The OSHA Standard Interpretation dated November 21, 2023 addresses the applicability of the Hazard Communication Standard (HCS) 29 CFR 1910.1200 to industrial markers containing liquid paint or ink. The key point is that these markers, when containing hazardous chemicals, fall under the scope of HCS.
Labeling: Manufacturers and importers must label these products in compliance with the HCS, ensuring proper hazard communication. This includes providing appropriate hazard warnings and symbols on the product's label.
Safety Data Sheets (SDS): An SDS must also be supplied for the industrial markers containing hazardous chemicals. These data sheets should cover all relevant safety and health information about the product's chemicals, per HCS standards.
End-User Obligations: Employers using these products must also comply with HCS by maintaining an up-to-date SDS and ensuring that workers are trained on the hazards and proper handling of these products.
The interpretation reinforces that even for everyday products like markers, if hazardous chemicals are present, strict HCS rules apply. See more here.
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