What Is A Hazardous Chemical?
The Hazard Communication standard (29CFR1910.1200), requires “all employers to provide information to their employees about the hazardous chemicals to which they are exposed”. What is a hazardous chemical? OSHA provides guidance on what is a chemical and what makes a chemical hazardous, but as with most regulations, you may have to establish more absolute definitions.
A chemical is defined in Webster’s as “a substance having a specific molecular composition, obtained by or used in a chemical process”. Unfortunately, this is not very decisive for use in determining if a material in the workplace is a chemical as almost everything could fit under this definition. OSHA includes a broad definition of chemical in the HazCom standard “any element, chemical compound, or mixture of elements and/or compounds”, which unfortunately is also very general. I believe the best practical definition of a chemical for HazCom purposes is any liquid, powder, gas or hazardous solid.
A chemical that presents a physical or health hazard is considered hazardous under HazCom. Sounds straight forward, but defining what is truly a hazard can be up to interpretation. To some people, peanut butter presents a health hazard because of acute allergic reaction. By defining a chemical and obtaining a MSDS for every chemical, you can be confident you are meeting regulatory requirements. The challenge with this approach will usually be what are defined by OSHA as “articles”. Articles as defined by OSHA – “consumer products that are used in the workplace in a manner comparable to normal conditions of consumer use”* – may present some difficulty in obtaining MSDS because manufacturers will indicate consumer products do not require MSDS. Require the MSDS anyway (manufacturers will have the MSDS despite thinking it is not required) because comparable to normal conditions of consumer use cannot be guaranteed. I have seen some strange things, including eating the urinal cakes in the men’s restrooms and spraying Pledge in eyes while trying to shine up a bald head (to point out of couple of the stranger cases) where the MSDS for consumer products were needed by medical personnel.
* From 29CFR1910.1200
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