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, Mrs. Schissler specifically mentioned 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.
Reference Interpretation and Compliance Letters:
- Applicability of the HCS to office workers and copy machine operators. [3/31/89]
- Application of the Hazard Communication Standard to art materials industry. [9/17/87]
- See Also: OSHA Instruction CPL 2-2.38D, Inspection Procedures for the Hazard Communication Standard, 29 CFR 1910.1200, 1915.99, 1917.28, 1918.90, 1926.59, 1928.21 [3/20/98]
October 2018
Tags: HAZCOM, OSHA
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