1. Hazardous Communications Program
Policy Document
Background
In a consistent and constant effort to increase safety in the workplace, the
Occupational Safety and Health Administration (OSHA) has developed a more universal
Hazardous Communication Standard (HCS or HazCom). The HCS was adopted from the
Globally Harmonized System (GHS) of labeling of chemicals created by the United
Nations. The benefit of the GHS is that this standard is now being implemented world
wide, and the entire international community will be able to communicate the hazards of
their chemicals effectively across international as well as inter-state borders. The other
benefit of adopting the GHS is that all chemicals will require a standardized labeling
format which will allow for ease of understanding through consistency. The end goal is
to allow the persons that regularly handle the chemicals and emergency personnel that
respond to chemical spills to properly equip themselves and secure the area.
Among the changes that OSHA has implemented in regards to labeling, they have
also standardized the format of the Safety Data Sheets (SDS), which is a departure from
the previous form of MSDS’s (or Material Safety Data Sheets). SDS’s now have a
standardized, sixteen-section format. AAA Molybdenum Products has made the effort to
update MSDS’s for all manufactured chemicals to the new SDS format as well as
identifying each chemical’s hazards. AAA Molybdenum Products will also train all
employees on the GHS labeling.
Requirements
Chemical Manufacturers
 Must evaluate hazards of all
manufactured and distributed
chemicals
 Label containers
 Maintain SDS’s and provide a copy
to customers – phase out and
replace old MSDS’s
Employers
 Identify and ensure labeling of all
Hazardous Materials (HazMat) in
the workplace
 Develop a HazCom program and
train employees
 Keep a SDS for each chemical and
allow all employees to have access
to SDS (Right-to-Know)
Exceptions
Office workers who encounter hazardous chemicals in occasional, isolated
instances are not required by OSHA to be trained in the handling of HazMats. SDS’s for
commercial products (e.g. Windex, Clorox) are not required when they are used in a
manner similar to how a regular consumer would use them; however, if employees work
with the HazMat in larger quantities and frequencies, then a SDS is required. SDS’s may
be kept in a digital format provided that every employee knows how to access them. In-
house labeling may be used provided that the package does not leave the premises and
that the labeling confers the same or similar information as required by the GHS. A
package does not have to be labeled if it is a temporary packaging and will be used by the
same operator within a single work-shift; for example, if a person is transporting a
chemical to another work area and will be utilized in the same day. There are other

2. exceptions listed by OSHA, none of which currently apply to AAA Molybdenum
Products.
Hazardous Communication Program
Please refer to PO.017 Hazard and Safety Plan in the Quality Management
System (QMS) manual for a list of dangerous chemicals kept in inventory. Most
chemicals are pre-labeled by the manufacturers and are consumed in production,
however, other materials (e.g. Perrhenic Acid) are manufactured at AAA Molybdenum
Products and must be properly labeled. AAA Molybdenum Products will not need to re-
label products that have been received and are already properly labeled. All employees
that regularly handle chemicals are required to ensure that all packages are properly
labeled – either received at or created by AAA Molybdenum Products.
Some chemicals are not dangerous, but have still been identified as causing
irritation or other nuisances. These chemicals must be identified and labeled as such by
management. Criteria for identifying and classifying hazards may be found in the GHS
Handbook known as the: GLOBALLY HARMONIZED SYSTEM OF
CLASSIFICATION AND LABELLING OF CHEMICALS (GHS); it is publically
available and can be found at: unece.org under the tab: Legal Instruments and
Recommendations.
Additional Information
If a chemical is subject to both GHS and Department of Transportation (DOT)
labeling requirements (i.e. when shipping the container), then DOT labeling takes
precedence over those required by GHS. Also, if additional information is required as
per GHS, then that information must be present on the packaging as long as it is not
repeated by the DOT labeling.
Example: Perrhenic Acid
As per DOT requirements, Perrhenic Acid must have:
 Proper Shipping Name
 Identification Number
 Technical Name(s)
 Name and Address of consignee and shipper
 Special Marking Requirements
 Diamond Hazard Class Label
And, as per GHS requirements, Perrhenic Acid must have:
 Product Identifier
 Signal Word
 Hazard Statement
 Pictogram
 Precautionary Statement(s)
 Name, address, and telephone number of chemical manufacturer
According to 29 CFR 1910.1200 C.2.3.3: “Where a label required by DOT appears
on a container, the pictogram specified in C.4 for the same hazard shall not appear.”

3. Therefore, no pictogram is necessary, but a Signal Word, Hazard Statement,
Precautionary Statement(s) are still required.
Ex.: Proper label for Storage:
Perrhenic Acid
CAS#: 13768-11-1
DANGER
Causes severe skin burns and eye damage
IF IN EYES: Rinse cautiously with water for
several minutes. Remove contact lenses,if present
and easy to do. Continue rinsing.
IF eye irritation persists:Get medical advice/
attention.
Wear protective gloves/ eye protection/ face
protection.
[Company name + contact information]
Ex.: Proper label for Shipping:
UN 3264
Corrosive liquid, acidic, inorganic, n.o.s. (Perrhenic
Acid Solution)
DANGER
Causes severe skin burns and eye damage
IF IN EYES: Rinse cautiously with water for
several minutes. Remove contact lenses,if present
and easy to do. Continue rinsing.
IF eye irritation persists: Get medical advice/
attention.
Wear protective gloves/ eye protection/ face
protection.
[Company name + contact information]
Retraining Employees
OSHA does not require that employers retrain their employees unless a new
physical or health hazard presents itself in the workplace, such as a new chemical that
requires never-before-used Personal Protective Equipment or methods for handling the
material. In this case, retraining is required.
Definitions and Acronyms
Acute vs. Chronic – Acutely toxic chemicals may cause harm after a single exposure,
whereas Chronic toxic chemicals may cause harm after repeated exposure or after a long
term
GHS – Globally Harmonized System
HCS – Hazardous Communications Standard (aka HazCom)
OSHA – Occupational Safety and Health Administration
DOT – Department of Transportation
SDS – Safety Data Sheet
HazMat – Hazardous Material
MSDS – Material Safety Data Sheet
QMS – Quality Management System