Hazard communication requirements

Employers are required to obtain and maintain Safety Data Sheets (SDSs) and make them readily available to employees for each hazardous chemical they use in shipyard employment. Employers must keep SDSs for every hazardous chemical they produce, import, or use, and must ensure employees can access them during each work shift in accordance with 1915.1200 and the identical requirements at 1910.1200.

• Keep SDSs current and accessible where employees can get them during their shift.
• If an SDS is not available, obtain it from the supplier or prepare one; employers cannot proceed without hazard information.

(See 1915.1200 and 1910.1200.)

A hazardous chemical label must identify the product, include a signal word, pictograms, hazard statements, precautionary statements, and the name, address, and phone number of the manufacturer or responsible party. These label elements come from the hazard communication requirements adopted in 1915.1200 (identical to 1910.1200) under the Globally Harmonized System (GHS).

• Labels help employees quickly recognize hazards and required protective measures.
• Employers must ensure incoming shipped containers retain supplier labels; if transferred to a secondary container, that container must be labeled unless used immediately and only by the person who filled it.

Yes — employers must train employees about hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard is introduced. The training must cover how to read labels and SDSs, the physical and health hazards, appropriate protective measures, and how to obtain and use hazard information in accordance with 1915.1200 and 1910.1200.

• Retraining is required when new hazards are introduced or when workplace practices change.
• Maintain records of training as appropriate for your program and workforce.

Employers must treat unlabeled or unknown containers as potentially hazardous until the chemical identity is determined, and they must either label the container with the correct information or remove the container from the workplace. This follows the obligation in 1915.1200 (and 1910.1200) to ensure container labeling and availability of SDSs.

• Secure or isolate unknown containers and prevent employee exposure while you identify the contents.
• Obtain SDSs from the supplier or send a sample for analysis if necessary; then label the container appropriately and communicate hazards to affected employees.

An employer may use an alternative workplace labeling system only if it provides employees with the same information as the supplier label and employees can readily access SDSs; the employer must ensure training on the alternative system. This is permitted under the hazard communication framework in 1915.1200 and 1910.1200.

• The alternative label must effectively communicate the chemical identity and hazards.
• Employers must train employees so they understand and can use the alternative labels and still locate SDSs when needed.

Yes — employers must develop, implement, and maintain a written hazard communication program that describes how the requirements for labels, SDSs, and employee training will be met. This requirement appears in 1915.1200 and mirrors 1910.1200.

A written program must include:

• Methods to provide labels and SDSs for each hazardous chemical;
• How the employer will inform employees of hazards and train them;
• Procedures for non-routine tasks and for contractor/multi-employer communication about hazards.

Employers must ensure that all employers on site, including contractors, are informed about hazardous chemicals they may be exposed to and the protective measures required; this includes making SDSs and labels available to them. These requirements follow from 1915.1200 and the identical obligations in 1910.1200.

• The host employer should communicate the hazards present, provide access to SDSs, and coordinate protective measures.
• Contractors must inform the host of any hazardous chemicals they bring on site and provide SDSs and labels for those chemicals.

Employers must maintain records that demonstrate employees received hazard communication training, such as training dates, subjects covered, and employee names or a roster. While 1915.1200 (and 1910.1200) require training, they also support maintaining evidence of training to show compliance.

• Training records help verify that initial and refresher training occurred and are useful during inspections.
• Keep training records for as long as they have regulatory or company value.

Portable containers that are immediately used by the employee who filled them during a single work shift may be exempt from full supplier labeling, but the chemical identity and hazard information must still be available to employees; employer labeling requirements otherwise apply under 1915.1200 and 1910.1200.

• If the container leaves the immediate control of the person who filled it or is stored for future use, it must be properly labeled.
• Use alternative workplace labels consistent with the written program and train employees to understand them.

Employers must classify each hazardous chemical or mixture according to the hazard categories in 1915.1200 (the same as 1910.1200) using the definitions and criteria provided by the standard and GHS. Classification determines label elements and what information goes on the SDS.

• For mixtures, classify based on the properties of the mixture and the concentrations of hazardous ingredients.
• If in doubt, consult the supplier SDS or perform testing to determine the correct classification.

Employers must accept supplier trade secret claims but still must ensure employees have access to the hazard information needed for safe handling; suppliers claiming trade secrets must still provide sufficient hazard communication information and emergency health information. These provisions are part of the framework in 1915.1200 and 1910.1200.

• If a specific chemical identity is withheld as a trade secret, the SDS must still list the hazardous properties and provide a contact for obtaining the specific identity in emergencies.
• Employers can request the withheld information from the supplier in writing for medical or emergency response purposes; suppliers must respond appropriately per the standard.

Before employees perform non-routine tasks involving hazardous chemicals, employers must inform those employees of the hazards, protective measures, and emergency procedures specific to the task. This requirement is part of the hazard communication obligations in 1915.1200 and 1910.1200.

• Provide task-specific training and ensure SDSs and labels are accessible for the chemicals involved.
• Describe personal protective equipment (PPE), ventilation, and procedures to minimize exposures during the non-routine operation.

Employers must ensure that employees can understand the SDS and label information; if workers do not read English, the employer must provide the information in a language they understand. The hazard communication duties in 1915.1200 and 1910.1200 require effective communication of hazards.

• Translate SDSs, provide translated label explanations, or give trained interpreters so employees understand hazards and protections.
• Document the steps taken to ensure comprehension as part of your written hazard communication program.

Yes — when a hazard class or category applies to a chemical, the corresponding GHS pictogram(s) must appear on the label under 1915.1200 (consistent with 1910.1200). Pictograms provide a quick visual cue of the type of hazard present.

• Ensure pictograms are the correct ones for the hazard class (e.g., flame for flammables, skull and crossbones for acute toxicity).
• If a pictogram is not applicable due to a specific labeling exception, document why and ensure other label elements and SDS information are present.

Employers must update SDSs and labels whenever they learn of new or significant information regarding a chemical's hazards or ways to protect against those hazards. The trigger to update comes from the requirements in 1915.1200 and 1910.1200.

• If a supplier revises an SDS, the employer should replace the old SDS and inform affected employees about the changes.
• When new hazard information emerges from testing, incident investigations, or regulatory action, update labels/SDSs and retrain employees as needed.

Yes — flammable gases stored on site are covered by hazard communication and must be classified and communicated per 1915.1200 and 1910.1200; Category 1 flammable gases are defined in 1910.1200(c) and explained in OSHA's interpretation on PSM aggregation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

• The PSM interpretation clarifies that Category 1 flammable gases meet the hazard definitions in 1910.1200(c) and must be communicated and handled appropriately.
• If quantities of flammable gases exceed other regulatory thresholds (e.g., PSM), coordinate compliance with those standards as well.

Yes — SDSs must include emergency and first-aid measures and special firefighting procedures, and employers must make sure employees and emergency responders know how to use that information. These SDS elements are part of the hazard communication requirements in 1915.1200 and 1910.1200.

• Post or make SDSs available to emergency responders on site and ensure employees know emergency steps and who to notify.
• Incorporate SDS emergency information into site emergency plans and training.

If an employer produces and uses a hazardous chemical only at their facility, they must still classify the chemical, prepare an SDS, label containers, and communicate hazards to employees per 1915.1200 and 1910.1200. Internal production does not remove the employer's obligations.

• Prepare an SDS that includes all required sections and ensure labels and training cover the internal chemical's hazards.
• If the chemical is shipped to others, additional supplier obligations apply.

Manufacturers and importers must classify chemicals and provide labels and SDSs; shipyard employers must ensure those SDSs and labels are present at the workplace, maintain a written program, and train employees. These roles flow from 1915.1200 and 1910.1200.

• Manufacturers/importers: prepare accurate SDSs and labels in compliance with the standard.
• Employers: obtain SDSs, ensure labels remain with containers, implement training, and maintain the written program.

If a consumer product used in the workplace presents a hazard under the criteria of 1915.1200 (same as 1910.1200), the employer must include it in the hazard communication program, ensure an SDS is available, label workplace containers, and train employees on its hazards.

• Even if labeled as a consumer product, workplace use triggers employer responsibilities if it meets hazard criteria.
• Maintain SDSs and training specific to how the product is used in the shipyard environment.

Employers must provide medical personnel the SDS and any other information necessary to treat the exposed employee, including the identity of the hazardous chemical unless it is a legitimate trade secret. This obligation is part of the hazard communication duties in 1915.1200 and 1910.1200.

• If a supplier claims a trade secret for an ingredient, the supplier must provide the specific chemical identity to a physician or nurse in a medical emergency upon request.
• Keep SDSs accessible for emergency responders and medical staff.

Yes — employers should maintain an up-to-date inventory of hazardous chemicals on site to support the written hazard communication program, SDS management, and emergency planning as expected under 1915.1200 and 1910.1200.

• Use the inventory to ensure SDSs are obtained for every chemical, to prioritize training, and to identify chemicals requiring special controls or coordination with other standards (e.g., PSM).
• Update the inventory when chemicals are added or removed from the workplace.

Hazard communication under 1915.1200 (and 1910.1200) is complementary to other OSHA standards; employers must comply with all applicable standards. For example, classification of Category 1 flammable gases under 1910.1200(c) can trigger Process Safety Management obligations as discussed in OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

• Hazard communication provides labels/SDSs and training; other standards (like PSM, respiratory protection, or PELs) impose additional controls beyond labeling and SDSs.
• Evaluate each chemical for all applicable standards and implement whichever requirements apply.

If a supplier does not provide an SDS, the employer must attempt to obtain it and, if unsuccessful, take steps to protect employees by obtaining hazard information from other sources and consider stopping use until safe information is available, consistent with obligations in 1915.1200 and 1910.1200.

• Contact the supplier formally and document the request; if the supplier still fails to provide an SDS, consider using an alternative product or send a sample to a laboratory for hazard testing.
• Protect employees with interim controls (PPE, engineering controls, restricted access) until accurate SDS information is obtained.

When a new SDS becomes available, employers must replace the old SDS with the updated version and inform affected employees about any significant changes in hazards or protections, per 1915.1200 and 1910.1200.

• Keep the updated SDS accessible to employees and emergency responders.
• Document that employees were informed or retrained on the new information if the update changes hazard controls or emergency response.