Q. Our product does not have a common name; we just
know it as A31. What should we do about the list?
A. Be sure to familiarize yourself with the definition
of a common name. A common name may be a trade name, a code
name or number, a brand name, or a generic name. If A31 is your
code number, it may be the common name for the product. However,
either the common name or the chemical name must be the identity
of the chemical, that is, the name that appears on both the label and the MSDS.
Q. We commonly call a particular product "green glop"
but that name does not appear anywhere on the label or
the MSDS. May we use "green glop" as the common name?
A. As long as the chemical name for the product provides
for cross-reference between the list, the MSDS and the label,
"green glop" would be acceptable as a common name on the list.
Q. If a product is a mixture of several hazardous
chemicals, how do we find its chemical name?
A. You should look at the MSDS to find the chemical name. It is possible that the mixture has a
name which "clearly identifies the chemical for the purpose
of conducting a hazard evaluation." If the mixture does
not have a chemical name, you must list the chemical names of
all the hazardous ingredients in the mixture indicated on the MSDS.
Q. We have some chemicals that we use throughout the plant.
How do we identify the work area?
A. If the chemical is used throughout the plant, it
is acceptable to list the work area as "plant-wide."
In developing your list, you must carefully consider how many
different work areas you have in your plant. Do not forget work
areas outside of the building where you may store hazardous chemicals.
Q. Can you send me a chemical information list form and I'll fill it out and send it back?
A. There is no form required under this law. You may
format your list in the way it is most useful for you as long
as it is in alphabetical order by common name. However, because
of the many requests for forms, a suggested format has been developed. See the next two pages.
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