OSHA Simplified Rule
One difference between this rule and many others adopted by OSHA is that this one is performance-oriented. That means you have the flexibility to adapt the rule to the needs of your workplace, rather than having to follow specific rigid requirements. It also means that you have to exercise more judgment to implement an appropriate and effective program.
The standard’s design is simple. Chemical manufacturers and importers must evaluate the hazards of the chemicals they produce or import. Using that information, they must then prepare labels for containers and more detailed technical bulletins called material safety data sheets (MSDS's). Chemical manufacturers, importers, and distributors of hazardous chemicals are all required to provide the appropriate labels and material safety data sheets to the employers to whom they ship the chemicals. The information must be provided automatically. Every container of hazardous chemicals you receive must be labeled, tagged, or marked with the required information. Your suppliers also must send you a properly completed MSDS at the time of the first shipment of the chemicals, and with the next shipment after the MSDS is updated with new and significant information about the hazards. You can rely on the information received from your suppliers. You have no independent duty to analyze the chemical or evaluate the hazards of it.
Employers that “use” hazardous chemicals must have a program to ensure the information is provided to exposed employees. “Use” means to package, handle, react, or transfer. This is an intentionally broad scope, and includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.
The requirements of the rule that deal specifically with the hazard communication program are:
The requirements of these paragraphs should be the focus of your attention.