Yes — the hazard communication requirements for construction are the same as the general industry Hazard Communication standard. See Hazard Communication under 1926.59 which states the construction requirements are identical to 1910.1200.
The employer who produces or imports a chemical is responsible for classifying its hazards. Employers must evaluate the chemical’s physical and health hazards and classify them in accordance with the criteria in 1910.1200.
The label from the chemical supplier must include the product identifier, signal word, hazard statements, pictograms, precautionary statements, and the name, address, and telephone number of the supplier. These labeling elements are required by 1910.1200.
Yes — employers may use alternative labeling systems on workplace secondary containers as long as they provide the same basic information and employees can quickly identify the hazards. Labels on secondary containers must at minimum include a product identifier and words, pictures, symbols, or a combination that provide at least general information about the hazards, consistent with 1910.1200.
The employer must maintain a current Safety Data Sheet (SDS) for each hazardous chemical used or stored on-site and make it readily accessible to employees during their work shift. These requirements are set out in 1910.1200.
Employers must provide hazard communication training at the time of an employee’s initial assignment and whenever a new physical or health hazard is introduced into the work area. This training requirement is described in 1910.1200.
Yes — construction employers must have a written hazard communication program. It should describe how labels, Safety Data Sheets (SDSs), and employee information and training will be handled, and identify a person responsible for the program. The requirement for a written program is in 1926.59 and mirrors 1910.1200.
Employers must still maintain an SDS for the mixture; if a manufacturer withholds specific chemical identity as a trade secret, the SDS must still provide all other required hazard information and the trade-secret claim must follow the rules in 1910.1200 for protecting identities while providing necessary hazard data to employers and health professionals.
On multi-employer worksites, each employer must make sure their employees are informed about hazards they may encounter and must share SDSs and information about hazardous chemicals they bring to the site. Employers must also coordinate with other employers so employees are protected, consistent with the duties in 1910.1200 as implemented for construction by 1926.59.
Yes — employers must ensure that SDSs and labels are updated whenever new hazard information becomes available for a chemical they use or store, and they must inform employees of the new information; this obligation is part of the requirements in 1910.1200.
A Category 1 flammable gas is a gas that is ignitable at or below a low flammability limit (LFL) criteria defined in 1910.1200(c). OSHA applied this definition in its interpretation on PSM flammable gas aggregation, confirming that refrigerant blends meeting Category 1 criteria are treated as such for related standards; see OSHA’s letter on PSM flammable gas aggregation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 which cites 1910.1200.
No — pictograms alone are not sufficient. Employers must train employees on all required elements of hazard communication, including the meaning of labels and pictograms, hazard statements, precautionary measures, and how to read SDSs, as required by 1910.1200.
SDSs must be readily accessible to employees in their work area during each work shift, and employers may keep them in written or electronic form as long as employees can access them immediately when needed; this accessibility requirement is stated in 1910.1200.
Yes — employers must ensure training and information are understandable to all employees; if an employee cannot understand English, the employer must provide information and training in a language and vocabulary that the employee understands, as required by 1910.1200.
Laboratory operations may be subject to different provisions (such as OSHA’s Laboratory Standard), but when hazardous chemicals are used outside laboratory-specific programs, employers must follow the hazard communication requirements in 1910.1200. Employers should review the applicable standards to determine which requirements apply in their situation.
Yes — employers must ensure that employees can readily identify hazardous chemicals, which generally includes labeling piping systems or providing an equivalent means of identification where employees could be exposed; this is consistent with the identification and labeling duties in 1910.1200.
Employers must treat unknown, unlabeled containers as hazardous and take steps to protect employees immediately — remove or isolate the container, prevent employee exposure, and obtain an SDS or identify the chemical before work proceeds, following general hazard communication and hazard control duties in 1910.1200.
Yes — employers may use electronic SDSs if they ensure employees can immediately access the information during their work shift; employers must provide a paper copy upon request and ensure access even during power outages or where electronic access is impractical, per the accessibility requirements of 1910.1200.