What to know: According to OSHA, employers are required to train their employees in the recognition of hazards that may be encountered in their workplace. The History of OSHA’s Hazard Communications Program On Jan 16, 1981, OSHA published a notice of proposed rulemaking (NPRM) titled, “Hazards Identification.”¹ This proposed rule would have required employers to assess hazards found in their workplaces, and then ensure that the containers –including pipes containing hazardous chemicals– are properly labeled. One month later, OSHA withdrew the NPRM “for further consideration of regulatory alternatives.”² On March 19, 1982, OSHA published an updated Notice of Proposed Rulemaking that established a 60-day time period ending on May 18, 1982, that called for comments and filing of notices to appear at public hearings. This proposal required all chemical manufacturers to “assess the hazards of all chemicals which they produce, and all employers in SIC Codes 20 through 39 to establish hazard communication programs for their employees.”³ It also required labeling of in-plant and downstream containers, through the availability of Material safety Data Sheets and by employee training. OSHA noted: “The proposed standard represented OSHA’s determination that rulemaking was necessary because many employers and employees in the manufacturing division are not aware of the presence of hazardous chemicals in their workplaces. This lack of knowledge increases the risk of occupationally-related chemical source illnesses and injuries, since appropriate protective measures can only be designed and implemented when the presence of a hazard is known.”⁴ The Hazard Communications NPRM received supportive comments from groups such as the American Petroleum Institute,⁵ Gulf Oil Chemicals Company,⁶ Celanese Corporation,⁷ Shell Oil Company,⁸and Kaiser Aluminum and Chemical Corporation.⁹ Kaiser wrote: “If implemented, this standard should do more to educate the worker about potential workplace hazards than any other standard since OSHA’s inception. Educated employees make safer employees.”¹⁰ On November 25, 1983, the first iteration of the Hazard Communication Standard finally became law. Four years later, on August 24, 1987,¹¹ the standard was expanded to cover all industries where employees were exposed to hazardous chemicals, and ensured that “chemical manufacturers, importers, and distributors provide material safety data sheets with the next shipment of hazardous chemicals to non-manufacturing employers or distributors after September 23, 1987.¹²” Importantly, the OSHA Hazard Communication Standard requires employers to provide training “on hazardous chemicals 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. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets.¹³” The parts of the Hazard Communication standard that most apply to railroads are: 1. Material Safety Data Sheets 2. Labeling and Placards 3. Signs 4. Hazardous Substance Training You can find OSHA’s entire Hazard Communication Standard here.   I have included the primary sections of the Haz Com standard that may apply to Railroad work. The document most associated with the Hazard Communication Standard is the Material Safety Data Sheet.  This document, commonly called simply an “MSD” or “MSDS” should include information about the hazards associated with the material, chemical, compound or mixture.  This information will include the percentage of the material’s component chemicals.  Some Material Safety Data Sheets were available as early as the 1970s, however many of these did not include information regarding toxic components.  For example, one major petroleum company published an MSDS for gasoline in the early 1970s that had no information regarding the percentage of benzene.  MSD Sheets that are up to date will likely include a complete list of the components of the material. Material Safety Data Sheets 1910.1200(a) Purpose. 1910.1200(a)(1) The purpose of this section is to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees. The requirements of this section are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), primarily Revision 7. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets and employee training. 1910.1200(a)(2): This occupational safety and health standard is intended to address comprehensively the issue of classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, and to preempt any legislative or regulatory enactments of a state, or political subdivision of a state, pertaining to this subject. Classifying the potential hazards of chemicals and communicating information concerning hazards and appropriate protective measures to employees, may include, for example, but is not limited to, provisions for: developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces; preparation and distribution of safety data sheets to employees and downstream employers; and development and implementation of employee training programs regarding hazards of chemicals and protective measures. Under section 18 of the Act, no state or political subdivision of a state may adopt or enforce any requirement relating to the issue addressed by this Federal standard, except pursuant to a Federally-approved state plan. 1910.1200(b): This section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. Safety data sheet (SDS) means written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of this section. 1910.1200(e): Written hazard communication program. 1910.1200(e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes the following: 1910.1200(e)(1)(i): A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas); and, 1910.1200(e)(1)(ii): The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas. 1910.1200(e)(4): The employer shall make the written hazard communication program available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director, in accordance with the requirements of § 1910.1020(e). 1910.1200(e)(5): Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the written hazard communication program may be kept at the primary workplace facility. 1910.1200(f): Labels and other forms of warning – 1910.1200(f)(1): Labels on shipped containers. The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked. Hazards not otherwise classified and hazards identified and classified under (d)(1)(ii) do not have to be addressed on the container. Where the chemical manufacturer, importer, or distributor is required to label, tag or mark the following shall be provided: 1910.1200(f)(1)(i): Product identifier; 1910.1200(f)(1)(ii): Signal word; 1910.1200(f)(1)(iii): Hazard statement(s); 1910.1200(f)(1)(iv): Pictogram(s); 1910.1200(f)(1)(v): Precautionary statement(s); 1910.1200(f)(1)(vi): Name, U.S. address, and U.S. telephone number of the chemical manufacturer, importer, or other responsible party. 1910.1200(f)(2): The chemical manufacturer, importer, or distributor shall ensure that the information provided under paragraphs (f)(1)(i) through (v) of this section is in accordance with Appendix C to § 1910.1200, for each hazard class and associated hazard category for the hazardous chemical, prominently displayed, and in English (other languages may also be included if appropriate). Transportation. 1910.1200(f)(5)(i): Chemical manufacturers, importers, or distributors shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked in accordance with this section in a manner which does not conflict with the requirements of the Hazardous Materials Transportation Act (49 U.S.C. 5101 et seq.) and regulations issued under that Act by the Department of Transportation (49 CFR subtitle B). 1910.1200(f)(5)(ii): The label for bulk shipments of hazardous chemicals must be on the immediate container, transmitted with the shipping papers or the bills of lading, or, with the agreement of the receiving entity, transmitted by technological or electronic means so that it is immediately available to workers in printed form on the receiving end of shipment. 1910.1200(f)(5)(iii): Where a pictogram required by the Department of Transportation under title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in appendix C.4 to this section for the same hazard is not required on the label. 1910.1200(f)(6): Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either: 1910.1200(f)(6)(i):  The information specified under paragraphs (f)(1)(i) through (v) of this section for labels on shipped containers; or, 1910.1200(f)(6)(ii): 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 program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical. 1910.1200(f)(7): 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, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of this section to be on a label. The employer shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift. 1910.1200(f)(8): The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. 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. 1910.1200(f)(9): The employer shall not remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information. 1910.1200(f)(10): The employer shall 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. 1910.1200(f)(11): Label updates. 1910.1200(f)(11)(i): Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information. For chemicals that have been released for shipment and are awaiting future distribution, chemical manufacturers, importers, distributors, or employers have the option not to relabel those containers; however, if they do not relabel the containers, they must provide the updated label for each individual container with each shipment. 1910.1200(g): Safety data sheets. 1910.1200(g)(1): Chemical manufacturers and importers shall obtain or develop a safety data sheet for each hazardous chemical they produce or import. Employers shall have a safety data sheet in the workplace for each hazardous chemical which they use. 1910.1200(g)(2): The chemical manufacturer or importer shall ensure that the safety data sheet is in English (although the employer may maintain copies in other languages as well), and includes at least the following section numbers and headings, and associated information under each heading, in the order listed (see appendix D to this section, for the specific content of each section of the safety data sheet): 1910.1200(g)(2)(i) Section 1, Identification; 1910.1200(g)(2)(ii) Section 2, Hazard(s) identification; 1910.1200(g)(2)(iii) Section 3, Composition/information on ingredients; 1910.1200(g)(2)(iv) Section 4, First-aid measures; 1910.1200(g)(2)(v) Section 5, Fire-fighting measures; 1910.1200(g)(2)(vi) Section 6, Accidental release measures; 1910.1200(g)(2)(vii) Section 7, Handling and storage; 1910.1200(g)(2)(viii) Section 8, Exposure controls/personal protection; 1910.1200(g)(2)(ix) Section 9, Physical and chemical properties; 1910.1200(g)(2)(x) Section 10, Stability and reactivity; 1910.1200(g)(2)(xi) Section 11, Toxicological information. 1910.1200(g)(2)(xii) Section 12, Ecological information; 1910.1200(g)(2)(xiii) Section 13, Disposal considerations; 1910.1200(g)(2)(xiv) Section 14, Transport information; 1910.1200(g)(2)(xv) Section 15, Regulatory information; and 1910.1200(g)(2)(xvi) Section 16, Other information, including date of preparation or last revision. Note 1 to paragraph (g)(2): To be consistent with the GHS, an SDS must also include the headings in paragraphs (g)(2)(xii) through (g)(2)(xv) of this section in order. Note 2 to paragraph (g)(2): OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction. 1910.1200(g)(3) If no relevant information is found for any sub-heading within a section on the safety data sheet, the chemical manufacturer, importer or employer preparing the safety data sheet shall mark it to indicate that no applicable information was found. 1910.1200(g)(4) Where complex mixtures have similar hazards and contents (i.e., the chemical ingredients are essentially the same, but the specific composition varies from mixture to mixture), the chemical manufacturer, importer or employer may prepare one safety data sheet to apply to all of these similar mixtures. 1910.1200(g)(5) The chemical manufacturer, importer or employer preparing the safety data sheet shall ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification. If the chemical manufacturer, importer or employer preparing the safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the safety data sheet within three months. If the chemical is not currently being produced or imported, the chemical manufacturer or importer shall add the information to the safety data sheet before the chemical is introduced into the workplace again. 1910.1200(g)(6) 1910.1200(g)(6)(i) Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated; 1910.1200(g)(6)(ii)  The chemical manufacturer or importer shall either provide safety data sheets with the shipped containers or send them to the distributor or employer prior to or at the time of the shipment; 1910.1200(g)(6)(iii)  If the safety data sheet is not provided with a shipment that has been labeled as a hazardous chemical, the distributor or employer shall obtain one from the chemical manufacturer or importer as soon as possible; and, 1910.1200(g)(6)(iv) The chemical manufacturer or importer shall also provide distributors or employers with a safety data sheet upon request. 1910.1200(g)(7) 1910.1200(g)(7)(i)  Distributors shall ensure that safety data sheets, and updated information, are provided to other distributors and employers with their initial shipment and with the first shipment after a safety data sheet is updated; 1910.1200(g)(7)(ii)  The distributor shall either provide safety data sheets with the shipped containers, or send them to the other distributor or employer prior to or at the time of the shipment; 1910.1200(g)(7)(iii)  Retail distributors selling hazardous chemicals to employers having a commercial account shall provide a safety data sheet to such employers upon request, and shall post a sign or otherwise inform them that a safety data sheet is available; 1910.1200(g)(7)(iv)Wholesale distributors selling hazardous chemicals to employers over-the-counter may also provide safety data sheets upon the request of the employer at the time of the over-the-counter purchase, and shall post a sign or otherwise inform such employers that a safety data sheet is available; 1910.1200(g)(7)(v) If an employer without a commercial account purchases a hazardous chemical from a retail distributor not required to have safety data sheets on file (i.e., the retail distributor does not have commercial accounts and does not use the materials), the retail distributor shall provide the employer, upon request, with the name, address, and telephone number of the chemical manufacturer, importer, or distributor from which a safety data sheet can be obtained; 1910.1200(g)(7)(vi)  Wholesale distributors shall also provide safety data sheets to employers or other distributors upon request; and, 1910.1200(g)(7)(vii)  Chemical manufacturers, importers, and distributors need not provide safety data sheets to retail distributors that have informed them that the retail distributor does not sell the product to commercial accounts or open the sealed container to use it in their own workplaces. 1910.1200(g)(8)  The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.) 1910.1200(g)(9)  Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency. 1910.1200(g)(10)  Safety data sheets may be kept in any form, including as operating procedures, and may be stored in such a way 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. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in their work area(s). 1910.1200(g)(11)  Safety data sheets shall also be made readily available, upon request, to designated representatives, the Assistant Secretary, and the Director, in accordance with the requirements of § 1910.1020(e). 1910.1200(h) Employee information and training. 1910.1200(h)(1)  Employers shall provide employees with effective information and training on hazardous chemicals 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. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets. 1910.1200(h)(2) Information. Employees shall be informed of: 1910.1200(h)(2)(i)  The requirements of this section; 1910.1200(h)(2)(ii)  Any operations in their work area where hazardous chemicals are present; and, 1910.1200(h)(2)(iii)  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. 1910.1200(h)(3)  Training. Employee training shall include at least: 1910.1200(h)(3)(i)  Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.); 1910.1200(h)(3)(ii)  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; 1910.1200(h)(3)(iii)  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, 1910.1200(h)(3)(iv)  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 sheet, including the order of information and how employees can obtain and use the appropriate hazard information. 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