Hours for hazard communication emergency information lines

October 25, 1986

Leo J. Sioris, Pharm.D.
Assistant Managing Director
Minnesota Regional Poison Center
[Recipient address omitted]
Dear Mr. Sioris:

This is in response to your letter of June 9, 1986 concerning the availability of emergency information under the Hazard Communication Standard (HCS), reference 29 CFR 1910.1200.

Your question and our response is as follows:

Question:

Do emergency information lines have to be operated 24 hours per day, or for some other specified time period?

Answer:

The HCS is primarily written in performance language. Paragraph (g)(2)(xii) of 29 CFR 1910.1200 does not specify hours of operation for emergency information lines.

The Occupational Safety and Health Administration's policy is to resist providing specifications that would erode the intended flexibility of performance standards. The Agency therefore, only provides guidelines to assist employers in fulfilling their responsibilities under the standard.

Chemical manufacturers should consider the following criteria in deciding the hour of operation of their emergency telephone line:

1) The completeness of the material safety data sheet for products

2) The toxicity/physical hazards of chemicals

3) The frequency the chemicals will be used and the immediacy of information needs based on all the above

4) Availability of information through other sources

If for example a manufacturer feels that their material safety data sheets are comprehensive and the products present little risk then the emergency number need only be open during normal work hours.

In summary, hours of emergency line operation must be decided individually by each chemical manufacturer.

Please feel free to contact us again if further assistance is needed.

Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations

[Requester letter reproduced on OSHA page; omitted here.]