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|Title: 03/17/1989 - Revised Hazard Communication Standard (HCS) Instruction, CPL 2-2. 38B CH-1|
|Record Type: Interpretation||Standard Number: 1910.1200|
March 17, 1989
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THROUGH: LEO CAREY, DIRECTOR, OFFICE OF FIELD PROGRAMS
FROM: THOMAS J. SHEPICH, DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAMS
On August 24, 1987, a final rule covering all employers was published in the Federal Register. Due to subsequent court and administrative actions, for a number of months OSHA was prevented from enforcing the rule in the construction industry, and enforcing in any industry certain requirements dealing with the maintenance of material safety data sheets on multi-employer worksites, coverage of consumer products, and the coverage of drugs in the non-manufacturing sector. As a result of further court actions, all provisions of the rule are now in effect in all segments of industry. OSHA, however, extended the compliance date until March 17, 1989, for programmed inspections in the construction industry and the three previously disapproved provisions.|
The result of the court actions necessitate revisions to the HCS directive. Attached for your review is a draft copy of our proposed changes. Please review and notify us by April 3, of any comments you may have.
Teach your employees about MSDS's with posters and pamphlets from Safety Emporium.
In the construction industry, it would probably be most efficient for the general contractor to coordinate the requirement for maintaining MSDS on site. For example, the general contractor could keep and make available MSDS in the office on the site.
An employer must provide other employer(s) MSDS if the other employer(s) will have employees exposed to potentially exposed. For example, if a painting contractor's workers are using flammable solvents in an area where another subcontractor's workers are welding pipes, then the painting contractor must ensure that the MSDS are available. However, if electricians are not working near or at the same time as, the paving contractor, and therefore it is not possible for either employer's employees to be exposed, then no exchange of MSDS is required.
This portable job site MSDS binder is just one of many OSHA compliance items available from Safety Emporium.
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19765&p_text_version=FALSE