Chemical inventory list under hazard communication rules

August 5, 1994

Mr. Doc Wallace
Safety Director
Capform, Inc.
[Recipient address omitted]
Dear Mr. Wallace:

Thank you for your letter of May 10, concerning the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200, requesting clarification on the list of hazardous chemicals as required under 1910.1200(e)(1)(i), referred to in your letter as the Material Safety Data Sheets (MSDS) index sheet.

In response to your inquiry, the employer is responsible for conducting the hazardous chemical inventory and developing the list of all hazardous chemicals in the workplace by using the identity that is referenced on the MSDS and the container label. This identity is often a common name, such as a product or trade name. The HCS also requires that this list be specific to the workplace as a whole or for individual workareas. The rule does not require that you indicate the hazards of each chemical on the list; employees are informed of hazards through MSDSs, labels, and training.

In closing, please bear in mind that the HCS is a performance oriented standard. This means that the employer has the flexibility to develop a hazard communication program that best fits their workplace and also meets the performance requirements of the standard.

We hope this information is helpful. If you have any further questions please contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Ruth E. McCully, Director
Office of Health Compliance Assistance

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[Corrected 12/6/2024]