Osha 1926 Construction Manual: Checklist For Compliance

OSHA 1926 CONSTRUCTION MANUAL
Checklist for compliance

The following checklist will help to ensure you are in compliance with the rule:
❏ Get a copy of the standard.
❏ Read the requirements of the standard.
❏ Prepare/update the chemical inventory.
❏ Obtain a Safety Data Sheet (SDS) for each hazardous chemical.
❏ Review/develop the written HazCom plan and update as necessary.
❏ Assign responsibilities for the various HazCom tasks.
❏ Ensure containers are labeled.
❏ Conduct worker training.
❏ Make SDSs available to workers.
❏ Establish procedures to keep SDSs current and available.
❏ Establish procedures to revise/update the written program.
❏ Establish procedures to evaluate the effectiveness of the program.
Hazard Classification
Hazard classification
The Hazard Communication standard helps protect against chemical source illnesses and injuries
by ensuring that employers and employees are provided with the information they need to anticipate,
recognize, evaluate and control chemical hazards, and take appropriate protective measures.
This information is provided through:
• Safety data sheets (SDSs),
• Labels, and
• Employee training.
In order for SDSs, labels, and training to be effective, the hazard information they convey must be
complete and accurate. So the chemical manufacturer or importer is responsible for classifying the
hazards and providing information downstream to distributors and users of the chemicals. Employers
must make sure that employees have access to the correct information about the hazards associated
with the particular chemicals.
Hazard classification is the process of evaluating available scientific evidence in order to determine
if a chemical is hazardous pursuant to the HCS. This evaluation identifies physical hazards (e.g.,
flammability or reactivity), health hazards (e.g., carcinogenicity or sensitization), and environmental
hazards although OSHA does not address environmental hazards in the HCS.
The hazard determination provides the basis for “classifying” the chemical, and providing the hazard
information in SDSs, labels, and employee training.
HAZARD COMMUNICATION–12
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Original content is the copyrighted property of J. J. Keller & Associates, Inc.
The hazardous nature of the chemical and the potential for exposure are the factors that determine
whether a chemical is covered. If it is not hazardous, it is not covered. If there is no potential for
exposure, (e.g., the chemical is inextricably bound and cannot be released), the rule does not cover
the chemical.
What is classification?
Classification is the starting point for hazard communication. It involves the identification of the haz-
ard(s) of a chemical or mixture by assigning a class and category of hazard/danger using GHS-
defined criteria.
The GHS draws a clear distinction between classes and categories in order to allow for “self
classification.”
The revised HCS has specific criteria for classifying each health and physical hazard, along with
detailed instructions for hazard evaluation and classification determinations for mixtures.
The three steps required for “Classification” are to:
• Identify the relevant data regarding the hazards of a chemical;
• Review those data to ascertain the hazards associated with the chemical; and
• Decide whether the chemical will be classified as hazardous, and the degree of hazard
where appropriate, by comparing the data with the criteria for health and physical hazards.
Hazard Class and Category

In the final rule, OSHA includes definitions for “hazard class” and “hazard category” to further explain
the approach of breaking down the hazardous effects into levels of severity.
Hazard Class
A “hazard class” is defined as “the nature of the physical or health hazards, e.g., flammable solid,
carcinogen, oral acute toxicity.”
Each hazard or endpoint (e.g., Explosives, Carcinogenicity) is considered to be a hazard class. Most
hazard classes are further sub-divided into categories of hazard.
Hazard Category
The definition of “hazard category” is “the division of criteria within each hazard class, e.g., oral acute
toxicity and flammable liquids include four hazard categories. These categories compare hazard
severity within a hazard class and should not be taken as a comparison of hazard categories
generally.”
Carcinogenicity has two hazard categories. Category one is for known or presumed human car-
cinogens while category two encompasses suspected human carcinogens.
The definitions of hazards are specific and detailed. OSHA has included the general provisions for
hazard classification in paragraph (d) of the revised rule, and added extensive information for clas-
sifying both pure chemicals and mixtures in Appendixes A and B that address the criteria for each
health or physical effect.
Under the 1994 HCS, a chemical was either an explosive or it was not. The GHS has seven cat-
egories of explosives, and assignment to these categories is based on the classification criteria
provided.
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GHS endpoints
GHS endpoints or cutoff values cover physical, health, and environmental hazards although OSHA
does not include environmental hazards in the HCS. For several hazards the GHS criteria are semi-
quantitative or qualitative.
The person responsible for GHS implementation should consult the GHS Document or “Purple Book”
for more complete information.
For some hazard classes, classification results directly when the data satisfy the criteria. For others,
classification of a chemical shall be determined on the basis of the total weight of evidence using
expert judgment.
This means that all available information bearing on the classification of hazard must be considered
together, including the results of valid in vitro tests, relevant animal data, and human experience such
as epidemiological and clinical studies and well-documented case reports and observations. Expert
judgment may be required to interpret these data.
OSHA has provided guidance on hazard classification for carcinogenicity. Part A of Appendix F
includes background guidance provided by GHS based on the Preamble of the IARC “Monographs
on the Evaluation of Carcinogenic Risks to Humans” (2006). Part B provides IARC classification
information. Part C provides background guidance from the National NTP “Report on Carcinogens”
(RoC), and Part D is a table that compares GHS carcinogen hazard categories to carcinogen clas-
sifications under IARC and NTP, allowing classifiers to be able to use information from IARC and NTP
RoC carcinogen classifications to complete their classifications under the GHS, and thus the
HCS.
See Appendix F Guidance for Hazard Classifications Re: Carcinogenicity (Non-Mandatory) in the
Reference section of this manual.
The data used for classification may be obtained from existing tests, literature, and practical expe-
rience — no testing is required.
The GHS classification criteria are test method neutral. Accordingly, tests that determine hazardous
properties conducted according to internationally recognized scientific principles can be used for
purposes of hazard classification.
Health Hazards
While the overall scope of what is covered is essentially the same as the previous HCS, the hazards
may be identified slightly differently. For example, the 1994 HCS covers reproductive toxicity as a
target organ effect, and includes all aspects of the effect under that hazard. The GHS has a separate
definition for germ cell mutagenicity, which was considered part of reproductive toxicity in the old
HCS.
OSHA defines a “Health hazard” as a chemical which is classified as posing one of the following
hazardous effects:
• Acute toxicity (any route of exposure),
• Skin corrosion or irritation,
• Serious eye damage or eye irritation,
• Respiratory or skin sensitization,
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• Germ cell mutagenicity,

• Carcinogenicity,
• Reproductive toxicity,
• Specific target organ toxicity (single or repeated exposure), or
• Aspiration hazard.
Here are OSHA’s definitions of the health hazards.
Acute toxicity
Acute toxicity refers to those adverse effects that occur
following oral or dermal administration of a single dose of
a substance, or multiple doses given with 24 hours, or an
inhalation exposure of 4 hours.
OSHA has adopted the first four of the five GHS catego-
ries in each of these classes:
• Acute Toxicity — Oral,
• Acute Toxicity — Dermal, or
• Acute Toxicity — Inhalation.
Chemicals are assigned to one of the categories on the
basis of LD50 (oral, dermal) or LC50 (inhalation) values.
The LC50 values are based on 4-hour tests in animals.
The GHS provides guidance on converting 1-hour inha-
lation test results to a 4-hour equivalent.
Exposure route Category 1 Category 2 Category 3 Category 4

Oral (mg/kg body- ≤ 5 > 5 and ≤ 50 > 50 and ≤ 300 > 300 and ≤ 2000
weight) see: Notes
(a)(b)
Dermal (mg/kg body- ≤ 50 > 50 and ≤ 200 > 200 and ≤ 1000 > 1000 and ≤ 2000
weight) see: Notes
(a)(b)
Inhalation — Gases ≤ 100 > 100 and ≤ 500 > 500 and ≤ 2500 > 2500 and ≤ 20000
(ppmV) see: Note (a)
Note (b) Note (c)
Inhalation — Vapors ≤ 0.5 > 0.5 and ≤ 2.0 > 2.0 and ≤ 10.0 > 10.0 and ≤ 20.0
(mg/l) see: Note (a)
Note (b) Note (c) Note
(d)
Inhalation — Dusts and ≤ 0.05 > 0.05 and ≤ 0.5 > 0.5 and ≤ 1.0 > 1.0 and ≤ 5.0
Mists (mg/l) see: Note
(a) Note (b) Note (c)
Notes to the table:
(a) The acute toxicity estimate (ATE) for the classification of a substance is derived using the LD50/LC50 where available;
(b) The acute toxicity estimate (ATE) for the classification of a substance or ingredient in a mixture is derived using:
(i) the LD50/LC50 where available. Otherwise,
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(ii) the appropriate conversion value from Table 1.2 that relates to the results of a range test, or
(iii) the appropriate conversion value from Table 1.2 that relates to a classification category;
(c) Inhalation cut-off values in the table are based on 4 hour testing exposures. Conversion of existing inhalation toxicity
data which has been generated according to 1 hour exposure is achieved by dividing by a factor of 2 for gases and vapors
and 4 for dusts and mists;
(d) For some chemicals the test atmosphere may consist of a vapor which is near the gaseous phase. In these cases,
classification is based on ppmV as follows: Category 1 (100 ppmV), Category 2 (500 ppmV), Category 3 (2500 ppmV),
Category 4 (20000 ppmV).
The terms “dust”, “mist” and “vapor” are defined as follows:
(i) Dust: solid particles of a substance or mixture suspended in a gas (usually air);
(ii) Mist: liquid droplets of a substance or mixture suspended in a gas (usually air);
(iii) Vapor: the gaseous form of a substance or mixture released from its liquid or solid state.
In the proposed rule, OSHA proposed to adopt GHS Categories 1 through 4, but not 5, saying that
the current coverage of the HCS is greater than Category 3 of the GHS, but does not include all of
Category 4. OSHA believed that adopting only three categories would reduce protections with regard
to acute toxicity. Adopting Category 4 expands coverage somewhat.
However, chemicals meeting the definition of Category 4 are already covered under the national
consensus standard on labeling that many chemical manufacturers already follow (ANSI Z129).
In addition, the EU covered them under their previous classification, packaging, and labeling of
dangerous substances (Directive 67/548/EEC) and preparations (Directive 1999/45/EC) directives,
and their adopted GHS provisions. These countries comprise the largest trading partner in chemicals
for the U.S. Thus, many manufacturers are already classifying their chemicals as acutely toxic to
comply with European requirements.
Skin corrosion/Irritation
Skin corrosion is the production of irreversible damage to the skin; namely, visible necrosis through
the epidermis and into the dermis, following the application of a test substance for up to 4 hours.
There are three sub-categories of Category 1 that OSHA has assigned to the single harmonized
corrosion category of Category 1.
Skin irritation means the production of reversible damage to the skin following the application of a
test substance for up to 4 hours. Substances and mixtures in this hazard class are assigned to a
single irritant category.
In the proposed rule, OSHA proposed to adopt Categories 1 and 2, but not Category 3, for skin
corrosion/irritation. OSHA felt that Category 3 covers more than the criteria for this hazardous effect
under the current HCS. In addition, the irritant effects covered by Category 3 are very minor and
transient, and of limited applicability in the workplace setting.
Serious eye damage/eye irritation

Serious eye damage is the production of tissue damage in the eye, or serious physical decay of
vision, following application of a test substance to the anterior surface of the eye, which is not fully
reversible within 21 days of application.
Eye irritation is the production of changes in the eye following the application of test substance to
the anterior surface of the eye, which are fully reversible within 21 days of application.
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Respiratory or skin sensitization

The hazard class “respiratory or skin sensitization” is differentiated into:
(a) Respiratory sensitization, and
(b) Skin sensitization.
Respiratory sensitizer means a chemical that will lead to hypersensitivity of the airways following
inhalation of the chemical.
Skin sensitizer means a substance that will induce an allergic response following skin contact.
The definition for “skin sensitizer” is equivalent to “contact sensitizer.” Substances and mixtures in
this hazard class are assigned to one hazard category. Consideration should be given to classifying
substances which cause immunological contact urticaria (an allergic disorder) as contact sensitiz-
ers.
The GHS criteria for respiratory and skin sensitizers have one category for each type of sensitization,
but also give the option of dividing that one category into two sub-categories, which involves a
differentiation in the type of evidence available. OSHA proposed to adopt the sub-categories for
classification, however, the Agency recognizes that there are situations where data are not available
to place the chemical into one of the sub-categories.
Simply classifying the chemical as Category 1 will be sufficient in cases where data are insufficient
to assign a subcategory.
Germ cell mutagenicity

A mutation is defined as a permanent change in the amount or structure of the genetic material in
a cell or an increased occurrence of mutations in populations of cells and/or organisms. The term
mutation applies both to heritable genetic changes that may be manifested at the phenotypic level
and to the underlying DNA modifications when known (including, for example, specific base pair
changes and chromosomal translocations).
The term mutagenic and mutagen will be used for agents giving rise to an increased occurrence of
mutations in populations of cells and/or organisms.
Substances and mixtures in this hazard class are assigned to one of two hazard categories. Cat-
egory 1 has two subcategories:
• Subcategory 1A Positive evidence from epidemiological studies; and
• Subcategory 1B Positive results in vivo heritable germ cell tests in mammals, human
germ cell tests, or in vivo somatic mutagenicity tests, combined with some evidence of
germ cell mutagenicity.
Category 2 is those chemicals which are suspected or possibly known to cause heritable mutations
in human germ cells.
Carcinogenicity
Carcinogen means a chemical substance or a mixture of chemical substances which induce cancer
or increase its incidence. Substances and mixtures in this hazard class are assigned to one of two
hazard categories.
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Category 1 has two subcategories:

• Subcategory 1A Known to have carcinogenic potential for humans, and
• Subcategory 1B Presumed to have carcinogenic potential for humans.
Category 2 is suspected human carcinogens.
Classification of a substance or mixture as posing a carcinogenic hazard is based on its inherent
properties and does not provide information on the level of the human cancer risk which the use of
the substance or mixture may represent.
Appendix F has been updated to reflect the latest version of the IARC text, but also includes addi-
tional guidance on how to use IARC and NTP to make carcinogenicity classifications. The inclusion
of this guidance should make classification easier for chemicals addressed by these sources, and
should also provide parameters for the type of weight-of-evidence decisions that are appropriate
under the GHS-aligned criteria.
Reproductive toxicity
Reproductive toxicity includes adverse effects on sexual function and fertility in adult males and
females, as well as adverse effects on development of the offspring. Some reproductive toxic effects
cannot be clearly assigned to either impairment of sexual function and fertility or to developmental
toxicity. Nonetheless, chemicals with these effects shall be classified as reproductive toxicants.
Adverse effects on sexual function and fertility means any effect of chemicals that interferes with
reproductive ability or sexual capacity.
Adverse effects includes, but is not limited to, alterations to the female and male reproductive sys-
tem, adverse effects on onset of puberty, gamete production and transport, reproductive cycle nor-
mality, sexual behavior, fertility, parturition, pregnancy outcomes, premature reproductive senescence,
or modifications in other functions that are dependent on the integrity of the reproductive sys-
tems.
Adverse effects on development of the offspring means any effect of chemicals which interferes with
normal development of the conceptus either before or after birth, which is induced during pregnancy
or results from parental exposure. These effects can be manifested at any point in the life span of
the organism.
The major manifestations of developmental toxicity include death of the developing organism, struc-
tural abnormality, altered growth and functional deficiency.
Adverse effects on or via lactation are also included in reproductive toxicity, but for classification
purposes, such effects are treated separately.
Specific Target Organ Toxicity — Single Exposure (STOT-SE)

Specific target organ toxicity — single exposure, (STOT-SE) means specific, non-lethal target organ
toxicity arising from a single exposure to a chemical. This category includes all significant health
effects that can impair function, both reversible and irreversible, immediate and/or delayed.
The adverse health effects produced by a single exposure include consistent and identifiable toxic
effects in humans; or, in experimental animals, toxicologically significant changes which have affected
the function or morphology of a tissue/organ, or have produced serious changes to the biochemistry
or hematology of the organism, and these changes are relevant for human health.
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Human data is the primary source of evidence for this hazard class.
Assessment must take into consideration not only significant changes in a single organ or biological
system but also generalized changes of a less severe nature involving several organs.
Specific target organ toxicity can occur by any route that is relevant for humans, i.e., principally oral,
dermal, or inhalation.
Specific Target Organ Toxicity — Repeated or Prolonged Exposure (STOT-RE)

Specific target organ toxicity — repeated exposure (STOT-RE) means specific target organ toxicity
arising from repeated exposure to a substance or mixture. All significant health effects that can impair
function, both reversible and irreversible, immediate and/or delayed.
Adverse health effects produced by repeated exposure include consistent and identifiable toxic effects
in humans, or, in experimental animals, toxicologically significant changes which have affected the
function or morphology of a tissue/organ, or have produced serious changes to the biochemistry or
hematology of the organism and these changes are relevant for human health.
Human data will be the primary source of evidence for this hazard class.
Assessment must take into consideration not only significant changes in a single organ or biological
system but also generalized changes of a less severe nature involving several organs.
Specific target organ toxicity can occur by any route that is relevant for humans, i.e., principally oral,
dermal, or inhalation.
Aspiration hazard
Aspiration means the entry of a liquid or solid chemical directly through the oral or nasal cavity, or
indirectly from vomiting, into the trachea and lower respiratory system.
Aspiration toxicity includes severe acute effects such as chemical pneumonia, varying degrees of
pulmonary injury or death following aspiration.
Aspiration is initiated at the moment of inspiration, in the time required to take one breath, as the
causative material lodges at the crossroad of the upper respiratory and digestive tracts in the lar-
yngopharyngeal region.
Aspiration of a substance or mixture can occur as it is vomited following ingestion. This may have
consequences for labeling, particularly where, due to acute toxicity, a recommendation may be con-
sidered to induce vomiting after ingestion.
However, if the substance/mixture also presents an aspiration toxicity hazard, the recommendation
to induce vomiting may need to be modified.
Physical Hazards
The process for classification of physical hazards is similar to that for health hazards. The hazards
of a substance are determined, and the data is compared to the GHS classification endpoints or
cutoff values. The substance is then placed into the proper hazard class and category. You can view
all of OSHA’s guidance on determining physical hazards in Appendix B Physical Criteria found in the
Reference section of this manual.
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Explosives
An explosive chemical is a solid or liquid chemical which
is in itself capable by chemical reaction of producing gas
at such a temperature and pressure and at such a speed
as to cause damage to the surroundings.
Pyrotechnic chemicals are included even when they do
not emit gases.
A pyrotechnic chemical is a chemical designed to produce
an effect by heat, light, sound, gas or smoke or a combi-
nation of these as the result of non-detonative self-
sustaining exothermic chemical reactions.
An explosive item is an item containing one or more explo-
sive chemicals.
A pyrotechnic item is an item containing one or more pyro-
technic chemicals.
The GHS criteria for explosives currently use the term “article” in a manner that is inconsistent with
that term as used in the workplace in the U.S. OSHA has changed the term to “item” in these
criteria.
An unstable explosive is an explosive which is thermally unstable and/or too sensitive for normal
handling, transport, or use.
An intentional explosive is a chemical or item which is manufactured with a view to produce a prac-
tical explosive or pyrotechnic effect.
The class of explosives comprises:
(a) Explosive chemicals;
(b) Explosive items, except devices containing explosive chemicals in such quantity or of such a
character that their inadvertent or accidental ignition or initiation shall not cause any effect
external to the device either by projection, fire, smoke, heat or loud noise; and
(c) Chemicals and items not included under (a) and (b) above which are manufactured with the
view to producing a practical explosive or pyrotechnic effect.
Flammable gases
Flammable gas means a gas having a flammable range with air at 20°C (68°F) and a standard
pressure of 101.3 kPa (14.7 psi). A flammable gas must be classified in one of the two categories
for this class.
Category 1 gases, which at 20°C (68°F) and a standard pressure of 101.3 kPa (14.7 psi): Are ignit-
able when in a mixture of 13% or less by volume in air; or Have a flammable range with air of at least
12 percentage points regardless of the lower flammable limit.
Category 2 gases, other than those of Category 1, which, at 20°C (68°F) and a standard pressure
of 101.3 kPa (14.7 psi), have a flammable range while mixed in air.
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Flammable aerosol
Aerosol means any non-refillable receptacle containing a gas compressed, liquefied or dissolved
under pressure, and fitted with a release device allowing the contents to be ejected as particles in
suspension in a gas, or as a foam, paste, powder, liquid or gas.
Aerosols must be considered for classification as flammable if they contain any component which is
classified as a flammable liquid, a flammable gas, or a flammable solid.
Flammable components do not include pyrophoric, self-heating, or water-reactive chemicals.
Flammable aerosols do not fall additionally within the scope of flammable gases, flammable liquids,
or flammable solids.
Oxidizing gases
Oxidizing gas means any gas which may, generally by pro-
viding oxygen, cause or contribute to the combustion of
other material more than air does.
“Gases which cause or contribute to the combustion of
other material more than air does” means pure gases or
gas mixtures with an oxidizing power greater than 23.5%
(as determined, by a method specified in ISO 10156:1996
or 10156-2:2005 or an equivalent testing method.)
Gases under pressure

Gases under pressure are gases which are contained in a
receptacle at a pressure of 200 kPa (29 psi) (gauge) or
more, or which are liquefied or liquefied and refrigerated.
They comprise compressed gases, liquefied gases, dis-
solved gases and refrigerated liquefied gases.
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Flammable liquids
Flammable liquid means a liquid having a flash point of not
more than 93°C (199.4°F).
The European system only addresses Categories 1 through
3. The 1994 HCS covers flammable liquids in Category 4,
and exclusion of this category would result in reduced pro-
tection, which OSHA does not believe is appropriate. Thus
Category 4 is included in the revised HCS.
Flammable solids
Flammable solid means a solid which is a readily com-
bustible solid, or which may cause or contribute to fire
through friction. Readily combustible solids are powdered,
granular, or pasty chemicals which are dangerous if they
can be easily ignited by brief contact with an ignition source,
such as a burning match, and if the flame spreads rapidly.
Self-reactive chemicals
Self-reactive chemicals are thermally unstable liquid or solid chemicals liable to undergo a strongly
exothermic decomposition even without participation of oxygen (air). This definition excludes chemi-
cals classified under this section as explosives, organic peroxides, oxidizing liquids or oxidizing
solids.
A self-reactive chemical is regarded as possessing explosive properties when in laboratory testing
the formulation is liable to detonate, to deflagrate rapidly or to show a violent effect when heated
under confinement.
Pyrophoric liquids
Pyrophoric liquid means a liquid which, even in small quantities, is liable to ignite within five minutes
after coming into contact with air.
A pyrophoric liquid shall be classified in a single category for this class using test N.3 in Part III,
sub-section 33.3.1.5 of the UN Recommendations on the Transport of Dangerous Goods, Manual
of Tests and Criteria, Fourth Revised Edition.
Pyrophoric solids
Pyrophoric solid means a solid which, even in small quantities, is liable to ignite within five minutes
after coming into contact with air.
A pyrophoric solid must be classified in a single category for this class using test N.2 in Part III,
sub-section 33.3.1.4 of the UN Recommendations on the Transport of Dangerous Goods, Manual
of Tests and Criteria, Fourth Revised Edition.
Self-heating chemicals
A self-heating chemical is a solid or liquid chemical, other than a pyrophoric liquid or solid, which,
by reaction with air and without energy supply, is liable to self-heat; this chemical differs from a
pyrophoric liquid or solid in that it will ignite only when in large amounts (kilograms) and after long
periods of time (hours or days).
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Self-heating of a substance or mixture is a process where the gradual reaction of that substance or
mixture with oxygen (in air) generates heat. If the rate of heat production exceeds the rate of heat
loss, then the temperature of the substance or mixture will rise which, after an induction time, may
lead to self-ignition and combustion.
Chemicals which, in contact with water, emit flammable gas

Chemicals which, in contact with water, emit flammable gases are solid or liquid chemicals which,
by interaction with water, are liable to become spontaneously flammable or to give off flammable
gases in dangerous quantities make up this category.
A chemical which, in contact with water, emits flammable gases must be classified in one of the three
categories for this class, using test N.5 in Part III, sub-section 33.4.1.4 of the UN Recommendations
on the Transport of Dangerous Goods, Manual of Tests and Criteria, Fourth Revised Edition.
Oxidizing liquids
Oxidizing liquid means a liquid which, while in itself not necessarily combustible, may, generally by
yielding oxygen, cause, or contribute to, the combustion of other material.
Oxidizing solids
Oxidizing solid means a solid which, while in itself is not necessarily combustible, may, generally by
yielding oxygen, cause, or contribute to, the combustion of other material.
Organic peroxides
Organic peroxide means a liquid or solid organic chemical which contains the bivalent -0-0- structure
and as such is considered a derivative of hydrogen peroxide, where one or both of the hydrogen
atoms have been replaced by organic radicals. The term organic peroxide includes organic peroxide
mixtures containing at least one organic peroxide.
Organic peroxides are thermally unstable chemicals, which may undergo exothermic self-accelerating
decomposition. In addition, they may have one or more of the following properties:
• Be liable to explosive decomposition,
• Burn rapidly,
• Be sensitive to impact or friction,
• React dangerously with other substances.
Chemical manufacturers and importers of organic peroxides are free to provide whatever advice they
deem appropriate in the supplementary information part of the label, or on the SDS, to guide down-
stream users for appropriate handling, as long as the advice does not conflict with the required
hazard communication information.
Corrosive to metals
A chemical which is corrosive to metals means a chemical which by chemical action will materially
damage, or even destroy, metals.
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Environmental Hazards
You may see environmental data included on the safety data sheet or on the container label, although
OSHA is not including any environmental data in the HCS. The classification for substances which
are hazardous to the aquatic environment are:
• Acute aquatic toxicity,
• Chronic aquatic toxicity,
• Potential for or actual bioaccumulation, and
• Degradation (biotic or abiotic) for organic chemi-
cals.
OSHA Defined Hazards

OSHA has also added definitions to the revised HCS for
pyrophoric gases and simple asphyxiants, and provided
guidance on how to define combustible dust for the pur-
poses of complying with the HCS.
Pyrophoric gases
OSHA has retained the definition for pyrophoric gases from the current HCS. Pyrophoric gases must
be addressed both on container labels and SDSs. As noted in Appendix C, OSHA has provided label
elements for pyrophoric gases which include the signal word “danger;″ the pictogram of the flame;
and the hazard statement, “Catches fire spontaneously if exposed to air.”
Simple asphyxiants
“Simple asphyxiants” are substances or mixtures that displace oxygen in the ambient atmosphere,
and can thus cause oxygen deprivation in exposed workers that leads to unconsciousness and
death. They are of particular concern in confined spaces.
In the final HCS, simple asphyxiants must be labeled where appropriate, and be addressed on SDSs.
OSHA has provided label elements for simple asphyxiants which include the signal word “warning”
and the hazard statement “may displace oxygen and cause rapid suffocation.” No pictogram would
be required.
Examples of asphyxiants include: nitrogen, helium, argon, propane, neon, carbon dioxide, and
methane.
OSHA believes that coverage of simple asphyxiants is very important to the HCS. Such substances
result in fatalities in the workplace, particularly in confined spaces, and users need to be warned
about their hazards effectively. OSHA is continuing to work with the UN to add this hazard to the
GHS.
Combustible dust
OSHA has not provided a definition for combustible dust to the final HCS given ongoing activities in
the specific rulemaking, as well as in the United Nations Sub-Committee of Experts on the GHS
(UN/SCEGHS).
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However, guidance is being provided through existing documents, including the Combustible Dust
National Emphasis Program Directive CPL 03-00-008, which includes an operative definition, as well
as provides information about current responsibilities in this area. In addition, there are a number of
voluntary industry consensus standards (particularly those of the NFPA) that address combustible
dust.
Combustible dust is defined as a solid material composed of distinct particles or pieces, regardless
of size, shape, or chemical composition, which presents a fire or deflagration hazard when sus-
pended in air or some other oxidizing medium over a range of concentrations.
In the final HCS, combustible dust hazards must be addressed on labels and SDSs. Label elements
are provided for combustible dust in the final HCS and include the signal word “warning” and the
hazard statement “May form combustible dust concentrations in the air.″
For chemicals in a solid form that do not present a combustible dust hazard, but may form com-
bustible dusts while being processed in normal downstream uses, the manufacturer or importer may
transmit the label to the customer at the time of the initial shipment, but the label does not need to
be included with subsequent shipments unless it changes.
This provides the needed information to downstream users on the potential hazards in the workplace,
while acknowledging that the solid metal or other materials do not present the same hazards that are
produced when these materials are processed under normal conditions of use.
OSHA has introduced this issue to the UN Sub-committee as well, but one of the problems is that
some countries’ systems are limited to supply chain requirements, and do not cover hazard com-
munication issues that arise in the workplace as a result of processing. Therefore, discussions con-
tinue, but the Sub-committee will not resolve this for at least two years.
Hazards Not Otherwise Classified (HNOC)

“Hazard not otherwise classified (HNOC)” means an adverse physical or health effect identified
through evaluation of scientific evidence during the classification process that does not meet the
specified criteria for the physical and health hazard classes addressed in this section.
This definition requires classifiers who find “scientific evidence” that a chemical can cause death,
illness, or injury to workers in a way not currently covered by the GHS classification criteria to dis-
close that fact on the SDS.
OSHA included this definition (HNOC) to preserve existing safeguards under requirements of the
HCS for chemical manufacturers and importers to disseminate information on hazardous chemicals
to downstream employers, and for all employers to provide such information to potentially exposed
employees. Inclusion of the definition does not create new requirements.
The HNOC requirement does not extend coverage to adverse physical and health effects for which
there is a hazard class addressed in this section. Rather, it covers hazards which either fall below
the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has
not been adopted by OSHA (e.g., acute toxicity Category 5).
OSHA believes that there are likely to be few HNOC hazards outside those covered by the specific
criteria in the final rule.
The HNOC definition is designed so as to prevent the final rule from being less protective than the
current standard by picking up any hazards that might fall within the definitions of the current rule,
but might fall outside the GHS hazard classes.
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This requirement is triggered only when the classifier has objective, scientific evidence of the
hazard.
OSHA included this definition (HNOC) to preserve existing safeguards under requirements of the
HCS for chemical manufacturers and importers to disseminate information on hazardous chemicals
to downstream employers, and for all employers to provide such information to potentially exposed
employees. Inclusion of the definition does not create new requirements.
It is important to understand that the HNOC definition essentially preserves (and does not expand)
the scope of the current rule, which is not as tightly bound to specific criteria as the GHS. The HNOC
definition should be interpreted and understood with this preservative goal in mind.
It is OSHA’s intent that the HNOC classification would be an interim measure, used until harmonized
criteria for a hazard can be adopted at the UN Sub-committee level, and subsequently incorporated
into the HCS through rulemaking.
Disclosing HNOC Hazards

HNOC hazards will not be required to be disclosed on the label. However, provision of an SDS for
HNOC chemicals is required, and information regarding their hazards is to be included in Section 2,
Hazard Identification.
Chemical manufacturers and importers are expected to assess these hazards when they are con-
ducting their hazard evaluation of physical and health hazards. A new or separate evaluation is not
required.

The following hazard classification checklist will help to ensure you are in compliance with the rule:
❏ Read and understand the hazard classification requirements of the standard.
❏ If you are a chemical manufacturer or importer, you must:
• Evaluate the chemical for hazard class and category.
• Include hazard determinations for mixtures.
❏ If you are an employer, you:
• Can rely upon the classification provided by the chemical manufacturer or importer.
• Must classify mixtures created in-house.
Written Hazard Communication Program

What is the written program?
All employers who have hazardous chemicals in the workplace must develop, implement, and main-
tain a hazard communication program.
The Written Hazard Communication Program, simply put, is the written record of what your company
has done and will do to comply with the Hazard Communication Standard.
The GHS does not include provisions for a written hazard communication program, so your written
program will not directly affected by implementation of the GHS. The only changes in 1910.1200,
Hazard Communication is to align terminology, such as “material safety data sheet” with the GHS
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term “safety data sheet.” However, you will need to update your HazCom program to detail how the
company will meet the requirements for labels and other forms of hazard warnings, SDSs, and
employee training.
The written hazard communication program is intended to ensure that hazard communication in a
given workplace is coordinated and comprehensive.
Your written program will serve two purposes — communication as to exactly what you have done
to comply with this Standard to:
1. Your employees, and
2. OSHA.
What should the plan contain?

The written program must describe how your facility will meet the requirements for:
• The chemical inventory,
• Indicating who is responsible for the various aspects of the program,
• Making written materials available to employees,
• Hazard warning labels and other forms of warning,
• Identifying the hazards associated with unlabeled pipes,
• Any special hazcom situations in your workplace and how they are handled,
• Providing access to safety data sheets, and
• Training employees.
In many potentially affected establishments that do not produce SDSs, and that have few affected
chemicals or few affected employees, a very basic hazard communication program may achieve
compliance with the OSHA final rule.
If the workplace has multiple employers onsite (for example, a construction site), the rule requires
that information regarding chemical hazards and protective measures be made available to the other
employers onsite, where appropriate.
The written program need not be lengthy or complicated, but it should have enough detail to provide
the reader with a blueprint of the workplace-specific program.
You must make this written program available, upon request, to your employees, their designated
representatives, and any OSHA officials.
The only work operations that do not have to comply with the written plan requirements are labo-
ratories and work operations where employees only handle chemicals in sealed containers. They are
discussed later in this chapter.
Responsible staff
Written hazard communication programs include provisions for who in the organization is respon-
sible for implementing different parts of the program. In order to have a successful program, assign
responsibility for both the initial and ongoing HazCom program activities that have to the various staff
members. In some cases, these activities may be part of current job assignments.
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For example, site supervisors are frequently responsible for on-the-job training sessions. Early iden-
tification of the responsible employees and their involvement in developing your action plan will result
in a more effective program design. Involving affected employees also will enhance the evaluation
of the effectiveness of your program.
Chemical inventory
An employer’s program must include a list of the hazardous chemicals known to be present in the
workplace. This is basically a list of the chemicals the employer must have safety data sheets for,
and must be available to employees so they, too, can determine what chemicals should be included
under the hazard communication programs in their workplace.
The list can be maintained by work area or for the workplace as a whole.
The list must be kept by an “identity” of the chemicals which is the “product identifier” that is refer-
enced on the label and the safety data sheet. In other words, the inventory can be common names
or product names, rather than individual chemical ingredients of each product by specific chemical
identity or chemical name.
Compiling the list will also give an employer some idea of the scope of the program required for that
facility.
Remember to include any consumer products that you have determined are covered by the standard
as well as any substances you produce (such as carbon monoxide).
Sometimes people think of “chemicals” as being only liquids in containers. The HCS covers chemi-
cals in all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether they are
“contained” or not. The hazardous nature of the chemical and the potential for exposure are the
factors that determine whether a chemical is covered. If it is not hazardous, it is not covered. If there
is no potential for exposure, (e.g., the chemical is inextricably bound and cannot be released), the
regulation does not cover the chemical.
After compiling the complete list of chemicals, you should review paragraph (b) to determine if any
of the items can be eliminated from the list because they are exempted materials.
For example, food, drugs, and cosmetics brought into the workplace for employee consumption are
exempt; rubbing alcohol in the first aid kit would not be covered.
Once you have compiled as complete a list as possible of the potentially hazardous chemicals in the
workplace, the next step is to determine if you have received safety data sheets for all of them. Check
your files against the inventory you have just compiled. If any are missing, contact your supplier and
request one.
It is a good idea to document these requests, either by copy of a letter or a note regarding telephone
conversations. If you have SDSs for chemicals that are not on your list, figure out why. Maybe you
don’t use the chemical anymore. Or maybe you missed it in your survey.
As new chemicals are purchased, the list should be updated. Many companies have found it con-
venient to include on their purchase order the name and address of the person designated in their
company to receive SDSs and who will update the inventory.
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Employee exposure and medical records

You may use SDSs to comply with the requirements of 1910.1020 Access to Employee Exposure and
Medical Records, and if you do so, you must keep the SDSs for the life of the exposed employee’s
employment, plus 30 years. However, you are not required to use SDSs as your exposure
records.
As you are developing your inventory, include with the chemical identity, where in your facility the
chemical is used, the date, and any other information that will be of assistance in clearly identifying
the substance in question such as common or trade name, manufacturer’s product name, or CAS
number. This list can then be used in compliance with the provisions of 1910.1020 Access to Employee
Exposure and Medical Records.
At 1910.1020(d)(1)(ii) OSHA says “Each employee exposure record shall be preserved and main-
tained for at least thirty (30) years, except that . . . (d)(1)(ii)(B) Material safety data sheets and
paragraph (c)(5)(iv) records concerning the identity of a substance or agent need not be retained for
any specified period as long as some record of the identity (chemical name if known) of the sub-
stance or agent, where it was used, and when it was used is retained for at least thirty (30) years
. . .”
You are required to keep a record of what chemical was used, when it was used, and where in the
facility it was used. Your yearly chemical inventory lists would be one way to do that.
Safety data sheets

In addition to copies of the SDSs, you should have complete documentation covering the following
points:
1. Designation of the person responsible for obtaining/maintaining the SDSs.
2. Where the data sheets are kept in your facility, and how employees can obtain access to them.
3. The procedures employees are to follow when they discover a missing SDS.
4. The procedure you will follow when the SDS is not received at time of first shipment.
5. A list of those chemicals without SDSs and copies of request letters you have sent to manu-
facturer or supplier.
6. If you generate SDSs, the procedure for updating the SDS when new and significant health
information is found.
SUGGESTION: You may want to keep in this file any written requests from employees for copies of
SDSs, and your dated response.
Employee training
The written program should provide enough details about the employer’s plans in this area to assess
whether or not a good faith effort is being made to train employees. You should discuss the following
points in the coverage of your training program:
1. Designation of person responsible for conducting training.
2. The criteria used to determine which employees will receive training (if you are training all
employees, state this).
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3. The format of the training program that is used (audiovisual, classroom instruction, etc.). If you
give any handouts to employees, it is a good idea to include copies of them.
4. Procedure to train new employees at the time of their initial assignment.
5. Procedure to retrain all employees when a new hazard is introduced. For example, will per-
sonnel track the training and retraining, or will area supervisors?
6. How training is documented (such as a copy of a training attendance sheet signed by employ-
ees upon completion of their training, if you use such a system).
Hazards of non-routine tasks

Your written program in this section should address the following points:
1. Designation of the person responsible for ensuring labeling of in-plant containers.
2. Designation of the person responsible for ensuring labeling of shipped containers.
3. A complete description of any labeling system used, either on shipped containers or in-plant
(include samples of labels used).
4. Description of written alternatives to labeling of in-plant containers, if used (for example, putting
the label information on batch tickets for stationary process tanks, using posters for air emis-
sions).
5. Procedures to review and update label information when necessary, to ensure that labels that
fall off or become unreadable are immediately replaced.
6. A copy of posters used (if any) to inform employees about the law, or where HCS information
is located.

The following written program checklist will help to ensure you are in compliance with the rule:
❏ Read and understand the requirements for the written program.
❏ Create a list of the hazardous chemicals in each work area or for the facility as a whole.
❏ Identify the person or job title responsible for compiling the chemical inventory and keeping it
current.
❏ If you are responsible for developing SDSs, document how you made your hazard determi-
nation(s).
❏ Document who has responsibility for:
• Obtaining SDSs.
• Updating SDSs when information on them changes.
• Making sure containers in the facility are properly labeled.
• Labeling shipped containers leaving your facility.
• Conducting HazCom training.
❏ Describe in writing the workplace labeling system, if not GHS-style.
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❏ Document the information covered in the hazard communication training program.

❏ Document which employees must receive HazCom training and the method for certifying who
was trained.
❏ Document how you inform employees of the hazards involved in non-routine tasks (e.g., main-
taining a process vessel).
❏ Document how you provide access to SDSs to employees of other employers when they are
working at your plant or jobsite.
Labels and Forms of Warning

Chemical manufacturers and importers
Chemical manufacturers and importers must convey the hazard information they learn from their
evaluation to downstream employers by means of labels on containers and safety data sheets
(SDSs).
Chemical manufacturers, importers, and distributors must ensure that each container of hazardous
chemical leaving the workplace is labeled, tagged, or marked.
Where the chemical manufacturer or importer is required to label, tag, or mark the following infor-
mation must be provided:
• Product identifier;
• Signal word;
• Hazard statement(s);
• Pictogram(s);
• Precautionary statement(s); and
• Name, address, and telephone number of the chemical manufacturer, importer, or other
responsible party.
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Workplace container labels

Except as noted below, employers must ensure that each container of hazardous chemicals in the
workplace is labeled, tagged, or marked with either:
1. The label information specified in the HCS for labels on shipped containers; or,
2. Product identifier and words, pictures, symbols, or combination thereof, which provide at least
general information regarding the hazards of the chemicals, and which, in conjunction with the
other information immediately available to employees under the hazard communication pro-
gram, will provide employees with the specific information regarding the physical and health
hazards of the hazardous chemical.
Employers may choose to label workplace containers either with the same label that would
be on shipped containers for the chemical under the revised regulation, or with label
alternatives that meet the requirements for the standard.
Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard
Rating and the Hazardous Material Information System (HMIS) are permitted for workplace con-
tainers. However, the information supplied on these labels must be consistent with the revised HCS,
e.g., no conflicting hazard warnings or pictograms.
The employer must ensure that workplace labels or other forms of warning are:
• Legible;
• In English; and
• Prominently displayed on the container, or readily available in the work area throughout
each work shift.
Employers having employees who speak other languages may add the information in their language
to the material presented, as long as the information is presented in English as well.
Alternative labeling
The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other
such written materials in lieu of affixing labels to individual stationary process containers. The alter-
native labeling method must:
• Identify the containers to which it is applicable; and
• Convey the information required to appear on container labels.
Employers using alternative methods must ensure that written materials associated with alternative
labeling requirements are readily accessible to the employees in their work area throughout each
work shift.
Portable containers
The employer is not required to label portable containers into which hazardous chemicals are trans-
ferred from labeled containers, and which are intended only for the immediate use of the employee
who performs the transfer. “Immediate use” means that the hazardous chemical will be under the
control of and used only by the person who transfers it from a labeled container and only within the
work shift in which it is transferred.
For purposes of this section, drugs which are dispensed by a pharmacy to a health care provider for
direct administration to a patient are exempted from labeling.
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Safety Data Sheets

What is the SDS?
OSHA defines a Safety Data Sheet (SDS) as written or printed material concerning a hazardous
chemical that is prepared in accordance with paragraph (g) of 1910.1200.
The SDS includes information such as the properties of each chemical; the physical, health, and
environmental health hazards; protective measures; and safety precautions for handling, storing,
and transporting the chemical.
The SDS is prepared by the manufacturer and represents the manufacturer’s understanding of the
hazards of the chemical, the appropriate conditions of use, and the necessary protective measures
to be employed when using the chemical.
SDSs may be kept in any form, including operating procedures, and may be designed to cover
groups of hazardous chemicals in a work area where it may be more appropriate to address the
hazards of a process rather than individual hazardous chemicals.
The SDS must be in English, although an employer may maintain copies in other languages as
well.
When do you need an SDS?

Chemical manufacturers and importers must obtain or develop an SDS for each hazardous chemical
they produce or import.
An SDS should be produced for all substances and mixtures that meet the harmonized criteria for
physical or health hazards as defined in the HCS, and for all mixtures which contain substances that
meet the criteria for carcinogenic, toxic to reproduction or target organ systemic toxicity in concen-
trations exceeding the cut-off limits for SDS specified by the criteria for mixtures.
Employers are required to have a safety data sheet in the workplace for each hazardous chemical
which they use. Again, “use” means to package, handle, react, emit, extract, generate as a byprod-
uct, or transfer.
You should not allow employees to use any chemicals for which you have not received an SDS. The
SDS provides information needed to ensure you have implemented proper protective measures for
exposure.
Where complex mixtures have similar hazards and contents (i.e. the chemical ingredients are essen-
tially the same, but the specific composition varies from mixture to mixture), the chemical manu-
facturer, importer or employer may prepare one safety data sheet to apply to all of these similar
mixtures.
You are not required to have an SDS for Hazards Not Otherwise Classified (HNOC).
Readily accessible
OSHA requires that SDSs be “readily accessible” to all affected workers during each work shift when
they are in their work area. There can be no barriers to immediate access to SDSs. If any barriers
exist, then the employer is not complying with HCS.
Employees must have immediate access to the SDSs and be able to get information when they need
it in order for an employer to be in compliance.
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“Work area” is defined as a room or specific work place.

SDSs must be available to all workers on all shifts. Factors to consider include:
• Must employees ask a supervisor or other management representative for the SDS?
• Can the employees access the SDSs during each work shift and in each work area?
• Have employees been trained on how to access SDSs and where they are kept?
• Do employees know who they can go to if they have questions?
The employees must have access to the SDSs themselves — simply having a system where the
information can be read to them over the phone is permitted only under the mobile worksite provision,
paragraph (g)(9), when employees must travel between workplaces during the shift. In this situation,
they have access to the SDSs prior to leaving the primary worksite, and when they return, so the
telephone system is simply an emergency arrangement.
Where employees must travel between workplace during a work shift, i.e., their work is carried out
in more than one geographic location, the SDSs may be kept at the primary workplace. The employer
must ensure that employees can immediately obtain the required information in an emergency.
Electronic access to SDSs

Electronic access and other alternatives to maintaining paper copies of the SDSs are permitted as
long as no barriers to immediate employee access in each workplace are created by such options.
Employers using electronic means to supply SDSs to their employees must ensure that:
• Reliable devices are readily accessible in the workplace at all times.
• That workers are trained in the use of these devices, including specific software.
• That there is an adequate back-up system for rapid access to SDSs in the event of an
emergency, including power outages, equipment, and on-line access delays.
• In the event of medical emergencies, a copy can be immediately provided to medical
personnel. Mere transmission of the requested information orally via telephone is not accept-
able.
• Affected employees must be trained to use the computer and the software necessary to
access and print SDSs.
• The system is part of the overall hazard communication program of the workplace.
If the employee’s work area includes the area where the SDSs can be obtained, then maintaining
SDSs on a computer would be in compliance.
Employers using electronic means to supply SDSs to their employees must ensure that there is an
adequate back-up system for rapid access to SDSs in the event of an emergency, including power
outages, equipment, and on-line access delays.
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Barriers to access
In the Preamble to the final rule OSHA says that ultimately the evaluation of an adequate SDS system
will rely on the judgement of the OSHA Compliance Officer. Factors to consider when determining
if SDSs are readily accessible include:
• Are the sheets or alternative methods maintained at a location and under conditions where
employees can access them during each work shift, when they are in their work areas?
• If an electronic system is used for SDS access do employees know how to operate and
obtain information from the system?
• Was there an emergency or accident where immediate access was critical?
If using an off-site SDS management service to meet the requirements of the HCS, are SDSs readily
available to employees, either as hard copies in the workplace or through electronic means and as
long as the provisions outlined in the HCS are ensured.
Employees must be able to access hard copies of the SDSs, and in the event of medical emer-
gencies, employers must be able to immediately provide copies of SDSs to medical personnel. Mere
transmission of the requested information orally via telephone is not acceptable.
The employer maintains primary responsibility for ensuring employee access to SDSs.
Checklist for SDS compliance

❏ Read and understand the HazCom SDS requirements.
❏ If you sell hazardous chemicals, provide an SDS to each purchaser prior to sending the initial
shipment or with the initial shipment of each hazardous chemical.
❏ Have an SDS for each chemical on your chemical inventory.
❏ Obtain an SDS for those hazardous chemicals you have in-house which do not have one from
the chemical manufacturer or importer.
❏ Evaluate your SDSs for “obvious inaccuracies” such as missing information, blank fields, and
outdated forms.
❏ Make SDSs “immediately available” to your workers during each work shift when they are in
their work areas.
❏ Ensure that all SDSs are at least in English.
❏ Check that the chemical identity on the SDS matches the chemical identity on the container
label and on the chemical inventory.
❏ Have SDSs for the chemicals created in your facility, such as welding fumes, the by-products
of combustion, and carbon monoxide.
❏ Train your employees on how to read an SDS and where they can find them.
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HazCom Training
The goal of the HCS is to reduce the total incidence of chemical source illnesses and injuries.
The GHS does not include harmonized training requirements, but does recognize the important role
that training plays in hazard communication.
Training will explain and reinforce the information presented to employees through container labels
and safety data sheets, and will help them to apply this information in their workplace.
Effective training date

OSHA is requiring that employees are trained on the new label elements (e.g., pictogram and signal
words) and SDS format by December 1, 2013, even though full compliance is not required until June
1, 2015.
Prior to exposure
Employers must provide employees with effective information and training on hazardous chemicals
that can be found in their work area:
• At the time of their initial assignment, and
• Whenever a new chemical hazard the employees have not previously been trained about
is introduced into their work area.
Purpose of training
A properly conducted training program will ensure comprehension and understanding of the chemi-
cal hazards within the workplace, decreasing the possibility of occupationally-related chemical source
illnesses and injuries.
The primary source of safety information comes from container labels and safety data sheets. Train-
ing serves to further explain and reinforce the information presented to employees through the chemi-
cal container labels and SDSs.
The intent is to ensure that when employees begin to see GHS-style labels and SDSs in their work-
places, they understand how to use them and access the information effectively.
It is not sufficient to read material to the workers or simply hand them material to read. Labels and
SDSs are only useful when workers understand the information presented and are aware of the
actions they must take to avoid or minimize exposure and the occurrence of adverse effects.
OSHA does not expect that every worker will be able to recite all the information about each chemical
in the workplace. In general, the most important aspects of training under the HCS are to ensure that
employees:
• Are aware that they are exposed to hazardous chemicals;
• Know how to read and use labels and safety data sheets; and
• Follow the appropriate protective measures established by the employer.
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Effective training
OSHA requires that employers provide “effective” training.
“Effective” means that the employees must carry the knowledge from the training into their daily jobs.
For example, if asked, they should know where hazardous chemicals are present in their work area,
and should also know how to protect themselves.
Training must include the details of the hazard communication program developed by the employer,
including an explanation of the labels received on shipped containers and the workplace labeling
system used by their employer; the safety data sheets, including the order of information and how
employees can obtain and use the appropriate hazard information.
An OSHA compliance officers would talk to employees to determine if they have received training,
if they know they are exposed to hazardous chemicals, and if they know where to obtain substance
specific information on labels and SDSs.
Allowing questions
Employees must be allowed the opportunity to ask questions during training about any issues they
do not understand. You should create a climate where workers feel free to ask questions. This will
help you to ensure that the information is understood.
Training sessions serve another important purpose — they provide a forum for employees to share
their health and safety concerns, and to obtain answers from managers and occupational health and
safety professionals.
Employees can also share their ideas and job experiences — they often have acquired real expertise
in dealing with potentially hazardous situations.
The employee training plan must consist of the following elements:
• The requirements of this section;
• Any operations in their work area where hazardous chemicals are present; and
• The location and availability of the written hazard communication program, including the
required list(s) of hazardous chemicals, and safety data sheets required by this section.
Who must be trained?

Employers must establish a training and information program for employees who are exposed to
hazardous chemicals in their work area. Remember it is better to train too many people rather than
too few. If you have some employees who are occasionally in an area where chemicals are stored
or used, and you are undecided whether they are “exposed,” include them in your training program.
“Exposure” or “exposed” means that “an employee is subjected to a hazardous chemical in the
course of employment through any route of entry (inhalation, ingestion, skin contact or absorption,
etc.) and includes potential (e.g., accidental or possible) exposure.”
Office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated
instances are not covered.
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Training temps/contract employees

Temporary or contract employees must also have hazcom training. The employment agency and the
host employer have a shared responsibility to ensure that contract employees are protected from
workplace hazards.
The employment agency has the primary responsibility under the OSH Act to provide the training and
information required by HazCom. The contracting employer is responsible for providing site-specific
training and would have the primary responsibility to control potential exposure conditions.
What training must include

The most important aspects of training under the HCS is to ensure that employees are aware that
they are exposed to hazardous chemicals.
Information and training may be designed to cover categories of hazards (e.g., flammability, carci-
nogenicity) or specific chemicals. Chemical-specific information must always be available through
labels and safety data sheets.
Employees must understand:
• Methods and observations that may be used to detect the presence or release of a haz-
ardous chemical in the work area (such as monitoring conducted by the employer, con-
tinuous monitoring devices, visual appearance or odor of hazardous chemicals when being
released, etc.);
• The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards,
as well as hazards not otherwise classified, of the chemicals in the work area;
• The measures employees can take to protect themselves from these hazards, including
specific procedures the employer has implemented to protect employees from exposure
to hazardous chemicals, such as appropriate work practices, emergency procedures, and
personal protective equipment to be used; and
• The details of the hazard communication program developed by the employer, including:
– An explanation of the labels received on shipped containers;
– The workplace labeling system used, if different;
– The safety data sheet, including the order of information;
– Where employees can find SDSs in their work areas;
– Where employees can find a copy of the written HazCom program; and
– Who employees can go to with any HazCom questions.
Information and training may be done either by individual chemical, or by categories of hazards (such
as flammability or carcinogenicity). If there are only a few chemicals in the workplace, then you may
want to discuss each one individually. Where there are a large number of chemicals, or the chemicals
change frequently, you will probably want to train generally based on the hazard categories (e.g.,
flammable liquids, corrosive materials, carcinogens).
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Focus on the specific chemical hazards in the workplace. Explain:

• How to detect the presence or release of the chemical;
• The visual appearance or odor when the chemical is being released;
• How any monitoring devices work and what they indicate; and
• The physical and health effects of the chemicals, and what first aid measures should be
used in the event of exposure or overexposure, and where on the SDS this information can
be found.
Do not overload the employees with chemical terminology. They should understand where infor-
mation is located, and what information is of importance to them.
OSHA does not expect that every worker will be able to recite all the information about each chemical
in the workplace. In general, the most important aspects of training under the HCS are to ensure that
employees are aware that they are exposed to hazardous chemicals, that they know how to read and
use labels and safety data sheets, and that, as a consequence of learning this information, they are
following the appropriate protective measures established by the employer.
OSHA compliance officers will talk to employees to determine if they have received training, if they
know they are exposed to hazardous chemicals, and if they know where to obtain substance-specific
information on labels and SDSs.
Workplace-specific chemical training

Discuss the company’s written program with employees, and explain who they can contact if they
wish to review a copy.
Show the employees where the SDSs are kept in their work area. Remember, during an inspection
OSHA will ask employees if they know where to find the SDSs. You want them to be able to answer
that question.
In addition to training employees on how to access SDSs, you must teach employees how to read
them. Explain the relevant categories on the SDS, what kind of information is found in those sections,
what some of the terms mean.
Also, if you make SDSs available to employees to share with their doctors, explain how employees
can request copies of the pertinent SDSs.
An employer can provide employees information and training through whatever means found appro-
priate and protective. There would always have to be some training onsite (such as informing employ-
ees of the location and availability of the written program and SDSs).
However, employee training may be satisfied in part by general training about the requirements of
the HCS and about chemical hazards on the job, which is provided by, for example, trade associa-
tions, unions, colleges, and professional schools. In addition, previous training, education, and expe-
rience of a worker may relieve the employer of some of the burdens of information and training that
worker.
Regardless of the method relied upon, however, the employer is always ultimately responsible for
ensuring that employees are adequately trained.
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Refresher training
OSHA has no requirement on how often employees must be retrained, therefore, refresher training
is not mandated. Refresher training can help remind employees of hazards and how to avoid them.
The HazCom Standard does not specify any retraining requirements. Therefore, refresher training
is not mandated.
However, OSHA requires that your workers “be trained,” meaning that they know about the hazards
of the chemicals they work with. So, realistically, can you provide training once and assume two or
three years later that your employees are still “trained”?
You should retrain when you find that employees are no longer retaining their hazard communication
knowledge and skills.
That is why OSHA suggests setting up a system for periodic review and retraining on hazcom topics.
You may find that you need to retrain frequently to maintain the effectiveness of the program.
Retraining needs are often misunderstood—some employers think that they have to repeat the entire
hazard communication training program. This may not be the case. Your evaluation results will be
helpful in determining exactly how much retraining is needed.
If you can document through evaluation measures that some or most knowledge and skill concepts
have been retained, then there is no need to repeat those parts of the hazard communication training
program.
For example, if employees can tell you where the hazard communication written program is located,
there is no need to repeat the information. Similarly, if they can satisfy your objectives that they know
“methods and observations” that may be used to detect the presence or release of a hazardous
chemical in the work area, there is no need to repeat the training program.
This means that you have to keep following up on, and documenting, the effectiveness of the training
program by observing employees on the job and reminding them about what they have learned.
Employer is responsible
Ultimately the employer is responsible for providing training. However, the HCS states that so long
as training is adequate, that training may be provided by:
• The current employer,
• A past employer,
• An employee union, or
• Any other entity.
If OSHA determines that an employee has not received training or is not adequately trained, the
current employer will be held responsible regardless of who trained that particular employee.
The employer has a responsibility when hiring a new employee who has been previously trained by
someone other than the current employer to evaluate the employee’s level of knowledge against the
training and information requirements of the standard.
Employee training may be satisfied in part by general training about the requirements of the standard
which is provided by, for example, trade associations, unions, trade schools, and colleges. Training,
education, and experience provided by a previous employer may relieve an employer of some of the
burdens of training that worker.
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It is always the responsibility of the current employer to ensure employees are properly trained.
Temporary or contract employees must also have HazCom training. The host employer is respon-
sible for providing site-specific training and would have the primary responsibility to control potential
exposure conditions.
Who can train?

OSHA does not specify who may do the training. Whoever does the chemical-specific training should
be familiar with the safe handling requirements of those chemicals. The employer may determine
who is qualified to do training at the facility.
Written program
When reviewing your written program regarding information and training, consider the following
items:
• Designation of person(s) responsible for conducting training;
• Format of the program used (audiovisuals, classroom instruction);
• Elements of the training programs (should be consistent with the elements in paragraph
(h) of the HCS); and
• Procedure to train new employees at the time of their initial assignment to work with a
hazardous chemical, and to train employees when introducing a new hazard into the work-
place.
Documentation
The rule does not require employers to maintain records of employee training, but many employers
choose to do so. This may help you monitor your own program to ensure that you have trained all
employees appropriately. By keeping training records the employer can ensure that all employees
have receive appropriate and timely training as needed.
Checklist for training compliance

❏ Read and understand the training requirements in the standard.
❏ Determine who must be trained, based on actual or potential exposure to chemicals.
❏ Ensure that the person who will do the training is competent and knowledgeable.
❏ Gather the necessary information, e.g., copy of the standard, SDSs, labels, chemical inventory,
vendor instructions, sample PPE, chemical dictionary, wallet cards, and employee handbooks.
❏ Determine if you will do training area by area or company-wide.
❏ Decide if you will train on each individual chemical, or group the chemicals based on shared
hazards, i.e., solvents, flammables, compressed gases.
❏ Have a system for offering refresher training as required.
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❏ Make sure your training program:

❏ Allows opportunity for employees to ask questions.
❏ Includes training on how to read and understand labels.
❏ Includes information on how to locate the SDSs, chemical inventory, and the written pro-
gram.
❏ Includes instructions on what to do with an unlabeled container.
❏ Includes instructions on what to do when no SDS can be found.
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Medical Services and First Aid — Part 1926.50

Page
Medical Services and First Aid .................................................................................3

What Do the Regulations Require? ......................................................................3
On-Site Medical Treatment ................................................................................3
The Regulations .............................................................................................4
First Aid Supplies ............................................................................................4
Automated External Defibrillators .........................................................................5
Fundamentals of a Workplace First-Aid Program...........................................................5
Assess the Risks and Design a First-Aid Program Specific for the Worksite .....................6
OSHA Requirements ........................................................................................7
First-Aid Supplies............................................................................................7
Automated External Defibrillators .........................................................................8
First-Aid Courses ............................................................................................9
Elements of a First-Aid Training Program ...............................................................9
Trainee Assessment .......................................................................................11
There’s a New Order for CPR, Spelled C-A-B.............................................................12
Lifting Techniques: Avoiding Back Injuries ................................................................12A
Why Back Pain Happens ...............................................................................12A
Basics of Good Lifting.....................................................................................13
Planning Ahead.............................................................................................14
When a Serious Backache Happens ...................................................................15
Work at Working Safely ...................................................................................15
OSHA Fact Sheets .............................................................................................16
Working Outdoors..........................................................................................16
OSHA Letters of Interpretation ...............................................................................18
Bloodborne Pathogens in Construction ................................................................18
Medical Services ...........................................................................................20
MEDICAL & FIRST AID–1

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Reserved

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Medical Services and First Aid

What do the regulations require?
If you are a construction employer, there are requirements for medical services and first aid at your
jobsites. The requirements include:
• The availability of medical personnel for advice and consultation on matters of occupa-
tional health.
• Making provisions prior to the start of the construction project for prompt medical attention
in case of serious injury.
• Having an infirmary, clinic, hospital, or physician that is reasonably accessible in terms of
time and distance, or having someone who has a valid certificate in first aid training avail-
able to render first aid.
• Having readily available first aid supplies.
• Having available means to transport an injured person to a physician or hospital.
• Posting emergency numbers for physicians, hospitals, and ambulances in a conspicuous
location if you do not have 911 service.
These requirements can be found at 29 CFR 1926.50.
On-site medical treatment

The construction regulation for medical services and first aid at §1926.50(b), says that provisions
must be made prior to commencement of the project for prompt medical attention in case of serious
injury. The phrase “reasonably accessible” in 1926.50(c) emphasizes the desirability of prompt assis-
tance when an injury or illness occurs. If you’ve been in the safety field long you know that this has
been interpreted to mean anything from three to fifteen minutes.
The following information from an OSHA Letter of Interpretation dated January 16, 2007, discusses
OSHA’s expectations to what “reasonably accessible” means:
The primary requirement addressed by these standards is that an employer must ensure prompt
first aid treatment for injured employees, either by providing for the availability of a trained first
aid provider at the worksite, or by ensuring that emergency treatment services are within rea-
sonable proximity of the worksite. The basic purpose of these standards is to assure that adequate
first aid is available in the critical minutes between the occurrence of an injury and the availability
of physician or hospital care for the injured employee.
One option these standards provide employers is to ensure that a member of the workforce has
been trained in first aid. This option is, for most employers, a feasible and low-cost way to
protect employees, as well putting the employer clearly in compliance with the standards. OSHA
recommends, but does not require, that every workplace include one or more employees who
are trained and certified in first aid, including CPR.
The other option for employers is to rely upon the reasonable proximity of an infirmary, clinic or
hospital. OSHA has consistently taken the view that the reasonable availability of a trained
emergency service provider, such as fire department paramedics or EMS responders, would be
equivalent to the “infirmary, clinic, or hospital” specified by the literal wording of the standards.

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Emergency medical services can be provided either on-site or by evacuating the employee to
an off-site facility in cases where that can be done safely.
However, the requirements that emergency medical services must be “reasonably accessible”
or “in near proximity to the workplace” are stated only in general terms. An employer who
contemplates relying on assistance from outside emergency responders as an alternative to
providing a first-aid-trained employee must take a number of factors into account. The employer
must take appropriate steps prior to any accident (such as making arrangements with the ser-
vice provider) to ascertain that emergency medical assistance will be promptly available when
an injury occurs. While the standards do not prescribe a number of minutes, OSHA has long
interpreted the term “near proximity” to mean that emergency care must be available within no
more than 3-4 minutes from the workplace, an interpretation that has been upheld by the Occu-
pational Safety and Health Review Commission and by federal courts.
The regulations
(a) The employer shall insure the availability of medical personnel for advice and consultation
on matters of occupational health.
(b) Provisions shall be made prior to commencement of the project for prompt medical attention
in case of serious injury.
(c) In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible in
terms of time and distance to the worksite, which is available for the treatment of injured employees,
a person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American
Red Cross, or equivalent training that can be verified by documentary evidence, shall be available
at the worksite to render first aid.
(d)(1) First aid supplies shall be easily accessible when required.
(2) The contents of the first aid kit shall be placed in a weatherproof container with individual
sealed packages for each type of item. The contents of the first-aid kit shall be checked by the
employer before being sent out on each job and at least weekly on each job to ensure that the
expended items are replaced.
(e) Proper equipment for prompt transportation of the injured person to a physician or hospital,
or a communication system for contacting necessary ambulance service, shall be provided.
(f) In areas where 911 is not available, the telephone numbers of the physicians, hospitals, or
ambulances shall be conspicuously posted.
(g) Where the eyes or body of any person may be exposed to injurious corrosive materials,
suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the
work area for immediate emergency use.
First aid supplies

First aid supplies are required to be easily accessible under paragraph 1926.50(d)(1). An example
of the minimal contents of a generic first aid kit is described in American National Standard (ANSI)
Z308.1–1978 Minimum Requirements for Industrial Unit-Type First-aid Kits. The contents of the kit
listed in the ANSI standard should be adequate for small work sites. When larger operations or
multiple operations are being conducted at the same location, employers should determine the need
for additional first aid kits at the worksite, additional types of first aid equipment and supplies and
additional quantities and types of supplies and equipment in the first aid kits.

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In a similar fashion, employers who have unique or changing first-aid needs in their workplace, may
need to enhance their first-aid kits. The employer can use the OSHA 200 log, OSHA 101’s or other
reports to identify these unique problems. Consultation from the local Fire/Rescue Department, appro-
priate medical professional, or local emergency room may be helpful to employers in these circum-
stances. By assessing the specific needs of their workplace, employers can ensure that reasonably
anticipated supplies are available. Employers should assess the specific needs of their worksite
periodically and augment the first aid kit appropriately.
If it is reasonably anticipated employees will be exposed to blood or other potentially infectious
materials while using first-aid supplies, employers should provide personal protective equipment
(PPE). Appropriate PPE includes gloves, gowns, face shields, masks, and eye protection.
Automated external defibrillators

With recent advances in technology, automated external defibrillators (AEDs) are now widely avail-
able, safe, effective, portable, and easy to use. They provide the critical and necessary treatment for
sudden cardiac arrest (SCA) caused by ventricular fibrillation, the uncoordinated beating of the heart
leading to collapse and death. Using AEDs as soon as possible after sudden cardiac arrest, within
3-4 minutes, can lead to a 60% survival rate. CPR is of value because it supports the circulation and
ventilation of the victim until an electric shock delivered by an AED can restore the fibrillating heart
to normal.
All jobsites are potential candidates for AED programs because of the possibility of SCA and the need
for timely defibrillation. Each jobsite should assess its own requirements for an AED program as part
of its first-aid response.
A number of issues should be considered in setting up a jobsite AED program:
• Physician oversight.
• Compliance with local, state, and federal regulations.
• Coordination with local EMS.
• A quality assurance program.
• A periodic review.
The OSHA website at www.osha.gov or the websites of the American College of Occupational and
Environmental Medicine at www.acoem.org, the American Heart Association at www.americanhear-
t.org, the American Red Cross at www.redcross.org, Federal Occupational Health at www.foh.dhhs-
.gov, and the National Center for Early Defibrillation at www.early-defib.org can provide additional
information about AED program development.
Fundamentals of a Workplace First-Aid Program

OSHA has a best practice for first aid titled: Fundamentals of a Workplace First-Aid Program. Excerpts
from it are shown below. You can review the entire program at: http://www.osha.gov/Publications/
OSHA3317first-aid.pdf.
First aid is emergency care provided for injury or sudden illness before emergency medical treatment
is available. The first-aid provider in the workplace is someone who is trained in the delivery of initial
medical emergency procedures, using a limited amount of equipment to perform a primary assess-
ment and intervention while awaiting arrival of emergency medical service (EMS) personnel.

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A workplace first-aid program is part of a comprehensive safety and health management system that
includes the following four essential elements:
• Management Leadership and Employee Involvement
• Worksite Analysis
• Hazard Prevention and Control
• Safety and Health Training
The purpose of this guide is to present a summary of the basic elements for a first-aid program at
the workplace. Those elements include:
• Identifying and assessing the workplace risks that have potential to cause worker injury or
illness.
• Designing and implementing a workplace first-aid program that: 1. Aims to minimize the
outcome of accidents or exposures. 2. Complies with OSHA requirements relating to first
aid. 3. Includes sufficient quantities of appropriate and readily accessible first-aid supplies
and first-aid equipment, such as bandages and automated external defibrillators. 4. Assigns
and trains first-aid providers who receive first-aid training suitable to the specific work-
place, and receive periodic refresher courses on first-aid skills and knowledge.
• Instructing all workers about the first-aid program, including what workers should do if a
coworker is injured or ill. Putting the policies and program in writing is recommended to
implement this and other program elements.
• Providing for scheduled evaluation and changing of the first-aid program to keep the pro-
gram current and applicable to emerging risks in the workplace, including regular assess-
ment of the adequacy of the first-aid training course.
This guide also includes an outline of the essential elements of safe and effective first-aid training
for the workplace as guidance to institutions teaching first-aid courses and to the consumers of these
courses.
Assess the risks and design a first-aid program specific for the worksite
Obtaining and evaluating information about the injuries, illnesses and fatalities at a worksite are
essential first steps in planning a first-aid program. Employers can use the OSHA 300 log, OSHA 301
forms, their Workers’ Compensation insurance carrier reports or other records to help identify the
first-aid needs for their businesses. For risk assessment purposes, national data for injuries, ill-
nesses and fatalities may be obtained from the Bureau of Labor Statistics (BLS) website at www.bls.gov/
iif. The annual data, beginning in 2003, are grouped by the North American Industrial Classification
System (NAICS) that assigns a numeric code for each type of work establishment. Prior to 2003, the
Standard Industrial Classification (SIC) system was used to categorize the data instead of
NAICS.
Employers should make an effort to obtain estimates of EMS response times for all permanent and
temporary locations and for all times of the day and night at which they have workers on duty. They
should use that information when planning their first-aid program. When developing a workplace
first-aid program, consultation with the local fire and rescue service or emergency medical profes-
sionals may be helpful for response time information and other program issues. Because it can be
a workplace event, SCA should be considered by employers when planning a first-aid program.

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It is advisable to put the First-Aid Program policies and procedures in writing. Policies and proce-
dures should be communicated to all employees, including those workers who may not read or speak
English. Language barriers should be addressed both in instructing employees on first-aid policies
and procedures and when designating individuals who will receive first-aid training and become the
on-site first-aid providers.
OSHA requirements
Sudden injuries or illnesses, some of which may be life-threatening, occur at work. The OSHA First
Aid standard (29 CFR 1910.151) requires trained first-aid providers at all workplaces of any size if
there is no “infirmary, clinic, or hospital in near proximity to the workplace which is used for the
treatment of all injured employees.”
In addition to first-aid requirements of 29 CFR 1910.151, several OSHA standards also require
training in cardiopulmonary resuscitation (CPR) because sudden cardiac arrest from asphyxiation,
electrocution, or exertion may occur. CPR may keep the victim alive until EMS arrives to provide the
next level of medical care. However, survival from this kind of care is low, only 5-7 percent, according
to the American Heart Association. The OSHA standards requiring CPR training are:
• 1910.146 Permit-required Confined Spaces
• 1910.266 Appendix B: Logging Operations – First-Aid and CPR Training
• 1910.269 Electric Power Generation, Transmission, and Distribution
• 1910.410 Qualifications of Dive Team
• 1926.950 Construction Subpart V, Power Transmission and Distribution
If an employee is expected to render first aid as part of his or her job duties, the employee is covered
by the requirements of the Occupational Exposure to Bloodborne Pathogens standard (29 CFR
1910.1030). This standard includes specific training requirements.
A few of the medical emergency procedures mentioned in this guide as first aid may be considered
medical treatment for OSHA recordkeeping purposes. The OSHA Recording and Reporting Occu-
pational Injuries and Illnesses regulation (29 CFR 1904) provides specific definitions of first aid and
medical treatment. If a medical emergency procedure which is considered by 29 CFR 1904 to be
medical treatment is performed on an employee with an occupational injury or illness, then the injury
or illness will be regarded as recordable on the OSHA 300 Log.
First-aid supplies
It is advisable for the employer to give a specific person the responsibility for choosing the types and
amounts of first-aid supplies and for maintaining these supplies. The supplies must be adequate,
should reflect the kinds of injuries that occur, and must be stored in an area where they are readily
available for emergency access. An automated external defibrillator (AED) should be considered
when selecting first-aid supplies and equipment.
A specific example of the minimal contents of a workplace first aid kit is described in American
National Standards Institute ANSI Z308.1 - 2003, Minimum Requirements for Workplace First Aid
Kits. The kits described are suitable for small businesses. For large operations, employers should
determine how many first-aid kits are needed, and if it is appropriate to augment the kits with addi-
tional first-aid equipment and supplies.

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Employers who have unique or changing first-aid needs should consider upgrading their first-aid kits.
The employer can use the OSHA 300 log, OSHA 301 reports or other records to identify the first-aid
supply needs of their worksite. Consultation with the local fire and rescue service or emergency
medical professionals may be beneficial. By assessing the specific needs of their workplaces, employ-
ers can ensure the availability of adequate first-aid supplies. Employers should periodically reassess
the demand for these supplies and adjust their inventories.
Automated external defibrillators

With recent advances in technology, automated external defibrillators (AEDs) are now widely avail-
able, safe, effective, portable, and easy to use. They provide the critical and necessary treatment for
sudden cardiac arrest (SCA) caused by ventricular fibrillation, the uncoordinated beating of the heart
leading to collapse and death. Using AEDs as soon as possible after sudden cardiac arrest, within
3-4 minutes, can lead to a 60 percent survival rate. CPR is of value because it supports the circulation
and ventilation of the victim until an electric shock delivered by an AED can restore the fibrillating
heart to normal.
All worksites are potential candidates for AED programs because of the possibility of SCA and the
need for timely defibrillation. Each workplace should assess its own requirements for an AED pro-
gram as part of its first-aid response. A number of issues should be considered in setting up a
worksite AED program:
• physician oversight;
• compliance with local, state and federal regulations;
• coordination with local EMS;
• a quality assurance program; and
• a periodic review, among others.

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The OSHA website at www.osha.gov or the websites of the American College of Occupational and
Environmental Medicine at www.acoem.org, the American Heart Association at www.americanheart.
org, the American Red Cross at www.redcross.org, Federal Occupational Health at www.foh.dhhs.
gov, and the National Center for Early Defibrillation at www.early-defib.org can provide additional
information about AED program development.
First-aid courses
Training for first aid is offered by the American Heart Association, the American Red Cross, the
National Safety Council, and other nationally recognized and private educational organizations. OSHA
does not teach first-aid courses or certify first-aid training courses for instructors or trainees. First-aid
courses should be individualized to the needs of the workplace. Some of the noted program elements
may be optional for a particular plant or facility. On the other hand, unique conditions at a specific
worksite may necessitate the addition of customized elements to a first-aid training program.
Elements of a first-aid training program

There are a number of elements to include when planning a firstaid training program for a particular
workplace. These recommendations are based on the best practices and evidence available at the
time this guide was written. Statistical information is available from BLS to help assess the risks for
specific types of work. Program elements to be considered are:
1. Teaching Methods
Training programs should incorporate the following principles:
• Basing the curriculum on a consensus of scientific evidence where available;
• Having trainees develop “hands-on” skills through the use of mannequins and partner
practice;
• Having appropriate first-aid supplies and equipment available;
• Exposing trainees to acute injury and illness settings as well as to the appropriate re-
sponse through the use of visual aids;
• Including a course information resource for reference both during and after training;
• Allowing enough time for emphasis on commonly occurring situations;
• Emphasizing skills training and confidence-building over classroom lectures;
• Emphasizing quick response to first-aid situations.
2. Preparing to Respond to a Health Emergency
The training program should include instruction or discussion in the following:
• Prevention as a strategy in reducing fatalities, illnesses and injuries;
• Interacting with the local EMS system;
• Maintaining a current list of emergency telephone numbers (police, fire, ambulance, poi-
son control) accessible by all employees;
• Understanding the legal aspects of providing first-aid care, including Good Samaritan
legislation, consent, abandonment, negligence, assault and battery, State laws and regu-
lations;

2/08
• Understanding the effects of stress, fear of infection, panic; how they interfere with per-
formance; and what to do to overcome these barriers to action;
• Learning the importance of universal precautions and body substance isolation to provide
protection from bloodborne pathogens and other potentially infectious materials. Learning
about personal protective equipment — gloves, eye protection, masks, and respiratory
barrier devices. Appropriate management and disposal of blood-contaminated sharps and
surfaces, and awareness of OSHA’s Bloodborne Pathogens standard.
3. Assessing the scene and the victim(s)
The training program should include instruction in the following:
• Assessing the scene for safety, number of injured, and nature of the event;
• Assessing the toxic potential of the environment and the need for respiratory protection;
• Establishing the presence of a confined space and the need for respiratory protection and
specialized training to perform a rescue;
• Prioritizing care when there are several injured;
• Assessing each victim for responsiveness, airway patency (blockage), breathing, circu-
lation, and medical alert tags;
• Taking a victim’s history at the scene, including determining the mechanism of injury;
• Performing a logical head-to-toe check for injuries;
• Stressing the need to continuously monitor the victim;
• Emphasizing early activation of EMS;
• Indications for and methods of safely moving and rescuing victims;
• Repositioning ill/injured victims to prevent further injury.
4. Responding to life-threatening emergencies
The training program should be designed or adapted for the specific worksite and may include
first-aid instruction in the following:
• Establishing responsiveness;
• Establishing and maintaining an open and clear airway;
• Performing rescue breathing;
• Treating airway obstruction in a conscious victim;
• Performing CPR;
• Using an AED;
• Recognizing the signs and symptoms of shock and providing first aid for shock due to
illness or injury;
• Assessing and treating a victim who has an unexplained change in level of consciousness
or sudden illness;
• Controlling bleeding with direct pressure;
• Poisoning — Ingested poisons: alkali, acid, and systemic poisons. Role of the Poison
Control Center (1-800-222-1222); Inhaled poisons: carbon monoxide; hydrogen sulfide;

2/08
smoke; and other chemical fumes, vapors, and gases. Assessing the toxic potential of the
environment and the need for respirators; knowledge of the chemicals at the worksite and
of first aid and treatment for inhalation or ingestion; effects of alcohol and illicit drugs so
that the first-aid provider can recognize the physiologic and behavioral effects of these
substances.
• Recognizing asphyxiation and the danger of entering a confined space without appropriate
respiratory protection. Additional training is required if first-aid personnel will assist in the
rescue from the confined space.
• Responding to medical emergencies; chest pain; stroke; breathing problems; anaphylactic
reaction; hypoglycemia in diabetics taking insulin; seizures; pregnancy complications; ab-
dominal injury; reduced level of consciousness; impaled object.
5. Responding to Non-Life-Threatening Emergencies
The training program should be designed for the specific worksite and include first-aid instruction for
the management of the following:
• Wounds — Assessment and first aid for wounds including abrasions, cuts, lacerations,
punctures, avulsions, amputations and crush injuries; principles of wound care, including
infection precautions; principles of body substance isolation, universal precautions and
use of personal protective equipment.
• Burns — Assessing the severity of a burn; recognizing whether a burn is thermal, electrical,
or chemical and the appropriate first aid; reviewing corrosive chemicals at a specific work-
site, along with appropriate first aid.
• Temperature Extremes — Exposure to cold, including frostbite and hypothermia; exposure
to heat, including heat cramps, heat exhaustion and heat stroke.
• Musculoskeletal Injuries — Fractures; sprains, strains, contusions and cramps; head, neck,
back and spinal injuries; appropriate handling of amputated body parts.
• Eye injuries — First aid for eye injuries; first aid for chemical burns.
• Mouth and Teeth Injuries — Oral injuries; lip and tongue injuries; broken and missing teeth;
the importance of preventing aspiration of blood and/or teeth.
• Bites and Stings — Human and animal bites; bites and stings from insects; instruction in
first-aid treatment of anaphylactic shock.
Trainee assessment
Assessment of successful completion of the first-aid training program should include instructor ob-
servation of acquired skills and written performance assessments.
Skills update
First-aid responders may have long intervals between learning and using CPR and AED skills. Nu-
merous studies have shown a retention rate of 6-12 months of these critical skills. The American
Heart Association’s Emergency Cardiovascular Care Committee encourages skills review and prac-
tice sessions at least every 6 months for CPR and AED skills. Instructor-led retraining for lifethreat-
ening emergencies should occur at least annually. Retraining for non-life-threatening response should
occur periodically.

2/11
Program update
The first-aid program should be reviewed periodically to determine if it continues to address the
needs of the specific workplace. Training, supplies, equipment and first-aid policies should be added
or modified to account for changes in workplace safety and health hazards, worksite locations and
worker schedules since the last program review. The first-aid training program should be kept up-
todate with current first-aid techniques and knowledge. Outdated training and reference materials
should be replaced or removed.
There’s a New Order for CPR, Spelled C-A-B

The American Heart Association is re-arranging the ABCs of cardiopulmonary resuscitation (CPR)
in its 2010 American Heart Association Guidelines for Cardiopulmonary Resuscitation and Emer-
gency Cardiovascular Care. Previously, the association recommended that lay and professional
rescuers use the A-B-Cs (Airway-Breathing-Compressions) of CPR to revive victims of sudden car-
diac arrest. Now, chest compressions are recommended as the first step, followed by airway and
breathing or C-A-B for short.
“For more than 40 years, CPR training has emphasized the ABCs of CPR, which instructed people
to open a victim’s airway by tilting their head back, pinching the nose and breathing into the victim’s
mouth, and only then giving chest compressions,” said Michael Sayre, M.D., co-author of the guide-
lines and chairman of the American Heart Association’s Emergency Cardiovascular Care (ECC)
Committee. “This approach was causing significant delays in starting chest compressions, which are
essential for keeping oxygen-rich blood circulating through the body. Changing the sequence from
A-B-C to C-A-B for adults and children allows all rescuers to begin chest compressions right away.”
In previous guidelines, the association recommended looking, listening, and feeling for normal breath-
ing before starting CPR. Now, compressions should be started immediately on anyone who is un-
responsive and not breathing normally.
All victims in cardiac arrest need chest compressions. In the first few minutes of a cardiac arrest,
victims will have oxygen remaining in their lungs and bloodstream, so starting CPR with chest com-
pressions can pump that blood to the victim’s brain and heart sooner. Research shows that rescuers
who started CPR with opening the airway took 30 critical seconds longer to begin chest compres-
sions than rescuers who began CPR with chest compressions.
The change in the CPR sequence applies to adults, children and infants, but excludes newborns.
Other recommendations, based mainly on research published since the last AHA resuscitation guide-
lines in 2005:
• During CPR, rescuers should give chest compressions a little faster, at a rate of at least
100 times a minute.
• Rescuers should push deeper on the chest, compressing at least two inches in adults and
children and 1.5 inches in infants.
• Between each compression, rescuers should avoid leaning on the chest to allow it to return
to its starting position.
• Rescuers should avoid stopping chest compressions and avoid excessive ventilation.
• All 9-1-1 centers should assertively provide instructions over the telephone to get chest
compressions started when cardiac arrest is suspected.

2/11
Lifting Techniques: Avoiding Back Injuries

Although lower back pain can result from acquired conditions at birth, or from infections or tumors,
the most common cause is sprains and strains. Employees can injure their back by improper lifting
of moderate to heavy objects, falling, auto accidents, and sports activities. But of these, lifting im-
properly is the largest single cause of back pain and injury. You can help employees prevent back
injury and pain by knowing and using proper lifting techniques yourself and teaching them to your
employees.
Problems with the lower back are a frequent cause of lost work time and compensation. A 1994
Bureau of Labor Statistics report said that nearly 400,000 injuries, (17 percent of all occupational
injuries or illnesses) were caused from overexertion in lifting. Not only does construction lose, but you
and employees lose when they are laid up for weeks, unable to stay active.
Although our backs hold up well, our lifestyles and activities can lead to back pain and injury. Here
are some things that can go wrong:
• Strains and sprains can result from injury to muscles and ligaments that support the back.
A torn ligament will result in severe back pain.
• Ruptured or slipped disk is not uncommon and occurs when the disk presses on a nerve.
• Chronic tension or stress can result in muscle spasms and aggravate persistent and
painful backache.
• Other conditions such as pain “referred to the back” from other organs, such as the
kidneys and prostate, can result in nagging back pain.
Why back pain happens

Poor techniques is the main concern when lifting, but other factors can contribute to the problem.
They are:
Poor posture
Whether standing, sitting, or reclining, posture affects the amount of strain put on the back. The
wrong posture increases strain on the back muscles and may bend the spine into positions that will
cause trouble. When standing correctly, the spine has a natural “S” curve. The shoulders are back
and the “S” curve is directly over the pelvis.
Good sitting posture should put employees knees slightly higher than their hips. Hips should be to
the rear of a chair with the lower back not overly arched. Also, shoulders and upper back are should
not be rounded. Reclining posture is important, too. Sleeping should be done on a side with the knees
MEDICAL & FIRST AID–12A

2/11
Reserved
MEDICAL & FIRST AID–12B

2/11
bent or on the back. Sleeping on the stomach, especially on a sagging mattress with the head on
a thick pillow, puts too much strain on the spine. Result: morning backache.
Poor physical condition

Physical condition can also lead to back pain. Being overweight, and especially with a pot belly, can
put extra strain on the spine. An estimate is that every extra pound up front puts ten pounds of strain
on the back.
When out of shape, the chances for chronic back pain are greater. Lack of exercise is a major factor,
too. A sudden strain on generally unused back muscles leads to trouble, particularly when there is
a sudden twisting or turning of the back. Proper diet and exercise is the sensible way to help avoid
back problems.
Stress
Stress is another factor that may lead to back pain. Tied in with general physical condition, stress
created from work or play can cause muscle spasms that affect the spinal nerve network. Although
stress is part of everyone’s life, and a certain amount of stress is normal, excessive stress causes
backaches. The solution is a balanced life style, with time to relax.
Repetitive trauma
People often think back injuries result from lifting heavy or awkward objects. Many back injuries,
however, do not come from a single lift, but develop from relatively minor strains over time.
Back injuries, as with other cumulative trauma disorders (CTDs), may arise from repeated injuries.
(But, repetitive, low-grade strains usually do not cause CTDs.) As the employee repeats a particular
irritating movement, the minor injuries begin to accumulate and weaken affected muscles or ligaments.
Eventually a more serious injury may occur.
Thus, a specific weight lifted may actually have little to do with any single injury. You should provide
and employees should use mechanical aids when appropriate along with good lifting techniques.
Lifting can be done safely when performed with caution.
Basics of good lifting

Today, most heavy objects are lifted by forklifts, hoists, platforms, and other types of equipment.
However, sometimes it is necessary to load or unload by hand, moderate to heavy objects. When
that is the case, knowing the proper ways to lift can save employees a great deal of pain and misery
from a sprained back.
Size up the load before trying to lift it

Test the weight by lifting at one of the corners. If the load is too heavy or of an awkward shape, the
best thing to do is encourage your employees to: (1) get help from a fellow worker, (2) use a me-
chanical lifting device or, (3) if they must lift, they must make sure they can handle the weight.

2/08
Bend the knees

This is the single most important rule when lifting moderate to heavy objects. Take a tip from pro-
fessional weight lifters. They can lift tremendous weights because they lift with their legs, not their
backs. When lifting a crate or box employees should:
• Place their feet close to the object.
• Center themselves over the load.
• Bend the knees.
• Get a good hand hold.
• Lift straight up, smoothly.
• Allow the legs, not the back, to do the work.
Once the load is lifted:
• Do not twist or turn the body once the lift is made — keep the load close to the body, and
keep it steady. Any sudden twisting or turning could result in back injury.
• Make sure the load is carried where it needs to go before attempting to move it — also,
make sure paths are clear of obstacles and that there are no hazards, such as holes or
spilled liquids in the path. Turn the body by changing foot positions, and make sure of the
footing before setting out.
• Set the load down properly — setting the load down is just as important as lifting it. Lower
the load slowly by bending the knees, letting the legs do most of the work. Don’t let go of
the load until it is secure on the floor.
• Always push, not pull the object when possible — when moving an object on rollers, for
example, pushing puts less strain on the back and is safer, should the object tip.
Planning ahead
Planning ahead makes sense. If employees know certain loads will have to be carried from an
unloading areas, they should place the objects on racks, not on the ground, whenever possible. That
way the load will not have to be lifted from the ground. They should not attempt to carry loads that
are clearly too heavy for them. Long objects, such as pipes and lumber, may not be heavy, but the
weight might not be balanced and such lifting could also result in back sprain. Such objects should
be carried by two more people.
If the load can be split up into smaller ones, employees are better off in doing that, even if loading
takes a few extra minutes. Trying to lift it all at once or even two or three loads may be asking for
trouble when the weight is great.
When working on something low, employees should bend their knees. They should keep their backs
as straight as possible. Bending from the waist can lead to back pain. If they have to work with their
back, they should keep their knees bent and their back flat. In both of these situations, frequent rest
breaks are necessary to keep from getting back fatigue.

2/08
When a serious backache happens

With simple care and rest, most back pain goes away. However, a serious back injury or chronic back
pain will require treatment. If the pain does not go away, or is accompanied by weakness or numb-
ness in the lower limbs, employees should see a doctor. Pain that radiates from the back to the
buttocks and legs is typical of lower back disorders and is called sciatica.
When employees go to a doctor, in addition to their medical history and having a physical exam, they
may need other tests to determine the exact source of the pain.
Treatment may consist of bed rest, cold or hot packs, traction, physical therapy, or muscle-relaxing
drugs. Some treatment requires injections around the spinal nerves and, in some cases, surgery may
be necessary.
Certain jobs require long hours of standing or sitting. These conditions can create back troubles.
When in these situations, Employees should:
• Get up and stretch frequently when required to sit for long periods.
• Ease the strain on their lower back if standing by changing foot positions often, placing
one foot on a rail or ledge.
• Keep their weight evenly balanced when standing. Don’t lean to one side.
Work at working safely

By using common sense, you can help employees keep their back out of trouble. Every time they
think about lifting, they should think defensively about their back and the possibility of a back sprain.
You and your employees should follow good lifting techniques, not only at work, but also at home.
With proper exercise, a good diet, and the proper lifting techniques, their chances of being out of work
with chronic or severe back pain are greatly reduced. You should teach them to:
• Plan ahead when lifting jobs are necessary.
• Get help to lift objects that are too heavy.
• Never twist or turn suddenly while carrying a heavy load.
• Make sure their path is clear, and be careful of their footing.
• Lift with the legs, not the back.
• Be aware of proper posture when sitting, standing, or reclining.
• Follow a sensible diet and exercise program to help their back.
Following these simple rules reduces the risk of you and your employees experiencing a back injury.

2/08
OSHA Fact Sheets

Working outdoors
Hot summer months pose special hazards for outdoor workers who must protect themselves against
heat, sun exposure, and other hazards. Employers and employees should know the potential haz-
ards in their workplaces and how to manage them.
Sun
Sunlight contains ultraviolet (UV) radiation, which causes premature aging of the skin, wrinkles,
cataracts, and skin cancer. There are no safe UV rays or safe suntans. Be especially careful in the
sun if you burn easily, spend a lot of time outdoors, or have any of the following physical features:
numerous, irregular, or large moles; freckles; fair skin; or blond, red, or light brown hair. Here’s how
to block those harmful rays:
• Cover up. Wear tightly woven clothing that you can’t see through.
• Use sunscreen. A sun protection factor (SPF) of at least 15 blocks 93 percent of UV rays.
Be sure to follow application directions on the bottle or tube.
• Wear a hat. A wide brim hat, not a baseball cap, works best because it protects the neck,
ears, eyes, forehead, nose, and scalp.
• Wear UV-absorbent shades. Sunglasses don’t have to be expensive, but they should
block 99 to 100 percent of UVA and UVB radiation. Before you buy, read the product tag
or label.
• Limit exposure. UV rays are most intense between 10 a.m. and 4 p.m.
Helpful link: www.cdc.gov/chooseyourcover
Heat
The combination of heat and humidity can be a serious health threat during the summer months. If
you work at a beach resort, on a farm, or in a kitchen, laundry, or bakery, for example, you may be
at risk for heat-related illness. So, take precautions. Here’s how:
• Drink plenty of water before you get thirsty.
• Wear light, loose-fitting, breathable clothing — cotton is good.
• Take frequent short breaks in cool shade.
• Eat smaller meals before work activity.
• Avoid caffeine and alcohol or large amounts of sugar.
• Find out from your health care provider if your medications and heat don’t mix.
• Know that equipment such as respirators or work suits can increase heat stress.
Helpful links:
www.cdc.gov/elcosh/docs/d0100/d000024/d000024.html
www.cdc.gov/Features/ExtremeHeat/

2/08
Lyme disease
This illness is caused by bites from infected ticks. Most, but not all, victims will develop a bulls-eye
rash. Other signs and symptoms may be non-specific and similar to flu symptoms such as fever,
lymph node swelling, neck stiffness, generalized fatigue, headaches, migrating joint aches, or muscle
aches. You are at increased risk if your work outdoors involves construction, landscaping, forestry,
brush clearing, land surveying, farming, railroads, oil fields, utility lines, or park and wildlife management.
Protect yourself with these precautions:
• Wear light-colored clothes to see ticks more easily.
• Wear long sleeves; tuck pant legs into socks or boots.
• Wear high boots or closed shoes that cover your feet completely.
• Wear a hat.
• Use tick repellants, but not on your face.
• Shower after work. Wash and dry your work clothes at high temperature.
• Examine your body for ticks after work. Remove any attached ticks promptly with fine-
tipped tweezers. Do not use petroleum jelly, a hot match, or nail polish to remove the tick.
Helpful link: www.osha.gov/OshDoc/data_LymeFacts/lymefac.pdf
West Nile virus

Illness from the West Nile virus is rare, but it does happen. Mild symptoms include fever, headache,
and body aches, occasionally with a skin rash on the trunk of the body and swollen lymph glands.
Symptoms of severe infection include headache, high fever, neck stiffness, stupor, disorientation,
coma, tremors, convulsions, muscle weakness, and paralysis.
Getting rid of standing water in containers such as discarded tires, buckets, and barrels helps reduce
mosquito breeding areas. In addition, you can protect yourself from mosquito bites in these ways:
• Apply insect repellent with DEET to exposed skin.
• Spray clothing with repellents containing DEET or permethrin.
• Wear long sleeves, long pants, and socks.
• Be extra vigilant at dusk and dawn when mosquitoes are most active.
Helpful link: www.cdc.gov/ncidod/dvbid/westnile/index.htm

2/09
OSHA Letters of Interpretation

Bloodborne pathogens in construction
Although the construction industry was exempted from the bloodborne pathogens standard shortly
after it was issued, several OSHA documents state that the General Duty Clause will be used to
enforce the bloodborne standard in construction operations. Such coverage of construction em-
ployers, though more limited than for general industry, is more stringent than had been indicated
initially. On May 5, 1992, OSHA announced an exemption for the construction industry from the
provisions of the bloodborne pathogens standard. The more recent interpretations published by
OSHA in November 1992 requires construction employers to provide at least some protection for
workers with occupational exposure to blood or other potentially infectious material.
Coverage under the General Duty Clause is not the same as under the standard itself. Construction
employees face no requirement for an exposure control plan, the written program of the the standard.
Enforcement officers have indicated that what is expected includes basic instruction in blood-borne
hazards, as well as Hepatitis B virus vaccination and follow-up for those first aid providers in the
event of an exposure incident.
OSHA will issue citations under the General Duty Clause where there is a serious and recognized
hazard which cannot be abated by implementing an abatement method required by the standards
listed above.
01/26/1993 Bloodborne pathogens standard and the construction industry:

Standard number: 1910.1030
Dear Construction Employer:
You wrote regarding the applicability of 29 CFR 1910.1030, the Occupational Exposure to Bloodborne
Pathogens standard and the General Duty Clause of the OSH Act, to the construction industry. You
specifically inquired about the provision of the hepatitis B vaccine to employees in the construction
industry who have occupational exposure to blood or other potentially infectious materials.
In addressing the OSHA Advisory Committee of Construction Safety and Health on May 19, Dorothy L.
Strunk, Acting Assistant Secretary, informed the committee that a policy decision had been made that
the bloodborne pathogens standard does not apply to the construction industry.
While the standard does not apply to construction work, as defined in 29 CFR 1910.12(b), it does apply
to employees performing maintenance activities which involve making or keeping a structure, fixture, or
foundation in proper condition in a routine, scheduled, or anticipated fashion and who experience
occupational exposure to blood or other potentially infectious materials while performing their job.
While trades such as plumbers, pipefitters and others who, at times, may be engaged in maintenance
activities are not generally considered to have occupational exposure as defined by the standard unless
they are working in health care facilities, it is the employer’s responsibility to determine which job
classification or specific tasks and procedures involve occupational exposure. If OSHA determines, on
a case-by-case basis, that sufficient evidence of reasonably anticipated exposure exists among em-
ployees performing maintenance work, the employer will be held responsible for providing the protec-
tions of 29 CFR 1910.1030 to those employees with occupational exposure.
Those employees engaged in construction activities who are occupationally exposed to the hazard of
bloodborne pathogens (such as those workers designated as responsible for providing first aid or
medical assistance) are afforded protection under several construction standards as well as the Gen-
eral Duty Clause.

2/09

Osha 1926 Construction Manual: Checklist For Compliance

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OSHA 1926 CONSTRUCTION MANUAL

Checklist for compliance

Hazard Class and Category

• Germ cell mutagenicity,

Exposure route Category 1 Category 2 Category 3 Category 4

Serious eye damage/eye irritation

Respiratory or skin sensitization

Germ cell mutagenicity

Category 1 has two subcategories:

Specific Target Organ Toxicity — Single Exposure (STOT-SE)

Specific Target Organ Toxicity — Repeated or Prolonged Exposure (STOT-RE)

Gases under pressure

Chemicals which, in contact with water, emit flammable gas

OSHA Defined Hazards

Hazards Not Otherwise Classified (HNOC)

Disclosing HNOC Hazards

Checklist for compliance

Written Hazard Communication Program

What should the plan contain?

Employee exposure and medical records

Safety data sheets

Hazards of non-routine tasks

Checklist for compliance

❏ Document the information covered in the hazard communication training program.

Labels and Forms of Warning

Workplace container labels

Safety Data Sheets

When do you need an SDS?

“Work area” is defined as a room or specific work place.

Electronic access to SDSs

Checklist for SDS compliance

Effective training date

Who must be trained?

Training temps/contract employees

What training must include

Focus on the specific chemical hazards in the workplace. Explain:

Workplace-specific chemical training

Who can train?

Checklist for training compliance

❏ Make sure your training program:

Medical Services and First Aid — Part 1926.50

Medical Services and First Aid .................................................................................3

MEDICAL & FIRST AID–1

MEDICAL & FIRST AID–2

Medical Services and First Aid

On-site medical treatment

MEDICAL & FIRST AID–3

First aid supplies

MEDICAL & FIRST AID–4

Automated external defibrillators

Fundamentals of a Workplace First-Aid Program

MEDICAL & FIRST AID–5

MEDICAL & FIRST AID–6

MEDICAL & FIRST AID–7

Automated external defibrillators

MEDICAL & FIRST AID–8

Elements of a first-aid training program

MEDICAL & FIRST AID–9

MEDICAL & FIRST AID–10