OSHA Field Safety and Health Management System (SHMS) Manual


  1. Purpose

    It is OSHA's policy to comply with the requirements of OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200.

  2. Scope

    This program applies to all work operations where there is exposure to hazardous chemicals that are known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. The mere presence of a hazardous chemical in the workplace does not trigger coverage under the HCS. There must be actual or potential exposure to an employee. Consumer products are not covered by this program to the extent that the use of the products results in a duration and frequency of exposure that is not greater than that which could be reasonably be experienced by consumers.

  3. Responsibilities
    1. Area Offices - responsible OSHA Manager(s) is the coordinator of the Hazard Communication Program (HCP) in his or her office, acting as the representative of the Regional Administrator.
      1. He or she may delegate the day-to-day responsibility for the HCP to one of the Assistant Area Directors or a senior industrial hygienist.

      2. Ultimate responsibility for the development and implementation of the program in each Area Office remains with the responsible OSHA Manager(s).

    2. Regional Offices – the Regional Hazard Communication Coordinator (RHCC), acting as the representative of the Regional Administrator, will have responsibility for the development and implementation of the program in the Regional Office, as well as act as overall coordinator for the program. For purposes of this program, the responsible OSHA Manager(s) and RHCC have the same responsibilities.

  4. Procedure
    1. List of Hazardous Chemicals

      1. A list will be maintained of all hazardous chemicals used in the office and updated as necessary. This list will be developed by each office and become a part of this program as an attachment.

      2. The list will identify the corresponding Safety Data Sheet (SDS) for each chemical.

    2. Safety Data Sheet

      1. A copy of an SDS for every substance on the list of hazardous chemicals in the Regional/Area office will be maintained.

      2. SDSs for all hazardous chemicals used in the Regional/Area Office will be readily accessible to employees at all times.

      3. Requisitions for hazardous chemicals are to include a request for the SDS. All SDSs will be reviewed for content and completeness. Additional research will be done if necessary.

      4. SDSs of new material to be purchased must be reviewed and the chemical approved for use by the responsible OSHA Manager(s) /RHCC or his or her designee. Whenever possible, the least hazardous substance will be obtained.

    3. Warning Labels

      1. All containers of hazardous chemicals in the office will be properly labeled.

      2. All labels will include the identity of the hazardous chemical and the appropriate hazard warning, including the target organ effects.

      3. Each label will be checked with the corresponding SDS to verify the information.

      4. Alternate labeling provisions, such as tags or markings, may be made for containers that are of unusual shape or size and do not easily accommodate a legible label.

      5. Chemicals that are transferred from a properly labeled container to a portable container, and that are intended only for the immediate use of the person who performs the transfer are not required to be labeled. Immediate use is defined in 29 CFR 1910.1200.

    4. Training

      1. Each employee who is potentially exposed to hazardous chemicals will receive training as outlined in this chapter.

      2. New employees will receive training on the contents of this program and specific training on the chemicals that the individuals will be directly working with during orientation and prior to performing work where exposure may occur.

      3. Additional training will be provided for employees whenever a new chemical is introduced into their work area.

      4. As warranted, training may be provided based on the uniqueness of the hazards to be encountered at an inspection worksite.

      5. The training program will emphasize the following elements:

        1. A summary of the HCS and the written program;

        2. Hazardous chemical properties, including visual appearance and odor, and methods that can be used to detect the presence or release of hazardous chemicals;

        3. Physical and health hazards associated with potential exposure to hazardous chemicals;

        4. Procedures to protect against hazards, such as personal protective equipment, work practices, and emergency procedures;

        5. Hazardous chemical spill leak procedures; and

        6. Location of SDSs, how to understand their content, and how employees may obtain and use appropriate hazard information.

    5. Hazardous Chemicals Encountered on Work Sites

      Recognizing that the greatest potential for exposure to hazardous chemicals involves field exposures during the course of on-site activities, the following issues will be considered:

      1. Field employees will identify potential hazards using the employer's list of hazardous chemicals and associated SDSs and labeling system.

        1. Ensure that appropriate protective measures, including personal protective equipment, are available and utilized.

        2. Where protective measures are not adequate, OSHA employees must avoid exposure and contact their responsible OSHA Manager(s) / RHCC.

      2. Samples collected during any on-site activity that may present a potential hazard to OSHA employees will be handled in accordance with procedures outlined by OSHA's Salt Lake City Technical Center.

    6. Contract Employees

      1. Outside contractors will be advised of any chemical hazards that may be encountered in the normal course of their work in OSHA offices.

      2. Outside contractors will be notified of the location and availability of SDSs.

      3. Each contractor bringing chemicals on-site must provide OSHA with the appropriate hazard information, including SDSs. All containers of hazardous chemicals brought on-site by an outside contractor must be appropriately labeled.

    7. Non-Routine Tasks

      If a non-routine task is planned in an OSHA office, affected employees must be informed of any chemical hazards associated with the performance of the task(s) and appropriate protective measures before such work is initiated.