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The employer may rely upon the hazard determination performed by the pharmaceutical manufacturer or importer.
Reference Interpretation and Compliance Letters: When is the chemical manufacturer required to distribute MSDSs?
Reference Interpretation and Compliance Letters: What are the container labeling requirements under HAZCOM?
Under HCS, the manufacturer, importer, or distributor is required to label each container of hazardous chemicals.
If the employee's work area includes the area where the MSDSs can be obtained, then maintaining MSDSs on a computer would be in compliance.
The pharmaceutical manufacturer and the importer have the primary duty for the evaluation of chemical hazards.The training provisions of the HCS are not satisfied solely by giving employee the data sheets to read.