Under the Hazard Communication Standard (29 CFR 1910.1200), an employer is required to prepare a list of the hazardous chemicals in the workplace. The list will eventually serve as an inventory for every chemical for which that the employer must have an MSDS.
The chemical list is developed using the chemical identity which is:
· referenced on the material safety data sheet (MSDS), and
· referenced on the container label.
The chemical identity is "any term which appears on the label, the MSDS, and the list of chemicals, and thus links these three sources of information.
OSHA state that the list may be compiled for the workplace as a whole or for individual work areas, but the list or lists become part of the written hazard communication plan.
Once the list is finished, compare it to the MSDSs you have in-house. If there are chemicals with no MSDSs, you must contact the distributor or manufacturer and obtain one. If there are MSDSs for chemicals not on your list, then you must find out why. Is the chemical no longer used? Or was the chemical missed during the inventory?
KOL tools can help
There are some tools in KOL that can help you with your chemical inventory. First, there is the Chemical Inventory List which is found under the Interactive Forms. It is a simple .pdf document which can be downloaded and printed, and filled in by hand.
Also, in Interactive Tools, under Chemical Programs, there is a Chemical Recordkeeping tool which can assist a user to manage in-house chemicals and print an inventory control sheet, among other things. It allows the user to identify chemicals by name and CAS number, and also note the location, work area, and status of the chemical.
Either of these can help you stay in compliance with the Hazard Communication standard's requirement for a chemical list.
For more information, visit the J.J. Keller & Associates Web site at www.jjkeller.com.
