concentration

MSDS Prepration date: July 1, 2005

The information contained herein is accurate to the best of our knowledge. My Company makes no
warranty of any kind, express or implied, concerning the safe use of this material in your process or
in combination with other substances.

B-9

Appendix B-2

Chemical Stuff

(GHS MSDS Example)

B-10

Appendix B-2
MSDS for Chemical Stuff

GHS SAFETY DATA SHEET

1. Identification
Product Name: Chemical Stuff
Synonyms: Methyltoxy Solution
CAS Number: 000-00-0
Product Use: Organic Synthesis
Manufacturer/Supplier: My Company
Address: My Street, Mytown, TX 00000

General Information: 713-000-0000
Transportation Emergency Number: CHEMTREC: 800-424-9300

2. Hazards Identification

GHS Classification:

Health Environmental Physical
Acute Toxicity – Category 2 (inhalation), Category 3
(oral/dermal)
Eye Corrosion – Category 1
Skin Corrosion – Category 1
Skin Sensitization – Category 1
Mutagenicity – Category 2
Carcinogenicity – Category 1B
Reproductive/Developmental – Category 2
Target Organ Toxicity (Repeated) – Category 2

Aquatic Toxicity – Acute 2 Flammable Liquid – Category 2

GHS Label:
Symbols: flame, skull and crossbones, corrosion, health hazard

Hazard Statements
DANGER!
Highly Flammable Liquid and Vapor.
Fatal if inhaled.
Causes severe skin burns and eye damage.
May cause allergic skin reaction.
Toxic if swallowed and in contact with skin
May cause cancer.
Suspected of damaging the unborn child.
Suspected of causing genetic defects.
May cause damage to cardiovascular, respiratory,
nervous, and gastrointestinal systems and liver and
blood through prolonged or repeated exposure.
Toxic to aquatic life.

Precautionary Statements
Do not eat, drink or use tobacco when using this
product.
Do not breathe mist/vapors.
Keep container tightly closed.
Keep away from heat/sparks/open flame. – No
smoking.
Wear respiratory protection, protective gloves and
eye/face protection.
Use only in a well-ventilated area.
Take precautionary measures against static
discharge.
Use only non-sparking tools.
Store container tightly closed in cool/well-ventilated
place.
Wash thoroughly after handling.

3. Composition / Information on Ingredients

Component CAS Number Weight %
Methyltoxy 000-00-0 80
(See Section 8 for Exposure Limits)

B-11

4. First Aid Measures

Eye: Eye irritation. Flush immediately with large amounts of water for at least 15 minutes.
Eyelids should be held away from the eyeball to ensure thorough rinsing. Get immediate
medical attention.

Skin: Itching or burning of the skin. Immediately flush the skin with plenty of water while
removing contaminated clothing and shoes. Get immediate medical attention. Wash
contaminated clothing before reuse.

Inhalation: Nasal irritation, headache, dizziness, nausea, vomiting, heart palpitations,
breathing difficulty, cyanosis, tremors, weakness, red flushing of face, irritability. Remove
exposed person from source of exposure to fresh air. If not breathing, clear airway and
start cardiopulmonary resuscitation (CPR). Avoid mouth-to-mouth resuscitation.

Ingestion: Get immediate medical attention. Do not induce vomiting unless directed by
medical personnel.

5. Fire Fighting Measures

Suitable Extinguishing Media: Use dry chemical, foam, or carbon dioxide to extinguish
fire. Water may be ineffective but should be used to cool fire-exposed containers,
structures and to protect personnel. Use water to dilute spills and to flush them away from
sources of ignition.

Fire Fighting Procedures: Do not flush down sewers or other drainage systems.
Exposed firefighters must wear NIOSH-approved positive pressure self-contained
breathing apparatus with full-face mask and full protective clothing.

Unusual Fire and Explosion Hazards: Dangerous when exposed to heat or flame. Will
form flammable or explosive mixtures with air at room temperature. Vapor or gas may
spread to distant ignition sources and flash back. Vapors or gas may accumulate in low
areas. Runoff to sewer may cause fire or explosion hazard. Containers may explode in
heat of fire. Vapors may concentrate in confined areas. Liquid will float and may reignite
on the surface of water.

Combustion Products: Irritating or toxic substances may be emitted upon thermal
decomposition. Thermal decomposition products may include oxides of carbon and
nitrogen.

6: Accidental Release Measures

Keep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep
out of low areas. (Also see Section 8).

Vapor protective clothing should be worn for spills and leaks. Shut off ignition sources; no
flares, smoking or flames in hazard area. Small spills: Take up with sand or other
noncombustible absorbent material and place into containers for later disposal. Large
spills: Dike far ahead of liquid spill for later disposal.

B-12

Do not flush to sewer or waterways. Prevent release to the environment if possible. Refer
to Section 15 for spill/release reporting information.

7. Handling and Storage

Handling
Do not get in eyes, on skin or on clothing. Do not breathe vapors or mists. Keep
container closed. Use only with adequate ventilation. Use good personal hygiene
practices. Wash hands before eating, drinking, smoking. Remove contaminated clothing
and clean before re-use. Destroy contaminated belts and shoes and other items that
cannot be decontaminated.

Keep away from heat and flame. Keep operating temperatures below ignition
temperatures at all times. Use non-sparking tools.

Storage
Store in tightly closed containers in cool, dry, well-ventilated area away from heat, sources
of ignition and incompatibles. Ground lines and equipment used during transfer to reduce
the possibility of static spark-initiated fire or explosion. Store at ambient or lower
temperature. Store out of direct sunlight. Keep containers tightly closed and upright when
not in use. Protect against physical damage.

Empty containers may contain toxic, flammable and explosive residue or vapors. Do not
cut, grind, drill, or weld on or near containers unless precautions are taken against these
hazards.

8. Exposure Controls / Personal Protection

Exposure Limits

Component OSHA
TWA STEL _____________________________
Methyltoxy 3 ppm C 15 ppm
(skin) (15 min.)

Engineering Controls: Local exhaust ventilation may be necessary to control air
contaminants to their exposure limits. The use of local ventilation is recommended to
control emissions near the source. Provide mechanical ventilation for confined spaces.
Use explosion-proof ventilation equipment.

Personal Protective Equipment (PPE)

Eye Protection: Wear chemical safety goggles and face shield. Have eye-wash stations
available where eye contact can occur.

Skin Protection: Avoid skin contact. Wear gloves impervious to conditions of use.
Additional protection may be necessary to prevent skin contact including use of apron,
face shield, boots or full body protection. A safety shower should be located in the work
area. Recommended protective materials include:
Butyl rubber and for limited contact Teflon.

B-13

Respiratory Protection: If exposure limits are exceeded, NIOSH approved respiratory
protection should be worn. A NIOSH approved respirator for organic vapors is generally
acceptable for concentrations up to 10 times the PEL. For higher concentrations,
unknown concentrations and for oxygen deficient atmospheres, use a NIOSH approved
air-supplied respirator. Engineering controls are the preferred means for controlling
chemical exposures. Respiratory protection may be needed for non-routine or emergency
situations. Respiratory protection must be provided in accordance with OSHA 29 CFR
1910.134.

9. Physical and Chemical Properties

Flashpoint: 2oC (35oF) Lower Flammability Limit: >3.00%
Autoignition Temperature: 480oC (896oF) Upper Flammability Limit: <15.00% Boiling Point: 77oC (170.6oF) @ 760 mm Hg Specific Gravity: 0.82g/ml @ 20oC Melting Point: -82oC % Volatile: 100 Vapor Pressure: 100.0 mm Hg @ 23oC Evaporation Rate (Water=1): 5(Butyl Acetate =1) Vapor Density(Air=1): 1.7; air = 1 Viscosity: 0.3 cP @ 25oC % Solubility in Water: 10 @ 20ºC Octanol/Water Partition Coefficient: log Kow: 0.5 Pour Point: NA pH: 7, 8% aqueous solution Molecular Formula: Mixture Molecular Weight: Mixture Odor/Appearance: Clear, colorless liquid with mild, pungent odor.

10. Stability and Reactivity

Stability/Incompatibility: Incompatible with ammonia, amines, bromine, strong bases
and strong acids.

Hazardous Reactions/Decomposition Products: Thermal decomposition products may
include oxides of carbon and nitrogen.

11. Toxicological Information

Signs and Symptoms of Overexposure: Eye and nasal irritation, headache, dizziness,
nausea, vomiting, heart palpitations, difficulty breathing, cyanosis, tremors, weakness,
itching or burning of the skin.

Acute Effects:

Eye Contact: may cause severe conjunctival irritation and corneal damage.

Skin Contact: may cause reddening, blistering or burns with permanent damage. Harmful
if absorbed through the skin. May cause allergic skin reaction.

Inhalation: may cause severe irritation with possible lung damage (pulmonary edema).

Ingestion: may cause severe gastrointestinal burns.

B-14

Target Organ Effects: May cause gastrointestinal (oral), respiratory tract, nervous system
and blood effects based on experimental animal data. May cause cardiovascular system
and liver effects.

Chronic Effects: based on experimental animal data, may cause changes to genetic
material; adverse effects on the developing fetus or on reproduction at doses that were
toxic to the mother. Methyltoxy is classified by IARC as group 2B and by NTP as
reasonably anticipated to be a human carcinogen. OSHA regulates Methyltoxy as a
potential carcinogen.

Medical Conditions Aggravated by Exposure: preexisting diseases of the respiratory
tract, nervous system, cardiovascular system, liver or gastrointestinal tract.

Acute Toxicity Values
Oral LD50 (Rat) = 100 mg/kg
Dermal LD50 (Rabbit) = 225-300 mg/kg
Inhalation LC50 (Rat) = 200 ppm/4 hr., 1100 ppm vapor/1 hr

12. Ecological Information

LC50 (Fathead Minnows) = 9 mg/L/96 hr.
EC50 (Daphnia) = 8.6 mg/L/48 hr.

Bioaccumulation is not expected to be significant. This product is readily biodegradable.

13. Disposal Considerations

As sold, this product, when discarded or disposed of, is a hazardous waste according to
Federal regulations (40 CFR 261). It is listed as Hazardous Waste Number Z000, listed
due to its toxicity. The transportation, storage, treatment and disposal of this waste
material must be conducted in compliance with 40 CFR 262, 263, 264, 268 and 270.
Disposal can occur only in properly permitted facilities. Refer to state and local
requirements for any additional requirements, as these may be different from Federal laws
and regulations. Chemical additions, processing or otherwise altering this material may
make waste management information presented in the MSDS incomplete, inaccurate or
otherwise inappropriate.

14. Transport Information

U.S. Department of Transportation (DOT)
Proper Shipping Name: Methyltoxy
Hazard Class: 3, 6.1
UN/NA Number: UN0000

Packing Group: PG 2
Labels Required: Flammable Liquid and Toxic

International Maritime Organization (IMDG)
Proper Shipping Name: Methyltoxy
Hazard Class: 3 Subsidiary 6.1
UN/NA Number: UN0000

B-15

Packing Group: PG 2
Labels Required: Flammable Liquid and Toxic

15. Regulatory Information

U.S. Federal Regulations
Comprehensive Environmental Response and Liability Act of 1980 (CERCLA):
The reportable quantity (RQ) for this material is 1000 pounds. If appropriate, immediately
report to the National Response Center (800/424-8802) as required by U.S. Federal Law.
Also contact appropriate state and local regulatory agencies.

Toxic Substances Control Act (TSCA): All components of this product are included on
the TSCA inventory.

Clean Water Act (CWA): Methyltoxy is a hazardous substance under the Clean Water
Act. Consult Federal, State and local regulations for specific requirements.

Clean Air Act (CAA): Methyltoxy is a hazardous substance under the Clean Air Act.
Consult Federal, State and local regulations for specific requirements.

Superfund Amendments and Reauthorization Act (SARA) Title III Information:

SARA Section 311/312 (40 CFR 370) Hazard Categories:
Immediate Hazard: X Delayed Hazard: X Fire Hazard: X
Pressure Hazard: Reactivity Hazard:

This product contains the following toxic chemical(s) subject to reporting
requirements of SARA Section 313 (40 CFR 372)
Component: CAS Number: Maximum %
Methyltoxy 000-00-0 80

State Regulations

California: This product contains the following chemicals(s) known to the State of
California to cause cancer, birth defects or reproductive harm:
Component: CAS Number: %
Methyltoxy 000-00-0 80

International Regulations

Canadian Environmental Protection Act: All of the components of this product are
included on the Canadian Domestic Substances list (DSL).

Canadian Workplace Hazardous Materials Information System (WHMIS):
Class B-2 Flammable Liquid
Class D-1-B Toxic
Class D-2-A Carcinogen
Class D-2-B Chronic Toxin
Class E Corrosive

B-16

This product has been classified in accordance with the hazard criteria of the Controlled
Products Regulations and the MSDS contains all the information required by the
Controlled Products Regulations.

European Inventory of Existing Chemicals (EINECS): All of the components of this
product are included on EINECS.

EU Classification: F Highly Flammable; T Toxic; N Dangerous to the Environment
EU Risk (R) and Safety (S) Phrases:

R11: Highly flammable.
R23/24/25: Toxic by inhalation, in contact with skin and if swallowed.
R37/38: Irritating to respiratory system and skin.
R41: Risk of serious damage to eyes.
R43: May cause sensitization by skin contact.
R45: May cause cancer.
R51/53: Toxic to aquatic organisms, may cause long-term adverse effects in the
aquatic environment.
S53: Avoid exposure – obtain special instructions before use.
S16: Keep away from sources of ignition – No Smoking.
S45: In case of accident or if you feel unwell, seek medical advice immediately
(show the label where possible).
S9: Keep container in a well-ventilated place.

S36/37: Wear suitable protective clothing and gloves.
S57: Use appropriate container to avoid environmental contamination.

16. Other Information

National Fire Protection Association (NFPA) Ratings: This information is intended
solely for the use of individuals trained in the NFPA system.

Health: 3 Flammability: 3 Reactivity: 0

Revision Indicator: New MSDS

Disclaimer: The information contained herein is accurate to the best of our knowledge.
My Company makes no warranty of any kind, express or implied, concerning the safe use
of this material in your process or in combination with other substances.

GHS Guide 1
GHS Guide 2

HAZARD COMMUNICATION

Small Entity Compliance

Guide for Employers That
Use Hazardous Chemicals

OSHA 3695-03 2014

Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions for
working men and women; by authorizing enforcement
of the standards developed under the Act; by assisting
and encouraging the States in their efforts to assure
safe and healthful working conditions; by providing for
research, information, education, and training in the field
of occupational safety and health.”

This guidance document is not a standard or regulation, and it creates no new legal obligations. It contains
recommendations as well as descriptions of mandatory safety and health standards. The recommendations
are advisory in nature, informational in content, and are intended to assist employers in providing a safe
and healthful workplace. The Occupational Safety and Health Act requires employers to comply with
safety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approved
state plan. In addition, the Act’s General Duty Clause, Section 5(a)(1), requires employers to provide their
employees with a workplace free from recognized hazards likely to cause death or serious physical harm.

Cover photo: Elizabeth Routh, Corpus Christi Area Office

Material contained in this publication is in the public
domain and may be reproduced, fully or partially, without
permission. Source credit is requested but not required.

This information will be made available to sensory-
impaired individuals upon request.

Voice phone: (202) 693-1999;
teletypewriter (TTY) number: 1-877-889-5627.

This publication provides a general overview of a particular
standards-related topic. This publication does not alter or
determine compliance responsibilities which are set forth
in OSHA standards, and the Occupational Safety and Health
Act. Moreover, because interpretations and enforcement
policy may change over time, for additional guidance on
OSHA compliance requirements, the reader should consult
current administrative interpretations and decisions by the
Occupational Safety and Health Review Commission and
the courts.

HAZARD COMMUNICATION

Small Entity Compliance
Guide for Employers That
Use Hazardous Chemicals

Occupational Safety and Health Administration

U.S. Department of Labor

OSHA 3695-03 2014

TABLE OF CONTENTS

I. Introduction ……………………………………………………………………………………………………………………………………. 1

II. Steps to an Effective Hazard Communication Program …………………………………………………………………… 7

1. Learn the Standard/Identify Responsible Staff …………………………………………………………………………… 9

2. Prepare and Implement a Written Hazard Communication Program …………………………………………..11

3. Ensure Containers are Labeled …………………………………………………………………………………………………..14

4. Maintain Safety Data Sheets ……………………………………………………………………………………………………. 20

5. Inform and Train Employees …………………………………………………………………………………………………….. 25

6. Evaluate and Reassess Your Program ………………………………………………………………………………………. 28

III. Conclusion

……………………………………………………………………………………………………………………………………. 29

Appendix A: Sample Written Hazard Communication Program ………………………………………………………….. 30

Appendix B: Quick Guide to Hazard Communication Training …………………………………………………………….. 33

Workers’ Rights

………………………………………………………………………………………………………………………………….. 36

OSHA Assistance, Services and Programs

…………………………………………………………………………………………. 36

NIOSH Health Hazard Evaluation Program

………………………………………………………………………………………….. 38

OSHA Regional Offices

………………………………………………………………………………………………………………………. 39

How to Contact OSHA

………………………………………………………………………………………………………………………… 40

Occupational Safety and Health Administrationv i

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 1

I. INTRODUCTION

Chemicals have become an important element
of almost every aspect of modern life. All
of these chemicals—from cleaning fluids to
pharmaceuticals, pesticides, and paints—are
produced in workplaces, and may be used in
workplaces downstream. While these chemicals
have utility and benefits in their applications, they
also have the potential to cause adverse effects.
These adverse effects include both health hazards
(such as carcinogenicity and sensitization), and
physical hazards (for example, flammability and
reactivity properties). In order to protect workers
from these effects—and to reduce the occurrence
of chemical source illnesses and injuries—
employers need information about the hazards of
the chemicals they use, as well as recommended
protective measures. Workers have both a right
and a need to know this information too, especially
so that they can take steps to protect themselves
when necessary.

No one knows exactly how many chemicals may be
present in American workplaces. The total number
of chemical substances that have been developed
and registered in the Chemical Abstracts Service
Registry reached 60 million in 2011—the last 10
million of those were added in less than two years.
Many of them involve innovations such as the
application of nanotechnology.

While not all of these chemicals are produced
commercially today, this vast number indicates the
scope of the potential problems in workplaces with
regard to the safe use of chemicals. In addition,
most chemical substances are formulated into
mixtures for use in the workplace. Therefore, the
number of unique chemical mixtures is far greater
than the number of substances, and most workers
are exposed to mixtures.

According to the Bureau of Labor Statistics
(BLS), acute illnesses and injuries due to chemical
exposures in the workplace have decreased
42% since the Hazard Communication Standard
was first promulgated.

The scope of workplaces in which chemical
exposures occur is also very broad. While
most people can readily associate working in a
chemical manufacturing plant as being a job that
involves chemical exposures, there are many
other types of facilities where such usage is also
commonplace. For example, construction workers
may be exposed to paints, lacquers, thinners,
asphalt fumes, or crystalline silica. Hair stylists are
exposed to chemical dyes and other hair products
that contain hazardous chemicals. All of these
types of exposures are of concern in terms of
protecting workers, and ensuring that chemicals
are used safely.

Audience for this Guide

This guide is intended to help small employers
comply with the Occupational Safety and Health
Administration’s (OSHA) Hazard Communication
Standard (HCS). The guide is advisory in nature
and informational in content. It is not itself a
standard or regulation, and it creates no new
legal obligations. The employer must refer to the
appropriate standard to ensure it is in compliance.
In 25 states and two territories, OSHA standards
are enforced by the state agency responsible
for the OSHA-approved state plan. These states
are: Alaska, Arizona, California, Hawaii, Indiana,
Iowa, Kentucky, Maryland, Michigan, Minnesota,
Nevada, New Mexico, North Carolina, Oregon,
Puerto Rico, South Carolina, Tennessee, Utah,
Vermont, Virginia, Washington, and Wyoming.
Connecticut, Illinois, New Jersey, New York, and
the Virgin Islands operate OSHA-approved State
Plans that apply only to state and local government
employees. State plans must adopt and enforce
standards that are either identical to or at least as
effective as the Federal OSHA standards.

OSHA’s Hazard Communication Standard

OSHA’s HCS, 29 CFR 1910.1200, addresses
the informational needs of employers and
workers with regard to chemicals. The HCS
was first promulgated in 1983, and covered the
manufacturing sector. It was later expanded to
cover all industries where workers are potentially
exposed to hazardous chemicals.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

Occupational Safety and Health Administration2

The revised Hazard Communication Standard is
expected to build on the success of the original
Hazard Communication Standard and prevent an
estimated additional 585 injuries and illnesses and
43 fatalities annually. It will reduce trade barriers and
result in estimated annualized benefits in productivity
improvements for American businesses that regularly
handle, store and use hazardous chemicals, as well as
cost savings for American businesses when revising
safety data sheets and labels for chemicals covered
under the standard.

In 2012, the HCS was modified to align its provisions
with the United Nations’ Globally Harmonized
System of Classification and Labelling of Chemicals
(GHS). Many benefits will result from revising the
HCS to be consistent with the GHS. In particular,
the GHS helps to ensure that imported chemicals
will be accompanied by consistent hazard and
precautionary information to protect workers
exposed in the U.S. In addition, the revised HCS can
facilitate trade in chemicals since it reduces potential
barriers posed by differing global requirements for
classification and labeling of chemicals.

“Classification” means to identify the relevant data
regarding the hazards of a chemical; review those
data to ascertain the hazards associated with the
chemical; and decide whether the chemical will be
classified as hazardous according to the definition
of hazardous chemical in this section. In addition,
classification for health and physical hazards includes
the determination of the degree of hazard, where
appropriate, by comparing the data with the criteria
for health and physical hazards.

“Label” means an appropriate group of written,
printed or graphic information elements concerning
a hazardous chemical that is affixed to, printed on, or
attached to the immediate container of a hazardous
chemical, or to the outside packaging.

“Safety data sheet (SDS)” means written or
printed material concerning a hazardous chemical
that is prepared in accordance with paragraph (g)
of this section.

The HCS is a unique OSHA standard in a number
of respects. It incorporates what is referred to as
a downstream flow of information from chemical
manufacturers, importers, and distributors, to
employers using the products:

■ The standard requires chemical manufacturers
and importers to classify the hazards of the
chemicals they produce or import, and to
prepare appropriate labels and safety data
sheets (SDSs) to convey the hazards, as well as
recommended protective measures.

■ Chemical manufacturers, importers, and
distributors must ensure that the containers
of these hazardous chemicals are labeled
when shipped, and that SDSs are provided
downstream with the first shipment and when
the SDSs are updated.

Thus, those who know the most about the
chemicals—the companies that produce, import,
or distribute them—have the responsibility to
assess available information, and convey what
is needed to downstream employers where the
hazardous chemicals are used. The scope of
coverage with regard to employers is addressed in
paragraph (b)(2) of the standard:

(b)(2) This section applies to any chemical which
is known to be present in the workplace in such
a manner that employees may be exposed under
normal conditions of use or in a foreseeable
emergency.

There are a number of definitions that impact
the interpretation of this definition of coverage
(see box to the left), but most workplaces will be
subject to the rule.

As an employer who is a chemical user, you are
required to receive labels and SDSs from your
suppliers. Employers have responsibilities under
the HCS to establish hazard communication
programs, and provide workers with access to
labels and SDSs, in addition to informing and
training these workers. The responsibilities
for hazard communication are illustrated in
Figure 1.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3

“Employee” means a worker who may be exposed
to hazardous chemicals under normal operating
conditions or in foreseeable emergencies. Workers
such as office workers or bank tellers who encounter
hazardous chemicals only in non-routine, isolated
instances are not covered.

“Exposure or exposed” means that an employee
is subjected, in the course of employment, to a
chemical that is a physical or health hazard, and
includes potential (e.g., accidental or possible)
exposure. “Subjected” in terms of health hazards
includes any route of entry (e.g., inhalation,
ingestion, skin contact or absorption.)

“Produce” means to manufacture, process, formulate,
blend, extract, generate, emit, or repackage.

“Use” means to package, handle, react, emit, extract,
generate as a by-product, or transfer.

This guide addresses employer responsibilities
under the HCS. Many of the provisions of the
standard apply only to chemical manufacturers,
importers, or distributors. This guide will focus
on assisting employers that only use but do not
produce chemicals, in order to identify the parts of
the rule that apply to their facilities, and help them
to develop and implement an effective hazard
communication program.

The 2012 revisions to the HCS, also referred to as
“HazCom 2012” in this document, primarily address
how chemical manufacturers and importers classify
chemical hazards and prepare required labels
and SDSs. If you are not a chemical manufacturer
or importer, and you already have a hazard
communication program that complies with the
original HCS, you will have limited changes to make
related to compliance with the revised standard.

Figure 1: How Hazard Communication Works

• Chemical
Manufacturers and
Importers classify
the hazards of
chemicals they
produce or import,
and prepare labels
and safety data
sheets based on the
classifications

Chemicals are Shipped to
Employers by Chemical

Manufacturers, Importers
or Distributors

Implement the
Program

• All Employers receive
labeled containers and
safety data sheets with
shipped chemicals

• All Employers must
prepare a written
hazard communication
program, including a
list of the hazardous
chemicals in the
workplace

Employers must ensure:

• All containers of
hazardous chemicals
are labeled

• Safety data sheets are
maintained for all
hazardous chemicals

• Workers are trained
on program elements,
hazards, protective
measures, etc.

Keep Information
Up-to-Date

Occupational Safety and Health Administration4

In order to understand the requirements of
HazCom 2012 as applied to your workplace, it
is useful to have a general familiarity with the
organization of the standard. It is divided into
regulatory paragraphs that describe requirements,
which are further supplemented by appendices
that contain specific details.

Organization of the Regulatory Requirements
for Hazard Communication

Paragraphs
of the Standard

Appendices
to the Standard

(a) Purpose

(b) Scope and
Application

(d) Hazard Classification

(e) Written Hazard
Communication Program

(f) Labels and Other
Forms of Warning

(g) Safety Data Sheets

(h) Employee
Information and Training

(i) Trade Secrets

(j) Effective Dates

Appendix A, Health
Hazard Criteria
(Mandatory)

Appendix B, Physical
Hazard Criteria
(Mandatory)

Appendix C, Allocation
of Label Elements
(Mandatory)

Appendix D, Safety Data
Sheets (Mandatory)

Appendix E, Definition
of “Trade Secret”
(Mandatory)

Appendix F,
Guidance for Hazard
Classifications re:
Carcinogenicity
(Non-Mandatory)

Under the HCS, an employer must prepare and
implement a hazard communication program
for workers potentially exposed to hazardous
chemicals. The requirements most relevant to this
responsibility can be found in paragraphs (e), (f),
(g), and (h) as listed above and indicated in purple.
The other parts of the standard may provide some
guidance on understanding the requirements
(such as Paragraph (c) Definitions), but your
responsibilities are to employees in your workplace,
and those responsibilities are specified in the
standard paragraphs highlighted in the table above.

As previously mentioned, your suppliers must
provide hazard information in the form of labels on
containers and SDSs when you receive a chemical.
The focus of the information is to provide the
identities and hazards of the chemicals, their
characteristics and properties, and how potential
adverse effects can be prevented. A “hazardous
chemical” means any chemical which is classified
as a physical hazard or a health hazard, a simple
asphyxiant, combustible dust, pyrophoric gas, or
hazard not otherwise classified.

In addition to the health and physical hazards
listed above, there may be some hazards that do
not meet the specified criteria for the physical
and health hazard classes provided in HazCom
2012. In these cases, the chemical manufacturer or
importer will designate the hazards as “hazards not
otherwise classified” (HNOC), and must provide
information on the SDS to ensure that downstream
employers are aware of these other effects and any
appropriate protective measures.

HCS Health and Physical Hazards

Health Hazards Physical Hazards

• Acute toxicity

• Skin corrosion/
irritation

• Serious eye damage/
eye irritation

• Respiratory or skin
sensitization

• Germ cell
mutagenicity

• Carcinogenicity

• Reproductive toxicity

• Specific target organ
toxicity – single and
repeated exposure

• Aspiration hazard

• Simple asphyxiant

• Explosives

• Flammable gases

• Flammable aerosols

• Oxidizing gases

• Gases under pressure

• Flammable liquids

• Flammable solids

• Self-reactive chemicals

• Pyrophoric liquids

• Pyrophoric solids

• Pyrophoric gas

• Self-heating chemicals

• Chemicals which in
contact with water,
emit flammable gases

• Oxidizing liquids

• Oxidizing solids

• Organic peroxides

• Corrosive to metals

• Combustible dust

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 5

HazCom 2012 refers to each of the defined hazards
as a “hazard class.” Most of these hazard classes
are subsequently divided into one or more
“hazard category(ies).” This classification is
done by the chemical manufacturer or importer,
and is based on the severity of the effect, and
the type of data available to indicate each effect.
This is important to employers because it leads
directly to the information that is subsequently
provided on labels and SDSs for the chemical. For
example, there are four categories in the hazard
class for flammable liquids. These categories
are based primarily on flashpoints, so the lower
the flashpoint, the more severe the effect. The
warnings provided on labels will reflect this
severity in different statements depending on
which category the chemical falls into based on
its flashpoint. The category itself does not appear
on the label, but it is available on the SDS for the
employer’s reference. As an example of hazard
categories under HazCom 2012, the following is
the criteria for categorizing chemicals classified as
flammable liquids:

Criteria for Flammable Liquids

Category Criteria

1 Flash point < 23°C (73.4°F) and initial boiling point ≤ 35°C (95°F)

2 Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F)

3 Flash point ≥ 23°C (73.4°F) and
≤ 60°C (140°F)

4 Flash point > 60°C (140°F) and
≤ 93°C (199.4°F)

As an employer who uses but does not
manufacture or import chemicals, you are not
responsible for making classifications or evaluating
the hazards of a chemical. You must receive a
label and SDS from your supplier based on the
classification the supplier has made given the
available scientific data on the product. All of the
criteria used by the chemical manufacturer or
importer to perform the classification are provided
in HazCom 2012 in Appendices A and B.

Employers are allowed to perform their own
classifications if they choose not to rely on the
information provided by the chemical manufacturer
or importer. If you choose to perform your own
classification you will need to comply with the
requirements in Appendices A and B of the standard.

If you choose to rely on the classification
performed by the manufacturer or importer, it is
not necessary to be familiar with the criteria for
classifying the chemicals, or the scientific data
supporting classification. However, you must
have a basic understanding of the hazardous
effects caused by the chemicals in your workplace.
You must also have such an understanding in
order to use the information to select protective
measures, and ensure proper management of the
chemicals in your workplace. Additionally, you
must include information on the different types of
hazards of the chemicals used in your workplace
and how workers can protect themselves in your
information and training program.

Compliance Dates

The first compliance date of importance is
December 1, 2013. By that date, you must train
your employees about the format and presentation
of the new labels and SDSs they will be seeing
in the workplace. Over the course of several
years, your suppliers will be updating labels and
SDSs to comply with the new requirements. It
is, therefore, important to ensure that you and
your employees are able to access and use the
information provided in the new approach. All new
labels and SDSs must be finished by June 1, 2015;
however, if you order from a distributer you may
still receive labels compliant with HazCom 1994
(the hazard communication standard issued in
1994 and replaced in 2012 by the revised standard)
until December 1, 2015. If an employer identifies
new hazards after December 1, 2015 due to the
reclassification of the hazardous chemicals, it has
six months, until June 1, 2016, to ensure that those
hazards are included in the hazard communication
program, workplace labeling reflects those
new hazards, and employees are trained on
the new hazards. During the transition from
current requirements to the new requirements,
employers may comply with either HazCom 1994
or HazCom 2012, both of which require a hazard
communication program.

Occupational Safety and Health Administration6

HazCom 2012 – Complete Schedule of Effective Dates

Effective Completion Date Requirement(s) Who

December 1, 2013 Train employees on the new label
elements and SDS format.

Employers

June 1, 2015

December 1, 2015

Comply with all modified provisions of
HazCom 2012, except:

Distributors may ship products labeled
by the manufacturer or importer under
the old system until December 1, 2015.

Chemical manufacturers, importers,
distributors and employers

June 1, 2016 Update alternative workplace labeling
and hazard communication program
as necessary, and provide additional
employee training for newly-identified
physical or health hazards.

Employers

Transition Period Comply with either HazCom 2012,
HazCom 1994, or both.

All chemical manufacturers, importers,
distributors and employers

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 7

II. STEPS TO AN EFFECTIVE
HAZARD COMMUNICATION
PROGRAM

All workplaces where workers are exposed to
hazardous chemicals must have a written hazard
communication program that describes how the
HazCom standard is implemented in that facility.
When hazard communication is implemented
effectively, it has significant benefits for both
the employer and the workers in a workplace.
Employers need the information provided to them
in order to assess the safety and health aspects
of their workplace appropriately, and to select
needed control measures for the chemicals that
are present. The information provided on SDSs
may also be used by employers to select the least
hazardous chemical available to accomplish what
is needed in the workplace. Substitution of a less
hazardous chemical benefits workers because
they will not be exposed to the greater hazards,
and benefits employers because they may have
less need for controls in some situations. The
information employers receive on labels and SDSs
will help them meet requirements for a safe and
healthful workplace.

An effective hazard communication program
benefits both workers and employers. The
information provided by suppliers allows employers
to design and implement a chemical safety and
health management program.

Workers are entitled to the information about
the identities and hazards of the chemicals
they are potentially exposed to when working.
When workers have such information, they are
able to take steps to protect themselves, and
to implement the controls their employer has
selected for them. Knowing the health effects

is important so that any signs or symptoms of
exposure can be evaluated. Furthermore, being
aware of the chemicals and associated hazards
can help the worker determine how the exposure
may affect preexisting medical conditions.

In a survey conducted by the U.S. Government
Accountability Office (GAO), approximately 30%
of responding small businesses indicated they
used information on SDSs to find less hazardous
chemicals to use in their workplaces.

Some employers view hazard communication as
merely a “paper exercise,” regarding compliance
as just making sure that all the required labels and
SDSs are available, but not using the information.
Hazard communication is much more than a
paper exercise when implemented properly. The
proper use of the information by employers to
control chemical exposure results in a decrease
in illnesses and injuries caused by chemicals
in the workplace—a clear benefit for exposed
workers. Effective hazard communication also
helps with effective management of chemicals in
the workplace, resulting in increased productivity,
decreased workers’ compensation costs, and other
employer benefits.

The HCS includes a three-part approach to
communicating information to downstream
employers, as well as workers.

■ Labeling containers of hazardous chemicals,
which serves as an immediate warning of
hazards

■ SDSs, which are sources of detailed
information on the hazardous chemical

■ Training on the hazards

An effective hazard communication program can
be accomplished in six steps (Figure 2).

Occupational Safety and Health Administration8

Figure 2: Six Steps to an Effective Hazard Communication

Program

1. Learn the
Standard/Identify
Responsible Staff

• Obtain a copy of OSHA’s Hazard Communication Standard.

• Become familiar with its provisions.

• Make sure that someone has primary responsibility for
coordinating implementation.

• Identify staff for particular activities (e.g., training).

2. Prepare and
Implement a
Written Hazard
Communication
Program

• Prepare a written plan to indicate how hazard
communication will be addressed in your facility.

• Prepare a list or inventory of all hazardous chemicals in
the workplace.

3. Ensure Containers
are Labeled

• Keep labels on shipped containers.

• Label workplace containers where required.

4. Maintain Safety
Data Sheets

• Maintain safety data sheets for each hazardous chemical in
the workplace.

• Ensure that safety data sheets are readily accessible
to employees.

5. Inform and Train
Employees

• Train employees on the hazardous chemicals in their
work area before initial assignment, and when new hazards
are introduced.

• Include the requirements of the standard, hazards of
chemicals, appropriate protective measures, and where and
how to obtain additional information.

6. Evaluate and
Reassess Your
Program

• Review your hazard communication program periodically to
make sure that it is still working and meeting its objectives.

• Revise your program as appropriate to address changed
conditions in the workplace (e.g., new chemicals, new
hazards, etc.).

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 9

1. Learn the
Standard/Identify
Responsible Staff
• Obtain a copy of OSHA’s Hazard Communication Standard.
• Become familiar with its provisions.
• Make sure that someone has primary responsibility for
coordinating implementation.
• Identify staff for particular activities (e.g., training).

You are already on your way to accomplishing
Step 1 by reading this guide. It is always best
to review the actual provisions of the standard
to ensure you are in full compliance. OSHA
provides online access to the standard, as well
as guidance, interpretations, and other relevant
materials on its hazard communication web page:
www.osha.gov/dsg/hazcom. The full regulatory
text can be found at: www.osha.gov/dsg/hazcom/
HCSFinalRegTxt.html.

As noted above, the provisions that apply
to employers simply using chemicals in the
workplace, rather than those that produce or
import chemicals, are found primarily in the
following paragraphs:

(e) Written Hazard Communication Program;
(f) Labels and Other Forms of Warning;
(g) Safety Data Sheets; and
(h) Employee Information and Training.

You can focus on the requirements in these
paragraphs to determine what is needed for
compliance in your workplace. There may also be
other provisions of the standard that help establish
compliance requirements in some workplaces.

Paragraph (b), Scope and Application, specifies
two types of work operations where the coverage
of the rule is limited. These are laboratories
and operations where chemicals are only
handled in sealed containers (e.g., a warehouse).
Employers with these types of work operations
have reduced obligations under the HCS and
basically only need to keep labels on containers
as they are received; maintain SDSs that are
received, and give employees access to them; and
provide information and training to employees.

Laboratories and operations where chemicals are
only handled in sealed containers do not have to
have written hazard communication programs and
lists of chemicals.

The limited coverage for laboratories and sealed
container operations addresses your obligation
to your own workers in the operations involved.
However, when laboratory employers or employers
where only sealed containers are involved
act as chemical manufacturers, distributors
or importers, they must fulfill their duties as
suppliers. For example, in warehouse operations
where the employees are only exposed to sealed
containers, paragraph (b)(4) of the standard would
apply. When these chemicals are distributed to
downstream users, paragraph (b)(4) requires the
company to provide HazCom 2012-compliant labels
and SDSs to downstream customers at the time of
the first shipment and when the SDS is updated.

Paragraph (c), Definitions, can be used to
determine the meaning of some provisions in
HazCom 2012 through the definitions provided for
the terms used in them. This guide will highlight
some of these definitions, but you may want to
consult the definitions for other terms to help
ensure you fully understand your compliance
obligations in the workplace.

Hazard communication must be a continuing
program in your facility. Compliance with the
HCS is not a “one shot deal.” In order to have
a successful program, it will be necessary to
assign responsibility to staff for both the initial
and ongoing activities needed to comply with
the standard. In some cases, these activities may
already be part of current job assignments. For
example, site supervisors are frequently responsible

http://www.osha.gov/dsg/hazcom/index.html

http://www.osha.gov/dsg/hazcom/HCSFinalRegTxt.html

Occupational Safety and Health Administration10

for on-the-job training sessions. Early identification
of the responsible workers, and their involvement in
the development of your plan of action, will result in
a more effective program design.

In order to ensure you have an effective
program and address all of the necessary
components, responsibility for implementation
of hazard communication should be assigned
to someone to coordinate. While different
people may be responsible for certain parts
of implementation, there should nevertheless

be someone who has overall responsibility.
Approaching compliance consistently, and
comprehensively, is the key to success.

The person responsible for the overall coordination
may not be the best person to accomplish all
of the elements. For example, training workers
may require different expertise than coordinating
compliance. The standard allows employers the
flexibility to do what is best in their own facilities as
long as compliance with all elements is achieved.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 11

2. Prepare and
Implement a
Written Hazard
Communication
Program
• Prepare a written plan to indicate how hazard
communication will be addressed in your facility.
• Prepare a list or inventory of all hazardous chemicals in
the workplace.

Paragraph (e), Written Hazard Communication
Program, requires employers to prepare and
implement a written hazard communication
program. This does not need to be lengthy or
complicated. The main intent of the requirement is
to help ensure that compliance with the standard
is done in a systematic way and that all elements
are coordinated. Thus, the program must describe
how the employer will address the requirements
of paragraphs (f) Labels and Other Forms of
Warning; (g) Safety Data Sheets; and (h) Employee
Information and Training, in the workplace. A
sample written program is provided in Appendix A
of this guide.

In addition, the written program must include the
following items:

■ Paragraph (e)(1): A list of the hazardous
chemicals known to be present in the
workplace. The list may be kept using any
product identifier from the SDS. Thus, the list
may be kept by product name, common name,
or chemical name. The important aspect of
this requirement is that the term used on the
list must also be available on both the SDS
and the label so that these documents can be
cross-referenced. The list can be compiled in
whatever way the employer finds most useful
and applicable to the workplace. A list of all
hazardous chemicals in the entire workplace
may be most suitable for very small facilities,
where there are few work areas and all
workers are potentially exposed to essentially
the same products. For larger workplaces, it
may be more convenient to compile lists of
hazardous chemicals by work area and have
them assembled together as the overall list for
the workplace.

The list is an inventory of chemicals for which
the employer must ensure that there is an
SDS available. Compiling the list also helps
employers keep track of the chemicals present,
and to identify chemicals that are no longer
being used, and thus could be removed from
the workplace. Removing such chemicals may
also reduce potential adverse effects that could
occur in the workplace.

The best way to prepare a comprehensive list
may be to survey the workplace. Purchasing
records may also help and employers should
establish procedures to ensure that purchasing
procedures result in receiving SDSs before
a material is used in the workplace. Prior to
purchasing chemicals, review the hazards of
the chemicals and evaluate if less hazardous
chemicals can be used instead.

“Product identifier” means the name or number
used for a hazardous chemical on a label or in
the SDS. It provides a unique means by which
the user can identify the chemical. The product
identifier used shall permit cross-references to
be made among the list of hazardous chemicals
required in the written hazard communication
program, the label and the SDS.

The broadest possible perspective should
be taken when doing the survey. Sometimes
people think of “chemicals” as being only
liquids in containers. The HCS covers
chemicals in all 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

Occupational Safety and Health Administration12

the factors that determine whether a chemical
is covered. If the chemical is not hazardous, it
is not covered by the standard. If there is no
potential for exposure (e.g., the chemical is
inextricably bound and cannot be released), the
chemical is not covered by the standard.

Look around. Identify chemicals in containers,
including pipes, but also think about chemicals
that are generated during work operations. For
example, welding fumes, dusts, and exhaust
fumes are all sources of chemical exposures.
Read the labels provided by suppliers for hazard
information. Make a list of all chemicals in the
workplace that are potentially hazardous. For
your own information and planning, you may
also want to note on the list the location(s) of the
products within the workplace, and an indication
of the hazards as found on the label. This will
help as you prepare the rest of your program.

Paragraph (b) of the standard, scope and
application, includes exemptions for various
chemicals or workplace situations. After
compiling the complete list of chemicals, you
should review paragraph (b) to determine if
any of the items can be eliminated from the
list because they are exempted materials. For
example, food, drugs, and cosmetics brought
into the workplace for personal consumption
by workers are exempt.

Once you have compiled a complete list of
the potentially hazardous chemicals in the
workplace, the next step is to determine if
you have received SDSs for all of them. Check
your files against the inventory you have just
compiled. Employers are required to have
SDSs for all hazardous chemicals that they
use. If any are missing, contact your supplier
and request one. It is a good idea to document
these requests, either by keeping a copy of a
letter or e-mail, or a note regarding telephone
conversations. If you cannot show a good faith
effort to receive the SDS, you can be cited for
not having the SDS for a hazardous chemical.
If you have SDSs for chemicals that are not on
your list, figure out why. Maybe you do not use
the chemical anymore. Or maybe you missed

it in your survey. Some suppliers provide
SDSs for products that are not hazardous.
These SDSs do not have to be maintained.

Do not allow workers to use any hazardous
chemicals for which you have not received an
SDS. The SDS provides information you need
to ensure that proper protective measures are
implemented prior to worker exposure.

■ Paragraph (e)(1)(ii): Methods to inform
employees of the hazards of non-routine tasks.
The written program needs to include how
an employer will inform workers of hazards
that are outside of their normal work routine.
While workers’ initial training will address the
types of exposures they will encounter in their
usual work routines, there may be other tasks
to be performed on occasion that will expose
these workers to different hazards, as well as
require novel control measures. For example,
in a manufacturing facility, it may be necessary
periodically to drain and clean out reactor
vessels. For this task, workers may be exposed
to cleaning chemicals that are not normally in
the workplace, and the usual controls for the
process may not protect them, so personal
protective equipment may have to be worn.
The written program needs to address how the
employer will handle such situations and make
sure that workers involved have the necessary
information to stay protected.

■ Paragraph (e)(2): Multi-Employer Workplaces.
Where there is more than one employer
operating on a site, and employees may
be exposed to the chemicals used by each
employer, the employer’s written hazard
communication program must address:

— How on-site access to SDSs will be
provided to the other employer(s).

— How such employers will be informed of
needed precautionary measures.

— How such employers will be informed of
the on-site labeling system if it is different
from the labels specified for shipped
containers under the standard.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 13

In summary, if you are not a new employer,
you should already have a written hazard
communication program for your workplace.
Review your written program to ensure that it is
consistent with the HazCom 2012 requirements.
It may need to be updated; for example, you may
have to add or delete chemicals from the list in
the program, or change your description of the
approach to workplace labeling.

If your workers’ job assignment requires travel
between various geographical locations, you
may keep the written program at the primary
work location.

Many trade associations and other professional
groups have provided sample programs and
other assistance materials to employers. These
have been very helpful to many employers since
they tend to be tailored to the particular industry
involved. You may wish to investigate whether

your industry trade groups have developed such
materials. Additionally, a sample written hazard
communication program is included in Appendix A
to this guide.

Although such general guidance may be helpful,
you must remember that the written program has
to reflect what you are doing in your workplace.
Therefore, if you use a generic program it must
be adapted to address the facility that it actually
covers. For example, the written plan must list
the chemicals present at the site, indicate who is
to be responsible for the various aspects of the
program in your facility, and indicate where written
materials will be made available to workers.

If OSHA inspects your workplace, the OSHA
Compliance Safety and Health Officer (CSHO) will
ask to see your written plan.

Occupational Safety and Health Administration14

3. Ensure Containers
are Labeled
• Keep labels on shipped containers.
• Label workplace containers where required.

Labels are the first part (paragraph (f) Labels and
Other Forms of Warning) of the three-part approach
to communicating information downstream
mentioned earlier. A label must be on the
immediate container of every hazardous chemical.
The label is an immediate type of warning since
it is present in the work area, right on the actual
container of a hazardous chemical. It is a snapshot
of the hazards and protective information related to
the chemical, and a summary of the more detailed
information available on the SDS.

When you purchase a hazardous chemical from a
supplier, you will receive a container that is labeled
with the information required under the HCS.
Employers can rely on the information provided
by their suppliers. The label requirements in the
HCS changed significantly with the publication of
HazCom 2012. Under the prior standard, chemical
manufacturers and importers were required to
convey the hazards and identity of the products,
but were not given specifications on how this
was to be done. As a result, labels varied in
terms of how the information was conveyed, the
terminology used, and the design of the label. This
made it more difficult for employers and workers
to access and comprehend the information
presented than if chemical manufacturers and
importers follow the same approach.

The label requirements for the revised standard
are more specific, which will lead to increased
uniformity. This should benefit employers
and workers by providing the information in
standardized language and graphics, making it
easier to understand, and helping to ensure that
labels on containers of the same chemical from
different suppliers have the same information.

HazCom 2012 provides chemical manufacturers
and importers the information to be conveyed
once they have determined the hazard of a
chemical. The labels you receive on a shipped

container must have the following information,
located together (other information may also
appear on the label):

■ Product identifier

■ Signal word

■ Hazard statement(s)

■ Pictogram(s)

■ Precautionary statement(s)

■ Name, address, and phone number of the
responsible party

■ The product identifier is any chemical,
common, or trade name or designation that the
chemical manufacturer or importer chooses to
use on the label. The term must also appear on
the SDS. The signal word, hazard statement(s),
pictogram(s), and precautionary statement(s)
are the label elements that comprise the
primary information about hazards and
protective measures on the label.

■ A signal word is a word used to indicate the
relative level of severity of hazard and alert the
reader to a potential hazard on the label. The
signal words used in the standard are “danger”
and “warning.” “Danger” is used for the more
severe hazards, while “warning” is used for
the less severe hazards. Signal words were not
previously used in the HCS, although they do
often appear on consumer labels. It is important
to be aware of—and train workers on—the way
signal words convey a difference in the severity
of the hazard. While the product is hazardous
wherever a signal word is indicated, the signal
word chosen can give a preliminary idea of the
relative significance of the effect.

■ A hazard statement is a statement assigned to
a hazard class and category that describes the
nature of the hazard(s) of a chemical, including,
where appropriate, the degree of hazard.
Example: Fatal if swallowed.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 15

■ The hazard statement(s) for a hazardous
chemical describe the hazard(s) in text, in
a simple, direct manner. There is a hazard
statement for each hazard category of a hazard
class, and it will vary depending on the degree
of hazard. The example presented above is a
hazard statement for acute oral toxicity. The
hazard statement conveys that the chemical is
severely toxic, and ingestion of the chemical
results in death. But for less toxic chemicals,
the hazard statement may be “toxic if
swallowed” or “harmful if swallowed.” As with
the signal words, this information conveys the
relative severity of the hazard, which impacts
how it is handled and controlled.

■ A pictogram is a composition that may include
a symbol plus other graphic elements, such as
a border, background pattern, or color, that is
intended to convey specific information about
the hazards of a chemical. Eight pictograms are
designated under this standard for application
to a hazard category. Under HazCom 2012,
pictograms are black symbols, on a white
background, with a red diamond border. For
example, this is the pictogram for oxidizers:

Pictograms are an important addition to the
hazard communication tools in the standard.
A pictogram draws the attention of a label
reader, and you and your workers should be
aware that the appearance of a pictogram in
a red diamond frame means that a hazard of
concern is present in the product. Some of the
pictograms in the standard have symbols that
resemble the hazardous effect, and others are
merely meant to attract attention. Pictograms
may be used for several different hazardous
effects as well (see Figure 3).

Pictograms have long been used internationally
because they convey information without text.
This allows users who are either literate in a
different language than that used on the label
or who are not literate at all to understand that
the chemical is hazardous.

One of the systems that has long used
pictograms is the international transport
system. This system has been adopted by
the U.S. Department of Transportation (DOT),
and is familiar to those who handle shipping
containers in the United States. The symbols
have been harmonized as much as possible
for the hazards covered both in transport
and in the workplace. While both pictograms
are diamond-shaped, the transport system’s
pictograms have backgrounds of various
colors. Where the shipping container is also the
container used in the workplace, workers must
be made aware of the DOT pictograms1, as
they may appear on the label in addition to, or
instead of, the HazCom 2012 pictograms used
to represent the same hazard. See Figure 4 for
examples of DOT pictograms. Note that the
environment pictogram located in the center
of the bottom row in Figure 3 is not required
under the OSHA standard since OSHA does
not regulate environmental hazards. However,
you may see this pictogram used on labels and
SDSs to convey environmental hazards, and
that will provide useful information for you to
use in managing your chemicals.

1. The U.S. Department of Transportation (DOT) uses the terms transport
“placards” or “labels” to refer to the diamond-shaped (square on point)
graphic elements that are used to identify shipments of hazardous materi-
als. However, for the purpose of this document, these graphic elements
are referred to as “pictograms.” More information on DOT placards or
labels may be found at www.dot.gov.

http://www.dot.gov

Occupational Safety and Health Administration16

Figure 3: HazCom 2012 Pictograms

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 17

Figure 4: Examples of Transport Pictograms

Occupational Safety and Health Administration18

■ A precautionary statement is a phrase that
describes recommended measures that should
be taken to minimize or prevent adverse
effects resulting from exposure to a hazardous
chemical, or improper storage or handling.
Example: Do not eat, drink, or smoke when
using this product.

Precautionary statements are key to helping you
decide what you need to do to protect workers
and your workplace. There are four types of
statements: Prevention, Response, Storage, and
Disposal. These have been assigned to hazard
classes and categories.

Therefore, a compliant HazCom 2012 label on a
shipped container will have at least the following
information as shown in Figure 5 (supplemental
information is permitted as long as it does not
conflict with the required information).

You are required by paragraph (f)(6) of the
standard to ensure that containers of hazardous
chemicals in your workplace are labeled. For those
containers that are received already labeled from

the supplier, and are used in the workplace, simply
maintaining the label received from the supplier is
the best and easiest option. However, the standard
is flexible, and employers may relabel these
containers, or label other containers used in the
workplace with various options as long as workers
have immediate access to the specific information
about the physical and health hazards of the
chemical. This could be included in the workplace
hazard communication program.

Under paragraph (f)(7), employers may use signs,
placards, process sheets, batch tickets, operating
procedures, or other written material instead of
affixing labels to individual stationary process
containers, as long as the alternative method
identifies which containers it applies to and conveys
at least general information regarding the hazards
of the chemicals. Paragraph (f)(8) of the standard
also addresses portable containers into which the
hazardous chemicals are transferred from a labeled
container, and which are for the immediate use of
the employee who performs the transfer. These
portable containers do not have to be labeled.

Figure 5: Example of Required HCS Label Elements

Product Identifier
Pictogram (Symbol in Red Frame)

Signal Word (Danger)
Hazard Statement(s) (Extremely flammable gas)

Precautionary Statement(s) (Keep away from heat and open flames. No smoking.
Leaking gas fire: Do not extinguish, unless leak can be stopped safely. Eliminate all ignition

sources if safe to do so. Store in well-ventilated place.)

Name, Address, and Telephone Number
of Manufacturer, Importer, or Other Responsible Party

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 19

Some employers use third-party workplace label
systems, such as those that have numerical
ratings to indicate the hazards (e.g., National
Fire Protection Association (NFPA) or Hazardous
Materials Identification System (HMIS)). These
may be used in conjunction with the supplemental
information on the label to ensure that workers
have complete information, as long as the ratings
are consistent with the hazard definitions in
HazCom 2012, i.e., the criteria used to assign the
numerical ratings reflects the hazard categories
in each hazard class in HazCom 2012. One note
with regard to numerical ratings—these systems
generally use the number 1 to indicate the lowest
degree of hazard, and the number 4 as the highest
degree. This is the opposite of the hazard category
numbering in HazCom 2012. Therefore, if as an
employer you are preparing such labels based
on information on the SDS, you must ensure that
the numbers are properly applied to reflect the
accurate degree of hazard information. Category
numbers do not appear on HazCom 2012 shipped
container labels, and are not equivalent to the
hazard rating systems.

HazCom 2012 hazard category numbers are not
required to appear on shipped container labels, and
are not equivalent to the NFPA and HMIS hazard
rating systems.

The employer must make sure that labels in the
workplace are legible and prominently displayed.
While the label information must be in English,
employers are free to add warnings in other
languages if workers would find that helpful. OSHA
has prepared QuickCards™ to describe the label
elements (OSHA 3492), as well as illustrate the
pictograms (OSHA 3491). These are available on
the OSHA web page, or can be obtained from your
local OSHA area office.

If your workplace is inspected by OSHA, CSHOs
will be looking for at least the following aspects of
your labeling approach:

1. Designation of person(s) responsible for
ensuring compliant labeling of shipped and in-
plant containers;

2. Description of written alternatives to labeling of
stationary process containers (if used);

3. Appropriate labels on all workplace containers,
including those received from a supplier,
secondary containers, and stationary process
containers;

4. A description and explanation of labels on both
shipped and workplace containers included in
the employee training program; and,

5. Procedures to review and update workplace
label information when necessary.

https://www.osha.gov/Publications/OSHA3492QuickCardLabel

https://www.osha.gov/Publications/OSHA3491QuickCardPictogram

Occupational Safety and Health Administration2 0

4. Maintain Safety
Data Sheets
• Maintain safety data sheets for each hazardous chemical in
the workplace.
• Ensure that safety data sheets are readily accessible
to employees.

The second part in the approach to communicating
information in HazCom 2012 is to maintain
SDSs (paragraph (g) Safety Data Sheets and
Mandatory Appendix D). The SDSs are the source
of detailed information on hazardous chemicals.
This includes information for many different
audiences—employers, workers, safety and
health professionals, emergency responders,
government agencies, and consumers. It is difficult
for one document to serve the needs of all of these
different audiences since some require much
more technical information than others. Therefore,
the SDS sections have generally been organized
so that the information of most use to exposed
workers, emergency responders, and others who
do not need extensive technical detail is in the
beginning of the SDS, while the more technical
information most commonly read by health and
safety professionals is located in the later sections.
For example, a description of a chemical’s health
effects appears in Section 2, hazard identification,
but the toxicological data upon which the
determination of these effects is based appears
in Section 11, toxicological information. All of the
sections are available to any reader, but there
is a difference between what is necessary for
a broader audience (workers and emergency
responders, for example), and what might be
needed by others designing protective measures
or providing medical services.

The SDS requirements in HazCom 2012 are based
on an internationally agreed upon 16-section SDS.
This format is based on ANSI Z400.12, so it

2 The first American National Standard Institute (ANSI) standard developed
to assist in the preparation of safety data sheets (American National
Standard for Hazardous Industrial Chemicals–Material Safety Data Sheets–
Preparation) was issued in 1993. This standard was updated in 1998 and
2004. In 2010, it was combined with ANSI Z129 and renamed, American
National Standard for Hazardous Workplace Chemicals–Hazard Evaluation
and Safety Data Sheet and Precautionary Labeling Preparation.

is most likely already familiar to your employees.
HazCom 2012 establishes section headings for the
SDS, as well as the order in which they are to be
provided, and the minimum information required
to be included in each section under Appendix D
of the standard. However, the information in some
of the sections are non-mandatory because they
address information that involve the requirements
of other government bodies, and thus are not
under OSHA’s jurisdiction. Even though these
sections are not considered mandatory by OSHA,
the headings are still required to be present on the
SDS. They will provide useful information for you
to address other requirements you may need to
follow. The sixteen sections are as follows, with
the non-mandatory sections indicated in italics:

1. Identification
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure control/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information

Chemical manufacturers and importers are
required to obtain or develop an SDS for each
hazardous chemical they produce or import.
Chemical manufacturers, importers, and

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 2 1

distributors are responsible for ensuring that their
customers are provided a copy of these SDSs, at
the time of the first shipment, and when an SDS
is updated with new and significant information.
Employers must have an SDS for each hazardous
chemical which they use. Employers may rely
on the information received from their suppliers
unless they know the information is incorrect.
If you do not receive an SDS automatically, you
must request one as soon as possible. If you
receive an SDS that is obviously inadequate, with,
for example, blank spaces, you must request an
appropriately completed one. If your request for
an SDS or for a corrected SDS does not produce
the information needed, you should contact your
local OSHA area office for assistance in obtaining
the SDS. Employers must maintain the current
version of the SDS; if a new SDS is received with a
shipment, they must maintain and make available
the new SDS.

The SDSs must be in English. Many larger
manufacturers also produce SDSs in other
languages. If you have workers who speak
language(s) other than English, you may be able to
obtain SDSs in those languages to ensure effective
hazard communication.

Employers must maintain copies of SDSs in their
workplaces, and must ensure that SDSs are readily
accessible to workers when they are in their work
areas during their work shifts. This accessibility
may be accomplished in many different ways. You
must decide what is appropriate for your particular
workplace. Some employers keep the SDSs in
a binder in a central location (e.g., in a pick-up
truck on a construction site). Others, particularly
in workplaces with large numbers of chemicals,
provide access electronically. However, if access
to SDSs is provided electronically, there must
be an adequate back-up system in place in the
event of a power outage, equipment failure, or
other emergency involving the primary electronic
system. As long as workers can get the information
when they need it, any approach may be used.
When workers must travel between workplaces
during a work shift, SDSs may be kept at the
primary workplace facility. No matter what system

is used, employers must ensure that workers and
medical personnel can immediately obtain the
required information in an emergency.

In order to ensure that you have a current SDS for
each chemical in the plant as required, and that
worker access is provided, OSHA’s CSHOs will be
looking for the following items in your program:

1. Designation of person(s) responsible for
obtaining and maintaining the SDSs;

2. How such sheets are maintained in the
workplace (e.g., in notebooks in the work
area(s) or electronically), and how workers
obtain access to them when they are in their
work area during the work shift;

3. Procedures to follow when the SDS is not
received at the time of the first shipment;

4. An SDS for each hazardous chemical in
the workplace, and training of workers that
includes review of SDS format and use.

For employers using hazardous chemicals, an
important aspect of the hazard communication
program is to ensure that someone is responsible
for obtaining and maintaining the SDSs for
every hazardous chemical in the workplace. To
ensure that your hazard communication program
improves safety and health with regard to
chemical use, you should review the SDSs, and use
the information to choose the needed protective
measures to prevent or reduce exposures in your
workplace. SDSs should be used to evaluate your
workplace, and establish a plan to ensure it is safe.
The following is a section-by-section description of
the information required for each part of the SDS
from Appendix D of HazCom 2012. Become familiar
with the information available in each section of an
SDS so that you will be able to more quickly access
this information in an emergency and make better
use of the data available.

OSHA has developed a QuickCard™ on SDSs
(OSHA 3493) that may be useful in your training
program. It is available on the OSHA Hazard
Communication web page at www.osha.gov/dsg/
hazcom, or from your local OSHA area office.

http://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html

http://www.osha.gov/dsg/hazcom

Occupational Safety and Health Administration2 2

Minimum Information for an SDS

Heading Subheading

1. Identification (a) Product identifier used on the label;

(b) Other means of identification;

(d) Name, address, and telephone number of the chemical manufacturer, importer, or other
responsible party;

(e) Emergency phone number.

2. Hazard(s)
identification

(a) Classification of the chemical in accordance with paragraph (d) of §1910.1200;

(b) Signal word, hazard statement(s), symbol(s) and precautionary statement(s) in accord with
paragraph (f) of §1910.1200. (Hazard symbols may be provided as graphical reproductions
in black and white or the name of the symbol, e.g., flame, skull and crossbones);

(d) Where an ingredient with unknown acute toxicity is used in a mixture at a concentration
≥ 1% and the mixture is not classified based on testing of the mixture as a whole, a
statement that X% of the mixture consists of ingredient(s) of unknown acute toxicity is
required.

3. Composition/
information on
ingredients

Except as provided for in paragraph (i) of §1910.1200 on trade secrets:

For Substances

(a) Chemical name;

(b) Common name and synonyms;

(d) Impurities and stabilizing additives which are themselves classified and which contribute
to the classification of the substance.

For Mixtures

In addition to the information required for substances:

(a) The chemical name and concentration (exact percentage) or concentration ranges of all
ingredients which are classified as health hazards in accordance with paragraph (d) of
§1910.1200 and

(1) are present above their cut-off/concentration limits; or

(2) present a health risk below the cut-off/concentration limits.

(b) The concentration (exact percentage) shall be specified unless a trade secret claim is made
in accordance with paragraph (i) of §1910.1200, when there is batch-to-batch variability in
the production of a mixture, or for a group of substantially similar mixtures (See A.0.5.1.2)
with similar chemical composition. In these cases, concentration ranges may be used.

For All Chemicals Where a Trade Secret is Claimed

Where a trade secret is claimed in accordance with paragraph (i) of §1910.1200, a statement
that the specific chemical identity and/or exact percentage (concentration) of composition has
been withheld as a trade secret is required.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 2 3

Heading Subheading

4. First-aid
measures

(a) Description of necessary measures, subdivided according to the different routes of
exposure, i.e., inhalation, skin and eye contact, and ingestion;

(b) Most important symptoms/effects, acute and delayed;

5. Firefighting
measures

(a) Suitable (and unsuitable) extinguishing media;

(b) Specific hazards arising from the chemical (e.g., nature of any hazardous combustion
products);

6. Accidental
release measures

(a) Personal precautions, protective equipment, and emergency procedures;

(b) Methods and materials for containment and cleaning up.

7. Handling and
storage

(a) Precautions for safe handling;

(b) Conditions for safe storage, including any incompatibilities.

8. Exposure
controls/
personal
protection

(a) OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial
Hygienists (ACGIH) Threshold Limit Value (TLV), and any other exposure limit used or
recommended by the chemical manufacturer, importer, or employer preparing the safety
data sheet, where available;

(b) Appropriate engineering controls;

9. Physical and
chemical
properties

(a) Appearance (physical state, color, etc.);

(b) Odor;

(d) pH;

(e) Melting point/freezing point;

(f) Initial boiling point and boiling range;

(g) Flash point;

(h) Evaporation rate;

(i) Flammability (solid, gas);

(j) Upper/lower flammability or explosive limits;

(k) Vapor pressure;

(l) Vapor density;

(m) Relative density;

(n) Solubility(ies);

(o) Partition coefficient: n-octanol/water;

(p) Auto-ignition temperature;

(q) Decomposition temperature;

(r) Viscosity.

Occupational Safety and Health Administration2 4

Heading Subheading

10. Stability and
reactivity

(a) Reactivity;

(b) Chemical stability;

(d) Conditions to avoid (e.g., static discharge, shock, or vibration);

(e) Incompatible materials;

(f) Hazardous decomposition products.

11. Toxicological
information

Description of the various toxicological (health) effects and the available data used to identify
those effects, including:

(a) Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact);

(b) Symptoms related to the physical, chemical and toxicological characteristics;

(d) Numerical measures of toxicity (such as acute toxicity estimates);

(e) Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on
Carcinogens (latest edition) or has been found to be a potential carcinogen in the International
Agency for Research on Cancer (IARC) Monographs (latest edition), or by OSHA.

12. Ecological
information
(Non-
mandatory)

(a) Ecotoxicity (aquatic and terrestrial, where available);

(b) Persistence and degradability;

(d) Mobility in soil;

(e) Other adverse effects (such as hazardous to the ozone layer).

13. Disposal
considerations
(Non-
mandatory)

Description of waste residues and information on their safe handling and methods of disposal,
including the disposal of any contaminated packaging.

14. Transport
information
(Non-
mandatory)

(a) UN number;

(b) UN proper shipping name;

(d) Packing group, if applicable;

(e) Environmental hazards (e.g., Marine pollutant (Yes/No));

(f) Transport in bulk (according to Annex II of MARPOL 73/78 and the IBC Code);

(g) Special precautions which a user needs to be aware of, or needs to comply with, in
connection with transport or conveyance either within or outside their premises.

15. Regulatory
information
(Non-
mandatory)

Safety, health and environmental regulations specific for the product in question.

16. Other
information,
including date
of preparation
or last revision

The date of preparation of the SDS or the last change to it.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 2 5

5. Inform and Train
Employees
• Train employees on the hazardous chemicals in their
work area before initial assignment, and when new hazards
are introduced.
• Include the requirements of the standard, hazards of
chemicals, appropriate protective measures, and where and
how to obtain additional information.

The third part of the hazard communication approach
in HazCom 2012 is employee information and training
(paragraph (h) Employee Information and Training).
The key requirement is in paragraph (h)(1):

(h)(1) Employers shall provide employees with
effective information and training on hazardous
chemicals in their work area at the time of their
initial assignment, and whenever a new chemical
hazard the employees have not previously been
trained about is introduced into their work area.
Information and training may be designed to
cover categories of hazards (e.g., flammability,
carcinogenicity) or specific chemicals. Chemical-
specific information must always be available
through labels and safety data sheets.

For information and training to be effective, the
workers in the training must comprehend the
hazards in the workplace and ways to protect
themselves. OSHA does not expect that workers
will be able to recall and recite all data provided
about each hazardous chemical in the workplace.
What is most important is that workers understand
that they are exposed to hazardous chemicals,
know how to read labels and SDSs, and have a
general understanding of what information is
provided in these documents, and how to access
these tools. Workers must also be aware of the
protective measures available in their workplace,
how to use or implement these measures, and who
they should contact if an issue arises.

Information and training may be done either by
individual chemical, or by hazard classes and
categories (such as acute toxicity or flammable
liquids). If there are only a few chemicals in the
workplace, then you may want to discuss each
one individually. Where there are large numbers of

chemicals, or the chemicals change frequently, you
will probably want to train generally based on the
hazard classes and categories. Workers must have
access to the substance-specific information on
the labels and SDSs.

HazCom 2012 requires employers to both provide
certain information to employees and to train
employees. The standard requires employees to be
informed of:

■ The general requirements of the Hazard
Communication Standard;

■ Where hazardous chemicals are located in their
work areas (operations where exposure may
occur); and,

■ What the workplace hazard communication
program includes, and where and how they can
access the program.

Training, on the other hand, is a more active
process. The training conducted to comply with
HazCom 2012 must address the following:

■ Methods and observations that may be used to
detect the presence or release of a hazardous
chemical in the work area (such as monitoring
conducted by the employer, continuous
monitoring devices, visual appearance or odor of
hazardous chemicals when being released, etc.);

■ The physical, health, simple asphyxiation,
combustible dust and pyrophoric gas hazards,
as well as hazards not otherwise classified, of
the chemicals in the work area;

■ The measures employees can take to protect
themselves from these hazards, including
specific procedures the employer has
implemented to protect employees from

Occupational Safety and Health Administration2 6

exposure to hazardous chemicals, such
as appropriate work practices, emergency
procedures, and personal protective equipment
to be used; and,

■ The details of the hazard communication
program developed by the employer, including
an explanation of the labels received on
shipped containers and the workplace labeling
system used by their employer; the SDS,
including the format of the SDS (where each
type of information is located) and how
employees can obtain and use the appropriate
hazard information.

A properly conducted training program will ensure
worker comprehension and understanding. It is
not sufficient to either just read material to the
workers, or simply hand them material to read.
As explained in Dr. Michaels’ OSHA Training
Standards Policy Statement (April 28, 2010), OSHA
requires employers to present information in a
manner and language that their employees can
understand. If employers customarily need to
communicate work instructions or other workplace
information to employees in a language other than
English, they will also need to provide safety and
health training to employees in the same manner.
Similarly, if the employee’s vocabulary is limited,
the training must account for that limitation. By the
same token, if employees are not literate, telling
them to read training materials will not satisfy the
employer’s training obligation.

In conducting a training program, you want to
create a climate where workers feel free to ask
questions. This will help you to ensure that the
information is understood. You must always
remember that the underlying purpose of the
HCS is to reduce the incidence of chemical source
illnesses and injuries. This will be accomplished by
modifying behavior through the provision of hazard
information and information about protective
measures. If your program works, you and your
workers will better understand the chemical hazards
in the workplace, and how to protect workers from
experiencing adverse effects. The procedures
you establish regarding, for example, purchasing,
storing, and handling of these chemicals will
improve, and thereby reduce the risks posed to
workers exposed to the chemical hazards involved.

Furthermore, your workers’ comprehension will
also be increased, and proper work practices will be
more likely followed in your workplace.

If you are going to do the training yourself, you
will have to understand the material and be
prepared to motivate the workers to learn. This is
not always an easy task, but the benefits are worth
the effort. More information regarding appropriate
training can be found in Appendix B of this guide,
which provides steps to follow in setting up and
conducting training.

In reviewing your hazard communication program
with regard to information and training, the
following items need to be considered:

1. Designation of person(s) responsible for
conducting training;

2. Format of the program to be used
(audiovisuals, classroom instruction, etc.);

3. Elements of the information and training
program (should be consistent with the
elements in paragraph (h) of the standard); and,

4. Procedure to train new workers at the time
of their initial assignment to work with a
hazardous chemical, and to train workers
when a new chemical hazard is introduced
into the workplace.

The written program should provide enough
details about the employer’s plans in this
area to assess whether or not a good faith
effort is being made to train workers. When
assessing an employer’s compliance with hazard
communication training requirements, OSHA
CSHOs will talk to workers to determine if they
have received training, if they know they are
exposed to hazardous chemicals, and if they know
where to obtain substance-specific information
on labels and SDSs. It should be noted that if
workers do not speak English, the employer must
convey the hazard communication information
in the language they understand—just like other
job requirements and instructions are provided.
OSHA has bilingual CSHOs, and they will be
speaking to workers who speak another language
to determine compliance.

https://www.osha.gov/dep/standards-policy-statement-memo-04-28-10.html

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 2 7

The standard does not require employers to
maintain records of employee training, but many
employers choose to do so. This may help you
monitor your own program to ensure that all
workers are appropriately trained. Keeping records
that document who was trained, when the training
was conducted, and what was covered is also
helpful to document compliance with OSHA’s
training requirement in case of an inspection. The
standard does not require retraining on a regular
schedule, it simply requires retraining if there is
a new chemical hazard introduced into the work
area. If your initial training program includes all
potential hazards covered by HazCom 2012, there
is no retraining required. However, it is good
business practice to repeat and reinforce what is
learned in training to make sure that workers retain
the hazard information.

If you already have a hazard communication
training program, you may simply have to update
it to comply with HazCom 2012. In particular, by
December 1, 2013, you will need to train your
employees about the new label and SDS formats
they will be seeing in their work areas. Additional
hazard training is not required if you have already
trained under the existing hazard communication
requirements. However, after you receive all of
the new labels and SDSs, and have updated your
hazard communication program, you may find that

there is a type of hazard on which employees have
not yet received training. You will need to train
employees on these new hazards at the time you
become aware of the new hazard. If you become
aware of new hazards after December 1, 2015, you
will have until June 1, 2016 to ensure those hazards
are included in the hazard communication program,
the workplace labeling reflects these new hazards,
and employees are trained on these new hazards.

An employer can provide employees information
and training through whatever means are found
appropriate. Although there will always have to be
some training onsite (such as informing workers of
the location and availability of the written program
and SDSs), employee training may be satisfied in
part by general training about the requirements
of the HCS and about chemical hazards on the
job which is provided by, for example, trade
associations, unions, colleges, and professional
schools. In addition, previous training, education
and experience of a worker may relieve the
employer of some of the burdens of informing and
training that worker. Regardless of the method
relied upon, however, the employer is always
ultimately responsible for ensuring that workers
are adequately trained. If the CSHO finds that the
training is deficient, the employer will be cited for
the deficiency regardless of who actually provided
the training on behalf of the employer.

Occupational Safety and Health Administration2 8

6. Evaluate and
Reassess Your
Program
• Review your hazard communication program periodically to
make sure that it is still working and meeting its objectives.

• Revise your program as appropriate to address changed
conditions in the workplace (e.g., new chemicals, new
hazards, etc.).

Because your hazard communication program
must remain up to date, it will be necessary to
periodically evaluate and reassess your program.

The information in your written program must be
accurate. The list of hazardous chemicals required
to be maintained as part of the written program
will serve as an inventory. As new chemicals are
purchased, the list must be updated. Revisions to
the inventory of chemicals should be made when
you eliminate chemicals in the workplace, or when
you bring in a new chemical. The inventory also
can be used to ensure that you have SDSs for all
chemicals in the workplace, and such revisions
are key to ensuring that is achieved. In addition,
designation of people to handle different parts of
the program should also be current and accurate.
Many companies have found it convenient to
include on their purchase orders the name and
address of the person designated in their company
to receive SDSs to help maintain a complete set.

Program coordinators should routinely walk around
the workplace to check that containers are labeled as
required and that workers are following established
work practices to protect themselves from chemical
exposure. Proactive monitoring of the workplace is
critical to ensuring compliance with the HCS.

As new SDSs are received, there should be a
process in place to review them and determine
whether any handling procedures need to change
to protect against the hazards of these chemicals.
Using information on the SDS effectively will make
safer workplace conditions a standard business
practice in your facility.

This simple checklist will help to ensure that you
are in compliance with the standard:

Obtained/accessed a copy of the standard.

____

Read and understood the requirements. ____
Assigned responsibility for tasks. ____
Prepared an inventory of chemicals. ____
Ensured that containers are labeled. ____
Obtained SDSs for each chemical. ____
Prepared written program. ____
Made SDSs available to workers. ____
Conducted training for workers. ____
Established procedures to maintain
current program.

____

Established procedures to evaluate
program effectiveness, including
maintenance of SDSs.

____

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 2 9

III. CONCLUSION

OSHA believes that the Hazard Communication
Standard is of critical importance to ensuring that
hazardous chemicals are identified, and that proper
measures are implemented in workplaces to
achieve safe use and handling. By understanding
the hazards of the chemicals, and using available
information to pick the proper control measures

to address these hazards, employers can achieve
many benefits for themselves, as well as for their
exposed workers. HazCom 2012 provides the
framework for building a chemical safety and
health management program in a workplace.
Figure 6 illustrates the steps that have been
discussed to ensure that a workplace hazard
communication program is effective.

Figure 6: An Effective Hazard Communication Program

Effec�ve

Hazard
Communica�on

Program

Read and Understand
the Standard; Assign
Responsibili�es for

Tasks

Prepare and
Implement a Wri�en

Hazard
Communica�on

Program with
Chemical List

Ensure All Containers
are Labeled

Maintain Safety Data
Sheets for All

Hazardous Chemicals
and Make Accessible

to Employees

Inform and Train
Employees About the

HCS, Workplace
Hazards, and

Protec�ve Measures

Establish Procedures
to Update When

Necessary; Evaluate
Effec�veness; Use

Informa�on to Select
and Maintain Needed
Protec�ve Measures

Occupational Safety and Health Administration3 0

APPENDIX A:
SAMPLE WRITTEN HAZARD
COMMUNICATION PROGRAM

The following sample hazard communication
program is based on the requirements of the
Hazard Communication Standard (HazCom 2012),
29 CFR 1910.1200. The intent of this sample is to
provide an easy-to-use format that can be modified
to address the specific situation in your workplace.
You are free to use whatever format you choose to
develop your program—there is no requirement to
follow this example. However, if you use this or any
other sample program, you must customize it to
your specific workplace, otherwise you will not be
in compliance with the HCS.

HAZARD COMMUNICATION PROGRAM

1. Company Policy

To ensure that information about the dangers of all
hazardous chemicals used by (Name of Company)
is known by all affected workers, the following
hazard communication program has been
implemented. Under this program, workers will be
informed of the requirements of the OSHA Hazard
Communication Standard, the operations where
exposure to hazardous chemicals may occur, and
how workers can access this program, as well as
labels and SDSs.

This program applies to any chemical which is
known to be present in the workplace in such
a manner that workers may be exposed under
normal conditions of use or in a foreseeable
emergency. All work areas that involve potential
exposure to chemicals are part of the hazard
communication program. Copies of the hazard
communication program are available in the
(location) for review by any interested worker.

(Name of responsible person and/or position) is the
program coordinator, with overall responsibility for
the program, including reviewing and updating this
plan as necessary.

2. Container Labeling

(Name of responsible person and/or position) will
verify that all containers received for use will be
clearly labeled in accord with the requirements
of HazCom 2012, including a product identifier,
pictogram, hazard statement, signal word, and
precautionary statements, as well as the supplier’s
contact information (name and address).

The (name of responsible person and/or position)
in each work area will ensure that all secondary
containers are labeled with the original supplier’s
label or with an alternative workplace label. For
help with labeling, see (name of responsible
person and/or position).

On the following individual stationary process
containers, we are using (description of labeling
system used) rather than a label to convey the
required information:

(List containers here)

We are using an in-house labeling system
(describe any in-house system which conveys
required workplace label information).

The (name of responsible person and/or position)
will review the company labeling procedures every
(provide a time period) and will update labels as
required.

3. Safety Data Sheets (SDSs)

The (name of responsible person and/or position)
is responsible for establishing and monitoring the
company SDS program. The procedure below will
be followed when an SDS is not received at the
time of initial shipment:

(Describe procedure to be followed here)

Copies of SDSs for all hazardous chemicals to
which workers are exposed or are potentially
exposed will be kept in (identify location). Workers
can access SDSs by (insert procedure for access).

Note: If alternatives to paper copies of SDSs are
used, describe the format used and how workers
can access the SDSs.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 1

SDSs will be readily available to all workers in each
work area during each work shift. If an SDS is not
available, contact (name of responsible person and/
or position).

When revised SDSs are received, the following
procedures will be followed to replace old SDSs:

(Describe procedures)

The (name of responsible person and/or position)
is responsible for reviewing the SDSs received for
safety and health implications, and initiating any
needed changes in workplace practices.

4. Employee Information and Training

(Name of responsible person and/or position) is
responsible for employee information and training.

Every worker who will be potentially exposed to
hazardous chemicals will receive initial training
on the Hazard Communication standard and this
program before starting work.

The training program for new workers is as follows
(describe how the training will be presented, and
what it will include).

Prior to introducing a new chemical hazard into
any work area, each worker in that work area will
be given information and training as outlined
above for the new chemical hazard. The training
format will be as follows:

(Describe training format, such as audiovisuals,
interactive computer programs, classroom
instruction, etc.)

5. Hazards of Non-routine Tasks

Periodically, workers are required to perform
non-routine tasks that are hazardous. Examples
of non-routine tasks are: confined space entry,
tank cleaning, and painting reactor vessels. Prior
to starting work on such projects, each affected
worker will be given information by (Name of
responsible person and/or position) about the
hazardous chemicals he or she may encounter
during such activity. This information will include
specific chemical hazards, protective and safety
measures the worker should use, and steps

the company is taking to reduce the hazards,
including ventilation, respirators, the presence of
another worker (buddy systems), and emergency
procedures.

6. Informing Other Employers/Contractors

It is the responsibility of (Name of responsible
person and/or position) to provide other employers
and contractors with information about hazardous
chemicals that their workers may be exposed
to on this work site, and suggested precautions
for workers. It is the responsibility of (Name of
responsible person and/or position) to obtain
information about hazardous chemicals used by
other employers to which our workers may be
exposed.

Other employers and contractors will be provided
with SDSs for hazardous chemicals generated by
this company’s operations in the following manner:

(Describe company policy here)

In addition to providing a copy of an SDS to other
employers, other employers will be informed of
necessary precautionary measures to protect
workers exposed to operations performed by this
company.

Also, other employers will be informed of the hazard
labels used by the company. If alternative workplace
labeling systems are used, the other employers will
be provided with information to understand the
labels used for hazardous chemicals to which their
workers may have exposure.

7. List of Hazardous Chemicals

A list of all known hazardous chemicals in the
workplace is attached to this program. This list
includes the name of each chemical, and the
work area(s) in which each of the chemicals is
used. Further information on each chemical may
be obtained from the SDSs, located in (identify
location).

When new chemicals are received, this list is
updated within (x) days of introduction into the
workplace. To ensure that any new chemical
is added in a timely manner, the following
procedures shall be followed:

Occupational Safety and Health Administration3 2

(Identify procedures to be followed)

The hazardous chemical inventory is compiled and
maintained by (Name of responsible person and/
or position and telephone number).

8. Chemicals in Unlabeled Pipes

Work activities may be performed by workers in
areas where chemicals are transferred through
unlabeled pipes. Prior to starting work in these

areas, the worker shall be informed by (Name
of responsible person and/or position) about
the identity and hazards of the chemicals in the
pipe, as well as required precautionary measures
required to be followed.

9. Program Availability

A copy of this program will be made available,
upon request, to workers, their designated
representatives, and OSHA.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 3

APPENDIX B:
QUICK GUIDE TO HAZARD
COMMUNICATION TRAINING

The Hazard Communication Standard (HCS) (29
CFR 1910.1200) requires employers that have
hazardous chemicals in their workplaces to
implement a hazard communication program.
The program includes information about labels on
containers, safety data sheets (SDSs), and training
for workers. Each employer must describe in a
written program how it will meet the requirements
of the HCS in each of these areas.

For employers that use chemicals, rather than
produce them, labels and SDSs are received
with the products they purchase. These written
documents form the basis of the hazard
communication program, providing information
for both employers and workers about the hazards
of the chemicals, as well as ways to protect people
from experiencing adverse effects as a result of
their use. Training is the last step to be undertaken
to implement an effective hazard communication
program. Through proper training, the employer
has the opportunity to ensure that workers
understand the hazards of the chemicals they work

with, as well as what steps to take to ensure that
they are protected from them. It also introduces
them to labels and SDSs, explaining how to
access these documents in their own workplace
to obtain additional information. Training is
therefore a critical part of the approach to hazard
communication, tying together the three major
components in an understandable form.

Before providing training, the employer should
have a basic understanding of the requirements
of the HCS, and have prepared its hazard
communication program. This quick guide will
focus on what is needed to set up a hazard
communication training program. It is based on
Training Requirements in OSHA Standards and
Training Guidelines (OSHA 2254) developed by
OSHA to assist employers to design any type of
occupational safety and health training program,
but relates the Guidelines specifically to hazard
communication. It is a step-by-step approach.
OSHA has also developed a series of QuickCards™
on elements of the training that employers
may find useful: www.osha.gov/dsg/hazcom/
ghsquickcards.html.

Training Step Factors to Consider

Determining
if training is
needed

Are workers potentially exposed to hazardous chemicals in your workplace? You can determine
this by reviewing the labels received on containers of chemicals you use, as well as safety data
sheets (SDSs). You must have a hazard communication program if you have workers who are
potentially exposed to hazardous chemicals. Training workers is part of the required hazard
communication program. Therefore, training is needed wherever workers are potentially
exposed to hazardous chemicals in their workplaces.

Identifying
training needs

Workers must be trained before they are initially assigned to work where they are potentially
exposed to a hazardous chemical. Therefore, if you have never provided training before, you
must train all workers who are potentially exposed. Once this initial training is completed, you
must train any new workers who are hired and will be working with hazardous chemicals. You
must also provide training whenever a new hazard is introduced, or when workers change
jobs and therefore face potential exposures. While training is not required to be repeated on
a regular basis, you may want to consider doing that to be sure that workers remember what
they have learned. It is also a good opportunity for you to review your hazard communication
program, and make sure that it is still working effectively.

http://www.osha.gov/Publications/osha2254

www.osha.gov/dsg/hazcom/ghsquickcards.html

Occupational Safety and Health Administration3 4

Training Step Factors to Consider

Identifying
goals and
objectives

Compliance with the requirements of the Hazard Communication Standard is a primary goal.
Compliance will promote a safer workplace by ensuring that the potential hazards of chemicals
are known both to you and to your workers. In addition, the measures to follow to prevent
adverse health or physical effects resulting from chemical exposures should be familiar to
everyone in the workplace. Preparing for the training gives you an opportunity to review the
hazards of the chemicals you have in the workplace, and to consider substituting less hazardous
chemicals where appropriate. It also allows you to review the protective measures you have
in place to ensure that they are working, and to consider other types of protection as well.
Implementation of a hazard communication program should be useful both to employers
that have hazardous chemicals as part of their workplace processes, and to workers who are
exposed to those chemicals. Training ties together all of the aspects of the workplace hazard
communication program to relate it to the actual workplace conditions. Thus both employers
and workers should be more familiar with the hazards present, know what steps must be taken
to control those hazards, and be assured that the workplace is safer. They should also know how
to obtain more information when needed from the container labels and the SDSs.

You may want to consider if you have any additional learning objectives you would like to
accomplish through this training program. For example, you may also have compliance
obligations for related standards that could be combined into this program and accomplished
in one training session (such as training required under the Respiratory Protection standard).
Also, it may be an opportunity to review safe work practices and ways to perform jobs in a more
efficient manner, and tie this into avoiding chemical hazards.

Identifying
learning
activities

The Hazard Communication Standard specifies what information must be provided to workers:

• The requirements of the Hazard Communication Standard;

• Any operations in their work area where hazardous chemicals are present; and

• The location and availability of the written hazard communication program, including the
required list(s) of hazardous chemicals, and SDSs required by the standard.

In addition to providing this information to workers, they must be trained on the following:

• Methods and observations that may be used to detect the presence or release of a
hazardous chemical in the work area (such as monitoring conducted by the employer,
continuous monitoring devices, visual appearance or odor of hazardous chemicals when
being released, etc.);

• The physical and health hazards of the chemicals in the work area;

• The measures workers can take to protect themselves from these hazards, including specific
procedures the employer has implemented to protect workers from exposure to hazardous
chemicals, such as appropriate work practices, emergency procedures, and personal
protective equipment to be used; and

• The details of the hazard communication program developed by the employer, including an
explanation of the labeling system and the SDS, and how workers can obtain and use the
appropriate information.

The way in which this information is conveyed is left up to the trainer to determine. You can
use any type of media available to you (such as slides, videos, computer interactive programs).
Combinations of media are often an effective way to keep the workers’ attention. In addition,
active participation is important, so you may want to include learning activities that allow the
workers to participate and have hands-on experiences. Relating the information to their specific
workplace conditions helps to ensure that you meet the requirements of the standard, as well as
improving learning and making the training more interesting.

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 5

Training Step Factors to Consider

Conducting the
training

Preparation: In order to train workers under the Hazard Communication Standard, the trainer
must be familiar with:

• the requirements of the standard that apply to the workplace;

• the hazardous chemicals in the workplace to which workers are potentially exposed, as well
as the types of hazards they pose;

• the hazard communication program implemented in the workplace; and

• the protective measures being employed in the workplace to prevent adverse effects from
occurring.

In addition to being thoroughly familiar with the material to be covered in the training, the
trainer must be aware of the facilities available for the training, including the physical location,
the type of equipment (e.g., a PowerPoint projector, computer), and plan the training session
accordingly based on the conditions.

Presenting the training: The purpose of the training is to convey information that is important
to the student, and will achieve a safer workplace. Care should be taken to ensure that the
facilities are conducive to a successful training session, and that the presentation is done in
a way that motivates learning and a positive outcome. Worker participation helps to ensure
that the learning objectives are accomplished. This can be done through hands-on examples,
discussions, and other active means of conveying the required information.

Evaluating
program
effectiveness

Consideration should be given to including some sort of evaluation tool in the training to obtain
feedback from the workers on the presentation, what formats might work better, and what they
learned. This could be in the form of a sheet to be filled out by workers after the training. In
evaluating the effectiveness of the program, you should observe how the training has changed
worker behavior. For example, if workers have better compliance with use of protective measures
(such as wearing gloves when appropriate), this could factor into the evaluation of the program.

Improving the
training

The trainers should use their own impressions as well as feedback from the students to improve
the training before it is presented again. If workers are not interested in the training as it is
conducted, do not appear motivated, and do not exhibit an increased knowledge of hazards and
the use of protective practices, it may be necessary to review and revise the training to achieve
a better outcome.

Following these seven steps should enable you
to design and implement an effective hazard
communication training program. A safer workplace

benefits the employer as well as the worker, and
their shared interest in this goal should help to
achieve effective hazard communication training.

Occupational Safety and Health Administration3 6

WORKERS’ RIGHTS

Under OSHA law, workers are entitled to working
conditions that do not pose a risk of serious harm.
To help assure a safe and healthful workplace, the
law provides workers with the right to:

■ File a confidential complaint with OSHA to have
their workplace inspected.

■ Receive information and training about
hazards, methods to prevent harm, and the
OSHA standards that apply to their workplace.
The training must be done in a language and
vocabulary workers can understand.

■ Receive copies of records of work-related injuries
and illnesses that occur in their workplace.

■ Receive copies of the results from tests and
monitoring done to find and measure hazards
in their workplace.

■ Receive copies of their workplace medical
records.

■ Participate in an OSHA inspection and speak in
private with the inspector.

■ File a complaint with OSHA if they have been
retaliated against by their employer as the
result of requesting an inspection or using any
of their other rights under the OSH Act.

■ File a complaint if punished or retaliated
against for acting as a “whistleblower” under
the 21 additional federal laws for which OSHA
has jurisdiction.

For more information, visit OSHA’s Workers’ Rights
page at www.osha.gov/workers.html.

OSHA ASSISTANCE, SERVICES AND PROGRAMS

OSHA offers free compliance assistance to
employers and workers. Several OSHA programs
and services can help employers identify and
correct job hazards, as well as improve their injury
and illness prevention program.

Establishing an Injury and Illness
Prevention Program

The key to a safe and healthful work environment
is a comprehensive injury and illness prevention
program.

Injury and illness prevention programs are
systems that can substantially reduce the number
and severity of workplace injuries and illnesses,
while reducing costs to employers. Thousands
of employers across the United States already
manage safety using illness and injury prevention
programs, and OSHA believes that all employers
can and should do the same. Thirty-four states
have requirements or voluntary guidelines for
workplace injury and illness prevention programs.

Most successful injury and illness prevention
programs are based on a common set of key
elements. These include management leadership,
worker participation, hazard identification, hazard
prevention and control, education and training,
and program evaluation and improvement. Visit
OSHA’s illness and injury prevention program web
page at www.osha.gov/dsg/topics/safetyhealth for
more information.

Compliance Assistance Specialists

OSHA has compliance assistance specialists
throughout the nation located in most OSHA
offices. Compliance assistance specialists can
provide information to employers and workers
about OSHA standards, short educational
programs on specific hazards or OSHA rights and
responsibilities, and information on additional
compliance assistance resources. For more details,
visit www.osha.gov/dcsp/compliance_assistance/
cas.html or call 1-800-321-OSHA [6742] to contact
your local OSHA office.

www.osha.gov/workers.html

www.osha.gov/dsg/topics/safetyhealth

https://www.osha.gov/dcsp/compliance_assistance/cas.html

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 7

Free On-site Safety and Health
Consultation Services for Small Business

OSHA’s On-site Consultation Program offers free
and confidential advice to small and medium-sized
businesses in all states across the country, with
priority given to high-hazard worksites. Each year,
responding to requests from small employers
looking to create or improve their safety and
health management programs, OSHA’s On-site
Consultation Program conducts over 29,000 visits
to small business worksites covering over 1.5
million workers across the nation.

On-site consultation services are separate from
enforcement and do not result in penalties or
citations. Consultants from state agencies or
universities work with employers to identify
workplace hazards, provide advice on compliance
with OSHA standards, and assist in establishing
safety and health management programs.

For more information, to find the local On-site
Consultation office in your state, or to request a
brochure on Consultation Services, visit www.osha.
gov/consultation, or call 1-800-321-OSHA [6742].

Under the consultation program, certain exemplary
employers may request participation in OSHA’s
Safety and Health Achievement Recognition
Program (SHARP). Eligibility for participation
includes, but is not limited to, receiving a full-
service, comprehensive consultation visit,
correcting all identified hazards and developing an
effective safety and health management program.
Worksites that receive SHARP recognition are
exempt from programmed inspections during the
period that the SHARP certification is valid.

Cooperative Programs

OSHA offers cooperative programs under which
businesses, labor groups and other organizations
can work cooperatively with OSHA. To find out
more about any of the following programs, visit
www.osha.gov/dcsp/compliance_assistance/
index_programs.html.

Strategic Partnerships and Alliances

The OSHA Strategic Partnerships (OSP)
provides the opportunity for OSHA to partner
with employers, workers, professional or
trade associations, labor organizations, and/or
other interested stakeholders. OSHA Strategic
Partnerships are formalized through unique
agreements designed to encourage, assist, and
recognize partner efforts to eliminate serious
hazards and achieve model workplace safety and
health practices. Through the Alliance Program,
OSHA works with groups committed to worker
safety and health to prevent workplace fatalities,
injuries and illnesses by developing compliance
assistance tools and resources to share with
workers and employers, and educate workers and
employers about their rights and responsibilities.

Voluntary Protection Programs (VPP)

The VPP recognize employers and workers
in private industry and federal agencies who
have implemented effective safety and health
management programs and maintain injury and
illness rates below the national average for their
respective industries. In VPP, management, labor,
and OSHA work cooperatively and proactively to
prevent fatalities, injuries, and illnesses through a
system focused on: hazard prevention and control,
worksite analysis, training, and management
commitment and worker involvement.

Occupational Safety and Health Training

The OSHA Training Institute in Arlington Heights,
Illinois, provides basic and advanced training
and education in safety and health for federal
and state compliance officers, state consultants,
other federal agency personnel and private sector
employers, workers, and their representatives.
In addition, 27 OSHA Training Institute Education
Centers at 42 locations throughout the United
States deliver courses on OSHA standards and
occupational safety and health issues to thousands
of students a year.

For more information on training, contact the
OSHA Directorate of Training and Education, 2020
Arlington Heights Road, Arlington Heights, IL
60005; call 1-847-297-4810; or visit www.osha.gov.

www.osha.gov/consultation

www.osha.gov/dcsp/compliance_assistance/index_programs.html

http://www.osha.gov

Occupational Safety and Health Administration3 8

OSHA Educational Materials

OSHA has many types of educational materials in
English, Spanish, Vietnamese and other languages
available in print or online. These include:

■ Brochures/booklets that cover a wide variety of
job hazards and other topics;

■ Fact Sheets, which contain basic background
information on safety and health hazards;

■ Guidance documents that provide detailed
examinations of specific safety and health issues;

■ Online Safety and Health Topics pages;

■ Posters;

■ Small, laminated QuickCards™ that provide
brief safety and health information; and

■ QuickTakes, OSHA’s free, twice-monthly online
newsletter with the latest news about OSHA
initiatives and products to assist employers
and workers in finding and preventing
workplace hazards. To sign up for QuickTakes
visit OSHA’s web site at www.osha.gov and
click on QuickTakes at the top of the page.

To view materials available online or for a listing
of free publications, visit OSHA’s web site at www.
osha.gov. You can also call 1-800-321-OSHA [6742]
to order publications.

OSHA’s web site also has a variety of eTools.
These include utilities such as expert advisors,

electronic compliance assistance, videos and other
information for employers and workers. To learn
more about OSHA’s safety and health tools online,
visit www.osha.gov.

NIOSH HEALTH HAZARD
EVALUATION PROGRAM

Getting Help with Health Hazards

The National Institute for Occupational Safety and
Health (NIOSH) is a federal agency that conducts
scientific and medical research on workers’ safety
and health. At no cost to employers or workers,
NIOSH can help identify health hazards and
recommend ways to reduce or eliminate those
hazards in the workplace through its Health Hazard
Evaluation (HHE) Program.

Workers, union representatives and employers can
request a NIOSH HHE. An HHE is often requested
when there is a higher than expected rate of a
disease or injury in a group of workers. These
situations may be the result of an unknown cause,
a new hazard, or a mixture of sources. To request
a NIOSH Health Hazard Evaluation go to www.
cdc.gov/niosh/hhe/request.html. To find out more
about the Health Hazard Evaluation Program:

■ Call (513) 841-4382, or to talk to a staff member
in Spanish, call (513) 841-4439; or

■ Send an email to HHERequestHelp@cdc.gov.

http://www.osha.gov

www.cdc.gov/niosh/hhe/request.html

mailto:HHERequestHelp@cdc.gov

Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 9

OSHA REGIONAL OFFICES

Region I
Boston Regional Office
(CT*, ME, MA, NH, RI, VT*)
JFK Federal Building, Room E340
Boston, MA 02203
(617) 565-9860 (617) 565-9827 Fax

Region II
New York Regional Office
(NJ*, NY*, PR*, VI*)
201 Varick Street, Room 670
New York, NY 10014
(212) 337-2378 (212) 337-2371 Fax

Region III
Philadelphia Regional Office
(DE, DC, MD*, PA, VA*, WV)
The Curtis Center
170 S. Independence Mall West
Suite 740 West
Philadelphia, PA 19106-3309
(215) 861-4900 (215) 861-4904 Fax

Region IV
Atlanta Regional Office
(AL, FL, GA, KY*, MS, NC*, SC*, TN*)
61 Forsyth Street, SW, Room 6T50
Atlanta, GA 30303
(678) 237-0400 (678) 237-0447 Fax

Region V
Chicago Regional Office
(IL*, IN*, MI*, MN*, OH, WI)
230 South Dearborn Street
Room 3244
Chicago, IL 60604
(312) 353-2220 (312) 353-7774 Fax

Region VI
Dallas Regional Office
(AR, LA, NM*, OK, TX)
525 Griffin Street, Room 602
Dallas, TX 75202
(972) 850-4145 (972) 850-4149 Fax
(972) 850-4150 FSO Fax

Region VII
Kansas City Regional Office
(IA*, KS, MO, NE)
Two Pershing Square Building
2300 Main Street, Suite 1010
Kansas City, MO 64108-2416
(816) 283-8745 (816) 283-0547 Fax

Region VIII
Denver Regional Office
(CO, MT, ND, SD, UT*, WY*)
Cesar Chavez Memorial Building
1244 Speer Boulevard, Suite 551
Denver, CO 80204
(720) 264-6550 (720) 264-6585 Fax

Region IX
San Francisco Regional Office
(AZ*, CA*, HI*, NV*, and American Samoa,
Guam and the Northern Mariana Islands)
90 7th Street, Suite 18100
San Francisco, CA 94103
(415) 625-2547 (415) 625-2534 Fax

Region X
Seattle Regional Office
(AK*, ID, OR*, WA*)
300 Fifth Avenue, Suite 1280
Seattle, WA 98104
(206) 757-6700 (206) 757-6705 Fax

* These states and territories operate their own
OSHA-approved job safety and health plans and
cover state and local government employees as
well as private sector employees. The Connecticut,
Illinois, New Jersey, New York and Virgin Islands
programs cover public employees only. (Private
sector workers in these states are covered by
Federal OSHA). States with approved programs
must have standards that are identical to, or at
least as effective as, the Federal OSHA standards.

Note: To get contact information for OSHA area
offices, OSHA-approved state plans and OSHA
consultation projects, please visit us online at
www.osha.gov or call us at 1-800-321-OSHA (6742).

www.osha.gov

Occupational Safety and Health Administration4 0

HOW TO CONTACT OSHA

For questions or to get information or advice,
to report an emergency, report a fatality or
catastrophe, order publications, sign up for
OSHA’s e-newsletter QuickTakes, or to file a
confidential complaint, contact your nearest

OSHA office, visit www.osha.gov or call OSHA
at 1-800-321-OSHA (6742), TTY 1-877-889-5627.

For assistance, contact us.
We are OSHA. We can help.

www.osha.gov

Occupational Safety and Health Administration4 2

The hazardous chemical inventory is compiled and maintained by (Name of responsible person and/or
position and telephone number).

8. Chemicals in Unlabeled Pipes

Work activities may be performed by workers in areas where chemicals are transferred through
unlabeled pipes. Prior to starting work in these areas, the worker shall be informed by (Name of
responsible person and/or position) about the identity and hazards of the chemicals in the pipe, as well
as required precautionary measures required to be followed.

9. Program Availability

A copy of this program will be made available, upon request, to workers, their designated
representatives, and OSHA.

For more information:

Occupational
Safety and Health
Administration

www.osha.gov (800) 321-OSHA (6742)

U.S. Department of Labor

www.osha.gov

I. Introduction
II. �Steps to an Effective Hazard Communication Program

1. �Learn the
Standard/Identify Responsible Staff
2. �Prepare and Implement a Written Hazard Communication Program
3. �Ensure Containers are Labeled
4. �Maintain Safety Data Sheets
5. �Inform and Train Employees
6. �Evaluate and Reassess Your Program
III. Conclusion

Appendix A:
Sample Written Hazard Communication Program
Appendix B:
Quick Guide to Hazard Communication Training

Workers’ Rights
OSHA Assistance, Services and Programs
NIOSH Health Hazard Evaluation Program
OSHA Regional Offices
How to Contact OSHA

Silent Killer in a Newly Constructed Manhole

Reason For the Intervention
OSHA received notification of a construction site fatality on August 5, 2004 – day following the incident

Reported that the employee was found at the bottom of a manhole

New sewer system under construction – SIC Code 1623

*
The inspection was initiated after our office received notification of a construction site fatality from the employer on August 5, 2004, which was a day after the incident.
The report was that the employee was found at the bottom of a newly constructed manhole.
The employer was a small construction company with a total of 20 employees. The company installs water and sewer lines, with a SIC Code of 1623.

The Site
Company laying sewer pipe & manholes for a new housing development
6 employees onsite
Farm land; slightly hilly; slope of ground ~ 1 to 4
Manhole was adjacent to an entrance ramp to a highway

*
The employer was laying sewer pipe and manholes for a new housing development.
There were 6 employees on site the day of the incident – five of the employees were laying pipe over the hill from the manhole that was involved in the incident. One employee (the victim) was grouting the manhole.
This photo shows the manhole from top of the hill looking down.
The area was previously farm land, it was slightly hilly, and the manhole was placed in the terrain with a slope of 1 to 4.
The manhole was adjacent to entrance ramps to a highway.

2 foot opening
4 foot wide internal diameter
Riser was constructed of 4’ X 4’ concrete pipe sections
17 feet deep outside 161/2 feet inside
Two 8” PVC Pipes in the bottom
Built on a 4” to 12” bed of limestone chat

*
This slide gives a break down of the sections of the manhole.
There were 4 sections with a total height of approximately 17 feet when measured on the outside (per drawings), and the inside measurement was 16 ½ feet (when measured with a trench pole). All of the sections were made of concrete and were coated with a water proofing substance. Ladder rungs were present in the interior surface.
There was a 2 foot opening at the top, and 4 foot wide internal diameter.
The manhole was set in a bed of gravel any where from 4 to 12 inches.
Two eight inch plastic sewer pipe enters and exits the manhole near the bottom.
At the time of the incident and the inspection activity, the inlets were plugged.

Code Requirements
City codes require a vacuum test – must maintain 10 inches of mercury for a specific time based on depth of manhole

If vacuum test fails, then sections of the manhole must be grouted to get a better seal

*
As stated earlier, there were 6 employees on site the day of the accident. 5 of the employees were working over the hill laying sewer pipe. The victim was assigned the job of grouting.
Each manhole, per city codes, must pass a leak test, which is accomplished by pulling a vacuum and the manhole must hold a vacuum of 10 inches of mercury for a set time based on the depth of the manhole.
This slide shows the vacuum test equipment. The upper photo shows the apparatus which seals the top of the manhole and the vacuum pump. The lower photo shows the plug inserts which are placed in the sewer pipe entering the bottom of the manhole and completes the sealed space.
If this test fails, as in this case, someone has to grout the seams of the manhole sections.

The Incident
After vacuum test failure, employee reportedly was assigned the grouting task

Grouting is done by hand and takes about 1 hour
The employee was working alone
The employee was found at the bottom of the manhole unconscious

*
After vacuum test failure, the employee reportedly was assigned the grouting task.
Grouting is often done by hand inside the manhole and it was reported that it takes about 1 hour to complete.
In this case, the employee was working alone in the manhole; and there was conflicting information as to when the last vacuum test was performed.
The employee was found unconscious at the bottom of the manhole.
The photo shows what OSHA found during the OSHA investigation—grout bucket and the orange hose connected to the plug inserts at the bottom of the manhole.
The plug inserts were still under pressure.

Inspection Activity
Picture goes here
Manhole Conditions
After recovery, the medical examiner requested sampling of manhole
Fire Department – Haz Mat Division took some multi-gas readings about 3 hours after recovery
Results were 16.3 to 17% for oxygen and 0.0 to 4.5 % LEL
Zero readings for carbon monoxide and hydrogen sulfide
No readings taken for carbon dioxide

*
After recovery, the medical examiner requested air sampling of the manhole.
The Kansas City, Missouri Fire Department-Hazardous Materials (Haz Mat) Division arrived on site about 3 hours after recovery to perform the air sampling with direct read multi-gas instruments.
Results were recorded with two direct read instruments.
The oxygen levels were reported at 16.3 and 17%.
And LEL levels at 0.0 and 4.5% and Chlorine levels at 4 PPM.
There were no detections for carbon monoxide or hydrogen sulfide.
No readings were taken for carbon dioxide.

Inspection Activity

The employer did not have a confined space entry program
OSHA’s Salt Lake City Technical Center Health Response Team
assisted with site analysis
Direct Reading Instruments results 9 days later revealed:
Oxygen – 16.0 to 18.2 %
CO2 – 1.8 to 3.5 % or
18,000 to 35,000 PPM
LEL – 5 to 8 %

*
During the inspection, it was reported that the employer did not have a confined space entry program and no equipment available.
Our office requested the assistance from OSHA’s Salt Lake City Technical Centers Health Response Team who had assisted similar cases. They arrived on the site about 9 days after the accident. The manhole had not been disturbed other than the placement of the manhole lid. The plug inserts were still in place and were under pressure.
Air sampling was accomplished through direct read instruments including one for carbon dioxide levels and a multi-gas instrument for oxygen and LEL.
The levels obtained that day revealed 16.0 to 18.2 % oxygen; 1.8 to 3.5 % or 18,000 to 35,000 PPM for carbon dioxide; and 5 to 8 % LEL.

Inspection Activities (cont.)
Grab or bulk air samples taken with a medium flow pump at 3 L/Min.

Collected in aluminum bags
Lab results as follows:
Oxygen – 12.5 to 14.1 %

CO2 – 16,845 to 23,968 PPM

Methane – 776 to 1372 PPM

*
In addition, the Health response Team collected grab or bulk air samples which were sent to the lab for analyses.
The samples were collected in aluminum bags with a medium flow sampling pump, as seen in this photo, and set at 3 liters per minute.
There were four samples collected from the bottom of the manhole and one control sample which was taken outside of the manhole.
The results produced the ranges of 12.5 to 14.1 % oxygen; and roughly 17,000 to 24,000 PPM (16,845 to 23,968 PPM) Carbon Dioxide; and 776 to 1372 PPM Methane.
The control sample revealed 19.8 % oxygen and 349 PPM for Carbon Dioxide.
These results were comparable to the direct readings that were obtained by the fire department.
Another interesting note, was that during this sampling the owner of the company was on site and had borrowed a multi-gas instrument and was inserting the instrument into the manhole along side of OSHA’s equipment. The alarm would go off when the oxygen level was below the set level of that instrument which is usually at 19.5% or slightly higher.

Carbon Dioxide
Colorless odorless gas
Displaces oxygen leading to oxygen deficiency
Special problem in Midwest area
Limestone Rock
Calcium Carbonate
Acidic topsoil
Acid leaches from soil, which then contacts the limestone producing Carbon Dioxide
Numerous fatalities
Especially in new sewer/vault leak testing using a vacuum
Pulls carbon dioxide into the space
Oxygen measured at less than 3% on other similar fatalities
5 similar cases known Nation-wide since 2000; 2 cases with 4 fatalities in the Kansas City area

*
In theory, what happens in these newly constructed manholes is the displacement of oxygen with other substances including carbon dioxide.
Carbon dioxide is a colorless and odorless gas and it is heavier than air.
In the midwest area, we have limestone rock and/or the manholes are constructed with a bed of limestone rock/gravel and there is acidic soil. It is believed that the acid leachs from the soil and combines with the limestone rock producing carbon dioxide.
There were 5 known cases involving fatalities in newly constructed manholes nation-wide since the year 2000, with 4 fatalities in the Kansas City Area. In most of these cases, the manholes were not connected to the active sewer (as in this case) and the vacuum test for leaks had been performed prior to the entry. It is believed that carbon dioxide is pulled into the manhole displacing the oxygen during these leak tests. The oxygen content in these manholes has been found to be as low as 3%. In most of the cases, it was reported that the employers have been entering the manholes for years without any problems; and manholes in the same areas had normal levels of oxygen and carbon dioxide.

Oxygen Deficient Atmospheres
19.5 % Minimum acceptable oxygen level.
15 – 19% Decreased ability to work strenuously. Impair coordination. Early symptoms.
12-14% Respiration increases. Poor judgment.
10-12% Respiration labored. Lips blue.
8-10% Mental failure. Fainting, Nausea, Unconsciousness, Vomiting.
6-8% 4-5 minutes – possible recovery, 6 minutes – 50% fatal, & 8 minutes – fatal.
4-6% Coma almost instantaneously. Death

*
19.5% oxygen is the minimal acceptable oxygen level per definitions used by OSHA, such as that used in the permit-required confined space standard in general industy.
As the oxygen levels decrease and depending on the work activity and the individual consumption, it becomes more difficult to support body functions.

Unit Assessment Questions

QUESTION 1

Explain the difference in fall protection requirements for connectors working in steel erection between 15 feet and 30 feet in height and connectors working more than two stories or 30 feet in height.
Your response should be at least 75 words in length.

QUESTION 2

Discuss some ways that employee exposure to overhead loads during steel erection can be reduced. When is working under a load permitted?
Your response should be at least 75 words in length.

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Construction Safety

QUESTION 2

How do the primary requirements of the hazard communication standard (written program, safety data sheets, labeling of hazardous substances, and training) work together to keep workers informed of chemical hazards they encounter at work? Your response should be at least 200 words in length.

QUESTION 2

Discuss some ways that employee exposure to overhead loads during steel erection can be reduced. When is working under a load permitted? Your response should be at least 75 words in length.

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Term Paper

Research Paper

Book Review

Assignment

Report

Case Study

Letter

Article

Coursework

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Q & A

Critical Thinking

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How do the primary requirements of the hazard communication standard (written program, safety data sheets, labeling of hazardous substances, and training) work together to keep workers informed of chemical hazards they encounter at work?
Your response should be at least 200 words in length.

Discuss some ways that employee exposure to overhead loads during steel erection can be reduced. When is working under a load permitted?
Your response should be at least 75 words in length.