HAZCOM COMPLIANCE CHECKLIST 


HAZARD DETERMINATION, 5194(d)  

     Have manufacturers evaluated all substances produced in their
     workplace, have importers evaluated all substances imported by
     them, and have employers evaluated all substances used by them
     (if they choose not to rely on the manufacturer's or
     importer's evaluation) to determine if they are hazardous,
     (d)(1)?

     Has available scientific evidence been used to evaluate
     substances, (d)(2)?

     Are substances listed in the Director's List of Hazardous
     Substances, have an OSHA PEL, or an ACGIH TLV, (d)(3)?

     Have substances on NTP, IARC, or OSHA carcinogen sources lists
     been treated as a carcinogens or a potential carcinogen and
     identified as such, (d)(4)(A) through (C)?

     If a mixture has not been tested as a whole for health
     hazards, are all the health hazards for each hazardous
     ingredient listed, (d)(5)(B)?

WRITTEN HAZARD COMMUNICATION PROGRAM (HCP), 5194(e)

     Does the HCP specify who is responsible for hazard
     determination, a plan for initial evaluation of all substances
     and the sources used to make the hazard determination, (e)(1)?

     Does the HCP include a list of hazardous substances known to
     be present in the workplace, (e)(1)(A)?

     Does the HCP include the methods the employer will use to
     inform employees of the hazards of non-routine tasks and the
     hazards associated with unlabeled pipes, (e)(1)(B)?

     Does the HCP include methods employer will use to provide
     other employers with access to the MSDS for each hazardous
     substance the other employer's employees may be exposed to,
     (e)(2)(A), with any information about precautionary measures
     to protect employees, e)(2)(B), and information about the
     labeling system used in the workplace, (e)(2)(C)?

     Is the written HCP available upon request to employees, their
     designated representatives, the Chief and NIOSH?
     
     Does the HCP include a description of how in-plant labeling
     will be accomplished, who is responsible for making and
     maintaining labels, a description of labeling system used and
     a description of an alternative written system, (e)(1)?

     Does the HCP include a description of how MSDS requirements
     will be met and who is responsible for MSDS program, (g)(1)?

     Does the HCP include a description of how MSDSs will be
     obtained and kept for every product used, how MSDSs will be
     made accessible to employees on request, how MSDS will be
     checked for accuracy, and how missing MSDSs are requested in
     writing from vendor, (g)(1)?

     Does the HCP include a description of how the Division will be
     notified if manufacturers or importers fail to respond to the
     employer's request for information, (g)(12)?  

     Does the HCP include a plan for updating MSDSs and for keeping
     current with new information, (g)(6)? 

     Does the HCP include a description of MSDS alternatives,
     (g)(10)?

     Does the HCP include a description of how employees are
     trained and who is responsible for training, (h)(1)?

LABELING AND OTHER FORMS OF WARNING, 5194(f)

     Do labels conform to other a substance-specific health
     standard, (f)(3)?

     Is each container labeled with product identity and hazard
     warnings, (f)(4)(A) and (B)?

     Are labels legible, in English and prominently displayed on
     the container, or readily available in the work area
     throughout each shift, (f)(8)?

     Is the manufacturer, importer or distributor ensuring that
     each container of hazardous substances is leaving the
     workplace with labeled with its identity (f)(1)(A), hazard
     warnings which convey specific health and physical hazards
     (f)(1)(B), and the name and address of manufacturer, importer
     or other
     responsible party, (f)(1)(C)?

     Do additional labeling requirements apply (5162, 5166 and
     5417)?

MATERIAL SAFETY DATA SHEETS, 5194(g)

     Have manufacturers and importers obtained or developed a MSDS
     for each hazardous substance they produce or import, (g)(1)?

     Have employers obtained or developed a MSDS for each hazardous
     substance they use, (g)(1)?

     Has the manufacturer provided the employer a requested MSDS,
     L.C.6399?

     Has the employer requested an MSDS as required, (g)(11)?

     If the employer has received no response to their MSDS request
     within 25 days, has the employer send the Director a copy of
     the written inquiry, (g)(12)(D)? 

     Are MSDSs accessible to employees during each work shift when
     they are in their work areas, (g)(8)?

     Does each MSDS contain the identity used on the label,
     chemical and common names and, for substances manufactured in
     California, CAS numbers of each hazardous ingredient
     (g)(2)(A)?

     Does each MSDS contain the physical and chemical properties of
     the hazardous substance, (g)(2)(B)?

     Does each MSDS contain information about the physical hazards
     of the hazardous substance, e.g., fire, explosion and
     reactivity data, (g)(2)(C)?

     Does each MSDS contain a description of the health hazards of
     the hazardous substance, including the signs and symptoms of
     exposure and any medical conditions which may be aggravated by
     exposure, (g)(2)(D) and (g)(2)(M)?

     Does each MSDS contain information about the potential routes
     of entry (g)(2)(E)?

     Does each MSDS contain information about applicable OSHA PELs,
     ACGIH TLVs, or any other exposure limit recommended by the
     MSDS preparer, (g)(2)(F)?

     Does each MSDS contain information indicating if the hazardous
     substance is listed as a potential carcinogen by NTP, IARC or
     OSHA, (g)(2)(G)?

     Does each MSDS contain precautions for handling, hygienic
     practices, protective measures for repair and maintenance of
     equipment and spill cleanup procedures, (g)(2)(H)?

     Does each MSDS contain any applicable control measures, e.g.,
     engineering controls, work practices, personal protective
     equipment, (g)(2)(I)?

     Does each MSDS contain emergency and first aid procedures,
     (g)(2)(J)?

     Does each MSDS contain the date of MSDS preparation or
     revision, (g)(2)(K)?

     Does each MSDS contain the name, address and telephone number
     of each MSDS preparer, (g)(2)(L)?

     Has the MSDS preparer sent a copy of the MSDS to the Director,
     (g)(13)?

EMPLOYEE INFORMATION AND TRAINING, 5194(h)

     Have employees been provided with information and training on
     hazardous substances in their work areas at the time of
     initial assignment and whenever a new hazard is introduced
     into their work area, 5194(h)(1)?      

     Have employees been informed of the requirements of the Hazard
     Communication Standard, 5194(h)(2)(A)?

     Have employees been informed of any operations in their work
     area where hazardous substances are present, 5194(h)(2)(B)?

     Have employees been informed of the location and availability
     of the employer's written Hazard Communication Program,
     including the list of hazardous substances and MSDSs,
     5194(h)(2)(C)?  

     Have employees been trained in the methods and observations
     that may be used to detect the presence or release of a
     hazardous substance in the work area, e.g., monitoring
     conducted by the employer, monitoring devices, visual
     appearance or odor of hazardous substances, 5194(h)(2)(D)?

     Have employees been trained in the physical and health hazards
     of the substances in the work area, and the measures they can
     take to protect themselves from these hazards, 5194(h)(2)(E)?

     Have employees been trained in the details of the HCP,
     including an explanation of the labeling system and the MSDSs
     and how employees can obtain the appropriate hazard
     information, 5194(h)(2)(F)?   

     Have employees been informed of their right to personally
     receive information regarding hazardous substances to which
     they may be exposed, 5194(h)(2)(G)1.?

     Have employees been informed of their right to have their
     physician or collective bargaining agent received information
     regarding hazardous substances to which they may be exposed,
     5194(h)(2)(G)2.?

     Have employees been informed of their eight not to be
     discharged or be discriminated against due to their exercise
     of the rights provided by Labor Code 6360 through 6399.7?

TRADE SECRETS, 5194(i)

     Has a supported trade secret claim been made, (i)(1)(A)?

     Does the MSDS contain information about the properties and
     effects of the hazardous substance, (i)(1)(B)?

     Does the MSDS indicate that the chemical identity is being
     withheld as a trade secret, (i)(1)(C)?

     Has trade secret information been released appropriate
     entities when requested during a medical emergency, (i)(2), or
     in non-emergency situations, (i)(3)?

     Has the party who is claiming trade secret protection under
     5194(i) complied with all requirements of subsection (i)(1)
     through (16)?







                                                                    
             C-43, Attachment (07/01/95)