Chemical manufacturers and importers are required to obtain or develop a material safety data sheet for each hazardous chemical they produce or import.  Distributors are responsible for ensuring that their customers are provided a copy of these MSDS's.  Employers must have an MSDS for each hazardous chemical which they use.  Employers may rely on the information received from their suppliers.  The specific requirements for material safety data sheets are in paragraph (g) of this section.  There is no specified format for the MSDS under the rule, although there are specific information requirements.  OSHA has developed a non-mandatory format, OSHA Form 174, which may be used by chemical manufacturers and importers to comply with the rule. The MSDS must be in English.  You are entitled to receive from your supplier a data sheet which includes all of the information required under the rule.  If you do not receive one automatically, you should request one.  If you receive one that is obviously inadequate, with, for example, blank spaces that are not completed, you should request an appropriately completed one.  If your request for a data sheet or for a corrected data sheet does not produce the information needed, you should contact your local OSHA Area Office for assistance in obtaining the MSDS.

The role of MSDS's under the rule is to provide detailed information on each hazardous chemical, including its potential hazardous effects, its physical and chemical characteristics, and recommendations for appropriate protective measures.  This information should be useful to you as the employer responsible for designing protective programs, as well as to the workers.  If you are not familiar with material safety data sheets and with chemical terminology, you may need to learn to use them yourself.  A glossary of MSDS terms may be helpful in this regard.  Generally speaking, most employers using hazardous chemicals will primarily be concerned with MSDS information regarding hazardous effects and recommended protective measures. Focus on the sections of the MSDS that are applicable to your situation.

MSDS's must be readily accessible to employees when they are in their work areas during their work shifts.  This may be accomplished in many different ways.  You must decide what is appropriate for your particular workplace. Some employers keep the MSDS's in a binder in a central location (e.g., in the pick-up truck on a construction site).  Others, particularly in workplaces with large numbers of chemicals, computerize the information and provide access through terminals.  As long as employees can get the information when they need it, any approach may be used.  The employees must have access to the MSDS's themselves - simply having a system where the information can be read to them over the phone is only permitted under the mobile worksite provision, paragraph (g)(9) of this section, when employees must travel between workplaces during the shift.  In this situation, they have access to the MSDS's prior to leaving the primary worksite, and when they return, so the telephone system is simply an emergency arrangement.

In order to ensure that you have a current MSDS for each chemical in the plant as required, and that employee access is provided, the compliance officers will be looking for the following types of information in your written program: