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OSHA 1910.1020AppB

NIOSH RTECS availability

Subpart Z

16 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.1020AppB, when does the recordkeeping rule apply because a substance appears in the NIOSH RTECS?

Yes — if a substance is listed in the latest printed NIOSH Registry of Toxic Effects of Chemical Substances (RTECS), the employer’s employee exposure and medical records (and analyses of those records) relevant to employees exposed to that substance fall under the recordkeeping rule. See Appendix B to 1910.1020 and the general applicability in 1910.20.

Under 1910.1020AppB, does an entry in the RTECS automatically mean the chemical must be avoided in the workplace?

No — an RTECS listing does not automatically mean the chemical must be avoided; it means the substance has documented potential to cause harm and requires that employers exercise care to prevent misuse and exposures. Appendix B explains that RTECS entries identify substances with evidence of harmful effects, but many listed substances are common and safe when used properly; employers should use that toxicity information to guide hazard evaluation and controls. See 1910.1020 App B.

Under 1910.1020AppB, must employers purchase the latest printed edition of the NIOSH RTECS to comply with recordkeeping rules?

No — employers are not required to purchase the RTECS to comply with the recordkeeping rule. Appendix B states it is appropriate to note that the final regulation does not require employers to buy a copy of RTECS, although some employers may choose to obtain it to help determine whether the rule applies. See 1910.1020 App B and the recordkeeping requirement in 1910.20.

Under 1910.1020AppB, what is the primary purpose of the NIOSH RTECS for employers and safety staff?

The RTECS is used as a chief source to determine whether there is evidence that a substance is a "toxic substance or harmful physical agent," which affects whether employee exposure and medical records are covered by the rule. Appendix B describes RTECS as a single-source reference for basic toxicity information, lowest‑dose effects, literature citations, and chemical identifiers useful for hazard evaluations, safety data sheet preparation, and selecting safer substitutes. See 1910.1020 App B and the definition of covered agents in 1910.1020(c)(13).

Under 1910.1020(b)(2), how does Appendix B describe the scope of records covered when a substance is listed in RTECS?

Appendix B states that when a substance appears in the latest printed RTECS, the regulation applies to employee exposure records, medical records, and analyses of those records that are relevant to employees exposed to the substance. In short, listing in RTECS can trigger coverage for both exposure monitoring and medical surveillance records under the rule. See 1910.1020(b)(2) and 1910.1020 App B.

Under 1910.1020AppB, where can employers or workers review the latest printed RTECS without buying it?

You can review recent printed or microfiche editions at many university and public libraries, at the OSHA Technical Data Center in Washington, D.C., or at any OSHA Regional or Area Office. Appendix B lists these options and notes the RTECS may also be purchased from the Government Publishing Office. See 1910.1020 App B.

Under 1910.1020AppB, does the RTECS include synonyms and foreign-language chemical names, and why does that matter?

Yes — the printed RTECS includes a large number of synonyms and foreign-language chemical names, which helps employers and health professionals rapidly identify substances produced in other countries and cross‑reference alternate names. Appendix B notes that the registry’s many synonyms and foreign names improve identification and linkage to toxicity data for hazard evaluation and recordkeeping decisions. See 1910.1020 App B.

Under 1910.1020AppB, does an employer need RTECS to determine whether a substance is a "toxic substance or harmful physical agent" under 1910.1020(c)(13)?

No — RTECS is used as one of the chief sources of information, but employers are not required to rely solely on it; the definition in 1910.1020(c)(13) covers chemical substances, biological agents, and physical stresses with evidence of harmful health effects, and Appendix B explains RTECS is a primary—but not exclusive—source for that evidence. See 1910.1020 App B.

Under 1910.1020AppB, how often is the printed RTECS issued and how does that affect employers who use it?

The printed RTECS is issued annually (with quarterly microfiche updates historically), so employers who consult it should use the latest printed edition to determine whether a substance is listed; Appendix B notes the RTECS is issued annually as mandated by the OSH Act. Using the current edition helps ensure employers base recordkeeping decisions on the most recent toxicity listings. See 1910.1020 App B.

Under 1910.1020AppB, if a chemical appears only in an older RTECS edition but not in the latest, does that affect coverage?

If a chemical appeared only in an older edition but is not in the latest printed RTECS, Appendix B indicates the regulation uses the latest printed edition as the chief source; therefore employers should rely on the current edition to determine coverage. If uncertainty remains, employers should document their evaluation and consider other authoritative toxicity sources while applying 1910.1020 recordkeeping requirements. See 1910.1020 App B and 1910.20.

Under 1910.1020AppB, can RTECS help employers prepare safety data sheets (SDSs) and hazard evaluations?

Yes — Appendix B explains that RTECS provides basic toxicity information and lowest-reported-dose data across routes of entry, which can help employers and safety professionals prepare or evaluate safety data sheets and conduct workplace hazard evaluations and substitute selection. See 1910.1020 App B.

Under 1910.1020AppB, who publishes and distributes the printed RTECS and microfiche editions?

The Government Publishing Office (GPO) distributes the printed edition and the quarterly microfiche; Appendix B gives the GPO ordering information and notes an annual subscription is available for the microfiche updates. Employers can order from the Superintendent of Documents at GPO or examine copies at many libraries and OSHA offices. See 1910.1020 App B.

Under 1910.1020AppB, how can an employer use the RTECS when deciding whether to keep exposure or medical records for a particular chemical?

Use RTECS search results as evidence that a chemical has documented toxic effects; if the substance is listed in the latest printed edition, the employer should treat employee exposure and medical records relating to that substance as governed by the rule and follow [1910.20] standards for creation, retention, and access. Document the search (edition used, date, search terms) to show how the decision was reached. See 1910.1020 App B and 1910.20.

Under 1910.1020AppB, does Appendix B create new employer obligations beyond 1910.1020 and 1910.20?

No — Appendix B is non‑mandatory guidance explaining how RTECS is used as a source of evidence; it does not create new legal obligations beyond the requirements in 1910.1020 and 1910.20. Employers must follow the binding standards, and Appendix B helps interpret how RTECS relates to those duties. See 1910.1020 App B.

Under 1910.1020AppB, if an employer cannot access the latest printed RTECS, what practical steps does Appendix B recommend?

Appendix B notes employers who lack the printed edition may still: review RTECS copies at nearby university/public libraries or at OSHA offices, consider purchasing the printed edition or microfiche subscription from GPO, and document their steps to identify toxic substances using available authoritative sources. Relying on other reliable toxicity information and documenting the evaluation can support compliance with 1910.1020 and 1910.20. See 1910.1020 App B.

Under 1910.1020AppB, how should employers document their use of RTECS when determining recordkeeping obligations?

Document the edition of RTECS consulted, the date searched, search terms or chemical names used (including synonyms), and the conclusion reached about coverage; Appendix B emphasizes using the latest printed edition and cross-referencing synonyms to identify listings, and such documentation supports compliance with recordkeeping requirements in 1910.20 and the guidance in 1910.1020 App B.