Compliance Guideline for the OSHA Hazard Communication Standard
(29 CFR 1910.1200)
This is the most frequently cited OSHA standard. The purpose of the regulation is to ensure that
employees who are, or may be exposed to hazardous substances understand the physical and
health hazards associated with these substances so that appropriate steps may be taken to protect
themselves.
Unlike other chemical regulations, there is no minimum quantity exemption for this regulation.
Even a small bottle of a "hazardous substance" on an employee's desk is sufficient to require an
employer to develop a hazard communication standard program.
The standard can be divided into five elements. You must comply with all of the elements to
avoid citations. The elements are:
1. Develop a written program which documents the steps for compliance.
2. Prepare a list of all hazardous substances used in the workplace. Keep this list up-to-date.
3. Compile Material Safety Data Sheets on the hazardous substances used in the workplace and
make them available to all employees.
4. Ensure that all hazardous substance containers are properly labeled.
5. Conduct training classes for all affected employees.
Many sheet metal contractors handle substances that contain a mixture of chemicals, for example,
cleaners, adhesives, etc. According to this OSHA standard, if the mixture contains 1% or more of
a listed "hazardous substance," the mixture itself is considered a hazardous substance. If the
mixture includes 0.1% or more of a cancer causing agent, the mixture would be considered a
hazardous substance. If you are not sure whether the product is a hazardous substance, it is
suggested that you assume that it is unless you are notified otherwise by the manufacturer or
supplier.
You should perform the following actions to comply with the OSHA standard.
1. Prepare a written Hazard Communication compliance program. The written program should
be concise, accurate, and contain the following information:
a. an explanation of how you will meet the requirements of labeling,
b. collecting and maintaining Material Safety Data Sheets, and
c. providing employee training and information.
2. Conduct an inventory to determine whether you have any hazardous substances at your shop
or on your worksites. The list should include the product name, manufacturer name and the
address and location where the product is being used in your facility.
3. Review the Company's Material Safety Data Sheets. If, based upon the results of the
hazardous substance inventory, there are missing Material Safety Data Sheets; send a written
request for a copy of the document to the manufacturer, importer or distributor of the product.
Keep a copy of the request letter.
4. Ensure all products are properly labeled. Generally, the manufacturer or distributor assumes
this responsibility. However, it is your responsibility to ensure completeness of the label. If
you are buying products in bulk and transfer product in smaller containers, it is your
responsibility to label these secondary containers.
5. Conduct Employee training. You should conduct training sessions with all affected employees
to explain:
a. the elements of the regulation,
b. how chemicals affect the body,
c. how to read a Material Safety Data Sheet and label, and
d. what steps to take for additional information.
Training should always be well-documented. At a minimum, have a sign-in sheet and an
outline of the topics covered. Be sure to give employees an opportunity to ask questions
during the training.
EXHIBIT B - HAZCOM CHEMICAL INVENTORY LIST
For
SMACNA MEMBER COMPANY NAME
METALS:
WELDING ROD:
GASES:
Prepainted Galvanized Steel
ER 316LP Welding Rod
100% Nitrogen
Galvanized Iron
Steel ER70S-6 Wire
95% Argon, 5% Oxygen
Aluminum
Aluminum ER4043
100% Oxygen
Galvanized Electrolitic
E 8018W2 Welding Rod
100% Argon
Type 316, 304 Stainless Steel
Stainless Steel ER316L Wire
100% Acetylene
Mild Steel (Hot/Cold Rolled)
Aluminum ER5356
75% Argon, 25% Carbon Dioxid
Copper
E-7018 Welding Rod
35% Hydrogen, 65% Nitrogen
Lead
E-6011 Welding Rod
100% Carbon Dioxide
Silicon Bronze A5.7/ER Cusi-A
98% Argon, 2% Oxygen
ACIDS:
Flux Cored Steel E71T-GS Mig Wire
E 100 All Sol Flux
50/50 Tin Lead Solder Alloy
90% Helium, 7.5% Argon, 2.5%
Carbon Dioxide
Propane
La-Co Regular Flux Paint
Sal Ammoniac
CHEMICALS:
SEALERS & GLUES
Solder Paste
Delo 400 30W Motor Oil
999A Silicone Glazing Compound
Muratic Acid
AW ISO 150 Machine Oil
Vulcum 921
Metal Etch
Kerosene
Putty Hardener 0200
Surfuric Acid
Isopropyl Alcohol
Sikaflex
Automatic Transmission Oil
795 Plastic Adhesive
PLASTICS:
Lubricating Oil
Foster Fos-Stik 85-45
Polyproplyne
Gasoline
Ductmate 795 Caulking
Plexiglass
Acetone
Vulkem 116
Visqueen
Aluminum Putty
Aluminum Gutterseal
Polyvinyl Chloride (PVC)
Goof-Off Remover
United Duct Sealer 3174
Anti-Seize Compound
Bitumastic 300M A&B
PAINTS:
Petrofer Spiral Pipe Mach. Oil
Spray Adhesive
Spray Paint
Penetrant/Lubricant
Glas Grip 925/901/658
Spray Primer
Diesel
7000 Neoprene
Mineral Thinner
Loctite
EPDM Adhesive
Metal Primer
CRC 3-36
Lacquer Thinner
Tap Magic Cutting Fluid
Synthetic Reducer
CRC Zinc Re Nu
Carboline 134 Part A & B
795 Building Sealant
Rain Patch Roofing Cement
FIBERGLASS:
United Duct Sealer 3438
Ductboard
Waterproofing Membrane
Rock Wool
732 Multi Purpose Sealant
Sound Attenuation
Richard’s APEX