Hazard communication for imported workplace chemicals

February 14, 1996

Saroj
[Recipient address omitted]
Dear Sir/Madame:

This is in response to your letter of October 6, 1995, to the Occupational Safety and Health Administration requesting information about the standards and regulations applicable in the United States for the sale, import, handling, and transport of various chemicals.

The Occupational Safety and Health Administration (OSHA) is responsible specifically for regulating the workplace use of materials such as the chemicals you list, and for protecting the health and safety of workers who may be exposed to such materials. Accordingly, OSHA standards address a wide range of workplace health and safety issues, including electrical safety, fire safety, chemical exposure, emergency response, first aid, personal protective equipment, and engineering controls, such as ventilation. Each of the OSHA standards addressing these issues may, to some extent, be applicable to the manufacture, transport, storage, and handling of the chemicals you list. Of these relevant OSHA standards, however, the Hazard Communication standard (Title 29 Code of Federal Regulations (29 CFR) Part 1910.1200) perhaps most directly affects importers and manufacturers of chemicals. This standard (a copy of which is enclosed for your information) requires chemical manufacturers or importers to assess the hazards of the chemicals which they produce or import and communicate these hazards with appropriate warnings and required protective measures to employees and downstream users through material safety data sheets and product labeling.

In any case, employers or chemical manufacturers and importers are responsible for evaluating their workplace operations and determining the extent to which OSHA standards apply. To assist in this effort, a complete set of OSHA General Industry standards (29 CFR Part 1910) may be obtained by writing or calling the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402, (202) 783-3238.

It is important to note, however, that a number of other federal agencies also regulate various aspects of chemical manufacture, import, sale, transportation, and handling. For instance, the Department of Commerce, the Department of Transportation, and the Environmental Protection Agency may have specific regulations regarding the import, sale, and transport of the materials you listed. In addition, individual states may have further regulations regarding these materials. Information on such federal and state regulations must be obtained by contacting each of these agencies directly. The Chemical Manufacturers Association, a private sector trade association, may be able to assist you identifying other relevant regulatory agencies and their respective standards or requirements. The addresses for these offices are listed below:

U.S. Department of Transportation
[Hazardous Materials Transportation]
400 7th Street S.W.
Washington, D.C. 20590-0001

U.S. Department of Commerce
[International Trade Administration]
14th Street & Constitution Avenue N.W.
Washington, D.C. 20230

U.S. Environmental Protection Agency
Office of International Activities
401 M Street S.W.
Washington, D.C. 20460-0001

Chemical Manufacturers Association
2501 M Street N.W.
Washington, D.C. 20037

We hope you find this information helpful. Thank you for your interest in worker safety and health.

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

Enclosure

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