Training when new chemical hazards enter the workplace

September 7, 1993

Mr. Earle Wilson
Compliance Technologies Incorporated
[Recipient address omitted]
Dear Mr. Wilson:

This is in response to your inquiry of August 11, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.

You requested clarification of 1910.1200(h), regarding the requirement for additional employee training whenever new hazards are identified. OSHA feels that the receipt of a new MSDS or chemical compels the employer to evaluate the information provided in the MSDS to ascertain whether the new product represents a new health or physical hazard to employees. Training would have to be provided to affected employees when new hazards are introduced into the workplace (not necessarily new chemicals).

The intent of the HCS training is to provide information to employees on the hazards they encounter in the workplace. Retraining can be as simple as a weekly safety meeting that highlights new chemicals in the workplace. As long as the initial training covers categories of chemicals and hazards, and how to read and understand MSDSs, retraining would merely have to assure that new products and chemicals are identified to the employees and that the hazards, if any, are recognized.

We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

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