- Train employees. The deadline to ensure all workers are familiar with the updated labeling and SDS elements was Dec. 1, 2013.
- Get the new SDSs. Take steps, including contacting chemical manufacturers, to ensure you have updated SDSs by June 1 for all chemicals onsite.
- Review the SDSs. When the new SDSs come in, closely examine them and consider whether you have appropriate controls in place for all hazards.
- Update hazcom program. If new hazards are listed on the SDSs, update your hazard communication program to mitigate the risks posed by those hazards.
- Review training. Make sure your employees understand the new labels and SDSs. Refresher training may be necessary.
Office workers who encounter hazardous chemicals only in isolated instances are not covered by the rule. The Occupational Safety and Health Administration (OSHA) considers most office products (such as pens, pencils, adhesive tape) to be exempt under the provisions of the rule, either as articles or as consumer products. For example with copy toner OSHA has previously stated that intermittent or occasional use of a copying machine does not result in coverage under the rule. However, if an employee handles the chemicals to service the machine, or operates it for long periods of time, then the program would have to be applied.