Updating our labels
The employer may rely upon the hazard determination performed by the pharmaceutical manufacturer or importer.
Additional training is to be done whenever a new physical or health hazard is introduced into the work area, not a new chemical.
The substance-specific data sheet must still be available, and the product must be properly labeled.
If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where employees will be exposed.
Host employers would then be responsible for providing site-specific hazard training pursuant to sections 1910.1200(h)(1) and 1926.59.
Reference Interpretation and Compliance Letters: Can MSDSs be stored on a computer to meet the accessability requirements of HAZCOM?