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Under review. This entry has not yet passed all eight gates of Methodology 1.0. It is a contextual editorial recommendation.

Under review conditional

Check a school's written hazard communication program for missing required elements

Takes a school's written hazard communication program and its chemical inventory list (product names only) and drafts a gap list against 29 CFR 1910.1200(e). The written program must describe how the label and warning, safety data sheet, and employee information and training requirements will be met, and must include a list of hazardous chemicals known to be present, using a product identifier referenced on the matching safety data sheet, and the methods for informing employees of hazards of non-routine tasks and of chemicals in unlabeled pipes in their work areas. Where contractors work on site, it checks for the 1910.1200(e)(2) methods: giving other employers access to safety data sheets, informing them of precautionary measures, and informing them of the labeling system. Each item is marked found, not found or needs review.

Human in the loop: The safety officer reviews the gap list and confirms the inventory against what is actually on site. The workflow does not classify chemicals, judge storage or approve the program. Limits: The inventory list may be out of date, and the workflow cannot see what is on the shelves. OSHA or state plan coverage of a given school employer must be confirmed locally. Not legal advice. Methodology 1.0: Strong candidate for replay.

How to run: Check a school's written hazard communication program for missing required elements

  1. Takes a school's written hazard communication program and its chemical inventory list (product names only) and drafts a gap list against 29 CFR 1910.1200(e). The written program must describe how the label and warning, safety data sheet, and employee information and training requirements will be met, and must include a list of hazardous chemicals known to be present, using a product identifier referenced on the matching safety data sheet, and the methods for informing employees of hazards of non-routine tasks and of chemicals in unlabeled pipes in their work areas. Where contractors work on site, it checks for the 1910.1200(e)(2) methods: giving other employers access to safety data sheets, informing them of precautionary measures, and informing them of the labeling system. Each item is marked found, not found or needs review.
  2. The safety officer reviews the gap list and confirms the inventory against what is actually on site. The workflow does not classify chemicals, judge storage or approve the program.
  3. The inventory list may be out of date, and the workflow cannot see what is on the shelves. OSHA or state plan coverage of a given school employer must be confirmed locally. Not legal advice.
Sources: 29 CFR 1910.1200, Hazard communication | Cornell LII ↗ (Snapshot pending)

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