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CPL 2-2.38D - Appendix E

Sample Hazard Communication Programs (A & B)

This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.



SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM (A)

  1. Company Policy

      To ensure that information about the dangers of all hazardous chemicals used by (Name of Company) are known by all affected employees, the following hazardous information program has been established:

      All work units of this company will participate in the hazard communication program. This written program will be available in the (location) for review by any interested employee.

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  2. Container Labeling

      The (person/position) will verify that all containers received for use will be clearly labeled as to the contents, note the appropriate hazard warning and list the name and address of the manufacturer.

      The (person/position) in each section will ensure that all secondary containers are labeled with either an extra copy of the original manufacturer's label or with labels that have the identity and the appropriate hazard warning. For help with labeling, see (person/position).

      On the following individual stationary process containers, we are using (description of labeling system used) rather than a label to convey the required information.

      We are using an in-house labeling system which relies on (provide a description of any in-house system which used numbers or graphics to convey hazard information.)

      The (person/position) will review the company labeling procedures every (provide a time period) and will update labels as required.

    This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

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  3. Material Safety Data Sheets (MSDSs)

      The (person/position) is responsible for establishing and monitoring the company MSDS program. He/she will make sure procedures are developed to obtain the necessary MSDSs and will review incoming MSDSs for new or significant health and safety information. He/she will see that any new information is passed on to affected employees. The procedure below will be followed when an MSDS is not received at the time of initial shipment:

      (Enter procedure to be followed here.)

      Copies of MSDSs for all hazardous chemicals to which employees are exposed or are potentially exposed will be kept in (state location).

      MSDSs will be readily available to all employees during each work shift. If an MSDS is not available, contact (person/ position).

      MSDSs will be readily available to employees in each work area using the following format:

      (Describe company format here.)

      When revised MSDSs are received, the following procedures will be followed to replace old MSDSs:

      (Describe procedures.)

    This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

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  4. Employee Training and Information

      The (person/position) is responsible for the Hazard Communication Program. He/she will ensure that all program elements specified below are carried out.

      Prior to starting work, each new employee will attend a health and safety orientation that includes the following information and training:

      Prior to introducing a new chemical hazard into any section of this company, each employee in that section will be given information and training as outlined above for the new chemical hazard. The training format will be as follows:

      (Enter format, such as audiovisuals, interactive computer programs,classroom instruction, etc.)

  5. Hazardous Non-Routine Tasks

      Periodically, employees are required to perform non-routine tasks which are hazardous. Some examples of non-routine tasks are: confined space entry, tank cleaning, and painting reactor vessels. Prior to starting work on such projects, each affected employee will be given information by the (person/position) about the hazardous chemicals he or she may encounter during such activity. This information will include specific chemical hazards, protective and safety measures the employee can use, and steps the company is taking to reduce the hazards, including ventilation, respirators, the presence of another employee (buddy systems), and emergency procedures.

      Examples of non-routine tasks performed by employees of this company are:

      TaskHazardous Chemical
      (describe task #1 here) (describe the hazardous chemicals involved)
      (describe task 2 here) (describe the hazardous chemicals involved)
      (describe task #3 here) (describe the hazardous chemicals involved)
      (describe task #4 here) (describe the hazardous chemicals involved)

    This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

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  6. Informing other Employers

      It is the responsibility of (person/position) to provide other employers with information about hazardous chemicals their employees may be exposed to on a job site and suggested precautions for employees. It is the responsibility of (person/ position) to obtain information about hazardous chemicals used by other employers to which employees of this company may be exposed.

      Other employers will be provided with material safety data sheets for hazardous chemicals generated by this company's operations.

      Material safety data sheets will be provided to other employers in the following manner:

      (Provide company policy here)

      In addition to providing a copy of an MSDS to other employers, other employers will be informed of precautionary measures needed to be taken to protect their employees who are exposed to operations performed by this company.

      Also, other employers will be informed of the hazard labels used by the company. If symbolic or numerical labeling systems are used, the other employees will be provided with information to understand the labels used for hazardous chemicals for which their employees may have exposure.

  7. List of hazardous chemicals

      The following is a list of all known hazardous chemicals used by our employees. This list includes the name of the chemical manufacturer, the work area the chemicals are used in, the dates of use, and the quantity used. Further information on each chemical may be obtained from the MSDSs which are located (state location).

      Hazardous Chemical Inventory
      ChemicalManufacturerWork AreaStart DateFinish DateQuantity
      (Include here the chemical list developed during inventory. Arrange this list so that you are able to cross-reference it with your MSDS file and labels on your containers. Additional information such as the manufacturer's telephone number, an emergeny number, scientific name, CAS number, the associated task ec., could be included and might be found useful to employees and the employer.)

      When new chemicals are received, this list is updated (including date the chemicals were introduced), within 30 days of introduction into the workplace. To ensure that the chemical is added in a timely manner, the following procedures shall be followed:

      (State procedures to be followed)

      The hazardous chemical inventory was compiled and is maintained by:

      (Name and Telephone Number of Responsible Party)

    This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

  8. Chemicals in Unlabeled Pipes

      Work activities are sometimes performed by employees in areas where chemicals are transferred through unlabeled pipes. Prior to starting work in these areas, the employee shall contact (person/position) for information regarding:

      • The chemical in the pipes.
      • Potential hazards.
      • Safety precautions to be taken.

      (Include here the chemical list developed during inventory. Arrange this list so that you are able to cross-reference it with your MSDS file and labels on your containers. Additional information such as the manufacturer's telephone number, an emergeny number, scientific name, CAS number, the associated task ec., could be included and might be found useful to employees and the employer.)

  9. Program Availability

      A copy of this program will be made available, upon request, to employees and their representatives.


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Notes for Chemical Manufacturers, Importers, and Distributors

  1. Hazard Determination - Chemical manufacturers and importers are to detail the methods they will use to conduct a hazard determination for the chemicals produced or imported in their work places. The procedures should identify the system in place to conduct hazard determinations. The system should identify the person or department responsible for conducting the hazard determination and the research strategy involved. Chemical manufacturers which rely on information from upstream suppliers should state this in their written program.

  2. Transmittal of MSDSs - Chemical manufacturers, importers, and distributors should develop a system to ensure that material safety data sheets are transmitted to customers. The system should identify the person or department responsible for ensuring the transmittal of material safety data sheets and should include a method to ensure that transmittal is accomplished as required by 29 CFR 1910.1200.

  3. Labels - Chemical manufacturers, importers, and distributors should have a system for ensuring appropriate labeling of hazardous chemicals.

  4. Updating Labels/MSDSs - A system should be detailed assigning responsibility and periodic review of scientific information required to update material safety data sheets and labels as required by 29 CFR 1910.1200.


This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

Hazard Communication Checklist
1. Has a list of all hazardous chemicals in the workplace been prepared?
2. Does the company have a method for updating the hazardous chemical list?
3. Has the company obtained or developed a material safety data sheet for each hazardous chemical used?
4. Has a system been developed to ensure that all incoming hazardous chemicals have labels and data sheets?
5. Are procedures in place to ensure labeling for containers of hazardous chemicals have labels and data sheets?
6. Are employees aware of the requirements of the Hazard Communication Standard and information specific to their workplace?
7. Are employees familiar with the hazards of the chemicals in their workplace?
8. Have the employees been informed of the hazards associated with performing non-routine tasks?
9. Do employees understand how to detect the presence or release of hazardous chemicals in their workplace?
10. Are employees trained about proper work practices and personal protective equipment in relation to the hazardous chemicals in their work area?
11. Does the training program provide information on appropriate first aid, emergency procedures, and the likely symptoms of overexposure?
12. Does the training program include an explanation of labels and warnings that are used in each work area?
13. Does the training describe where employees obtain data sheets and how employees use them?
14. Is a system in place to ensure that new employees are trained before beginning work?
15. Is a system in place to identify new hazardous chemicals before they are introduced into a work area?
16. Is a system in place to inform employees of the hazards associated with newly introduced chemicals?


SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM (B)



Our Hazard Communication Program

This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

General Company Policy

List of hazardous chemicals

This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

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Material Safety Data Sheets (MSDSs)

Labels and Other Forms of Warning

Non-Routine Tasks

This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.

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Training

Contractor Employers

Additional Information


Previous: Appendix D   |   Top of Page   |   CPL 2-2.238D

This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.


The official, public domain, OSHA version of this document is available at https://www.osha.gov/enforcement/directives/cpl-02-02-038.