Hazard Communication
One Standard, Four Moving Parts
1910.1200 requires a written program, labels, safety data sheets, and training, all supported by an inventory of the hazardous chemicals present. It applies to hazardous chemicals in the workplace; among the excluded items are hazardous waste, tobacco, articles, ionizing radiation, and biological hazards.
Labels
Supplier labels carry the product identifier, a signal word (DANGER or WARNING), hazard statements, pictograms, precautionary statements, and the supplier's name, address, and phone number. Secondary containers must also be labeled - the only exception is when the material is transferred by an employee and used immediately by that same employee.
Safety Data Sheets: 16 Sections
The first eight sections do the practical work: identification, hazard identification, composition, first aid, firefighting, accidental release, handling and storage, and exposure controls/personal protection. OSHA enforces Sections 1–11 and 16; Sections 12–15 (environmental, disposal, transport, regulatory) are not enforced by OSHA. Electronic access is acceptable only if it is readily available in the work area with a backup.
Training
Training is required at initial assignment and whenever a new chemical hazard is introduced. It must cover methods to detect a release, physical and health hazards, protective measures, and how to read labels and SDSs - including for non-routine tasks.
Traps and a Rule of Thumb
Traps: 16 sections does not mean 16 enforced sections; the environment pictogram is not required by OSHA; trade secret claims never block disclosure to health professionals in an emergency; training is required even for intermittent use.
Rule of thumb: 16, 9, 2 - 16 SDS sections, 9 pictograms (8 required by OSHA), 2 signal words.