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If the hazardous chemicals are transferred into unmarked containers, these containers must be labeled with the required information, unless the container into which the chemical is transferred is intended for the immediate use of the employee who performed the transfer.Reference Interpretation and Compliance Letters: How does HAZCOM apply to pharmaceutical drugs?What are temporary agency employers required to do to meet HAZCOM requirements?In meeting the requirements of OSHA's Hazard Communication Standard, the temporary agency employer would, for example, be expected to provide generic hazard training and information concerning categories of chemicals employees may potentially encounter.This exemption in OSHA's regulation is based, however, not upon the chemical manufacturer's intended use of his product, but upon how it actually is used in the workplace.

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Reference Interpretation and Compliance Letters: When is the chemical manufacturer required to distribute MSDSs?

For example, if a new solvent is brought into the workplace, and it has hazards similar to existing chemicals for which training has already been conducted, then no new training is required.

As with initial training, and in keeping with the intent of the standard, the employer must make employees specifically aware which hazard category (i.e., corrosive, irritant, etc.) the solvent falls within.

The substance-specific data sheet must still be available, and the product must be properly labeled.

If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where employees will be exposed.

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