Recently, we received the following question from a subscriber:
I need to include wording in my hazard communication program to comply with 29 CFR 1910.1200(e)(2)(iii). Do you have any suggestions?
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Here’s our answer:
The standard at 29 CFR 1910.1200(e)(2) requires that the written HazCom program specify the methods that employers at multiemployer worksites will use to share information with other employers and employees regarding SDSs and access to them, precautionary measures and any labeling systems used at the workplace. It doesn’t specify wording.
BLR’s sample HazCom plan uses this wording in the “Informing other employers or contractors at multiemployer worksites” section:
“Also, other employers will be informed about container labels used by the organization. Where labeling systems are used that are not the original container labels, the employees of other employers or contractors will be provided with information explaining the labels used for hazardous chemicals to which they may be exposed.”
Some state agencies have sample plans that use such wording:
It is the responsibility of _______ to provide employers of any other employees at the worksite with the following information:
- Copies of SDSs (or make them available at a central location) for any hazardous chemicals that the other employer(s)’ employee may be exposed to while working.
- Inform other employers of any precautionary measures that need to be taken to protect employees during normal operating conditions or in foreseeable emergencies.
- Provide other employers with an explanation of the labeling system that is used at the work site.
- Also, OSHA’s HazCom rule at 29 CFR 1910.1200(e)(3) also states that you the employer may rely on an existing hazard communication program to comply with these requirements, provided that it meets the criteria established in this paragraph (e), including (e)(2)(iii)).
This OSHA letter of interpretation clarifies HazCom requirements for employers on multiemployer worksites.