Q&A: Emergency contact number and response on SDSs
What are the requirements for having an emergency contact number on SDS? What kind of emergency response is required for the emergency phone number, i.e. does the phone need to be staffed 24 hours a day?
Per 29 CFR 1910.1200, Appendix D, Section 1 of an SDS must contain an emergency phone number.
OSHA Directive CPL 02-02-079 – Inspection Procedures for the Hazard Communication Standard provides instructions for OSHA Compliance Officers to follow when inspecting a facility. On the topic of the emergency telephone number, the document states (p. 64-65) “[t]he SDS requires the inclusion of the contact information for the manufacturer in addition to emergency contact numbers. There is no requirement for the emergency number to be staffed 24 hours per day if the SDS specifies the restrictions on the contact hours. The emergency contact number can be for a company contracted to provide information in the case of an emergency [].” The directive goes on to state that “[t]here must be someone available at the emergency phone number who is able to provide more information concerning the product.”
An OSHA Letter of Interpretation elaborates on using a contracted company, stating “[a] contracted company that provides additional information for a hazardous chemical may be an SDS author or contracted preparer, such as an online SDS service. In this arrangement, a manufacturer or importer may agree to list the contracted company on its chemical label and SDS as the party to be contacted to provide additional or emergency information. However, the manufacturer or importer remains as the responsible party and, as such, maintains the ultimate responsibility for compliance with OSHA’s HCS.” The Letter of Interpretation also states that for chemicals distributed in the U.S. “[t]he emergency telephone number must be U.S. based.”
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