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)