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Environment

I N F O R M A T I O N F R O M K O D A K J-311 $20.00

Hazard Communication for


Photographic Processing Facilities
Kodaks health, safety,

and environmental

publications are available

to help you manage your

photographic processing

operations in a safe,

environmentally sound

and cost-effective

manner. This publication

is part of a series of

publications on health
Making employees aware of Every employee has a need and
chemical hazards is an important right to be protected from and safety issues
part of providing a safe workplace. hazards in their workplace.
While a photographic processing The OSHA Hazard Communi- affecting photographic
facility is typically considered a cation Standard was established to
low hazard workplace, there are ensure that employers and processing facilities.
certain materials and operations employees know about workplace
that can present hazards to chemical hazards and how to
employees. An understanding of
It will help you meet the
protect themselves from those
those potential hazards and hazards. This standard is different
measures to protect employees from other OSHA standards in that
requirements of the OSHA
who handle those chemicals should it broadly covers all aspects of
be a key element in the health and hazardous chemical Hazard Communication
safety program at your facility. manufacturing, movement, and use
The Occupational Safety and rather than focusing on a single Standard.
Health Administration (OSHA) has operation or chemical. The
developed a framework of federal standard includes information on
regulations that govern workplace hazard evaluation, Material Safety
safety. These regulations are based Data Sheets (MSDSs), chemical
on the principles that: lists, container labels, and
Every employee has a need and employee training to ensure that
right to be made aware of the chemical hazards are properly
hazards in their workplace. communicated to users of those
materials.

Eastman Kodak Company, 1999


This publication reviews how the Hazardous Chemical Descriptions Kodak provides MSDSs with most
OSHA Hazard Communication photographic processing chemicals,
Standard applies to photographic Hazard Type Examples even those that are not classified as
processing facilities. A Compressed gases hazardous chemicals. Those not
recommended compliance process (cylinder of nitrogen), classified as hazardous chemicals
oxidizers
for photographic processing can be identified by the statement
Physical (chlorine bleach),
facilities and a self-assessment Hazard combustible liquids Low Hazards for Recommended
checklist are also included to assist (kerosene), and Handling under Section 3 Hazard
you in reviewing and improving flammable materials Identification of the KODAK
your current program. (cleaning solvents) MSDS.
Additional requirements that Chemicals that may
apply to businesses that distribute, cause acute or chronic
package or mix photographic health effects, such as: EXEMPTIONS
processing chemicals are provided irritants (ammonia),
Health There are some materials that are
corrosives (acetic acid),
in Appendix A. Hazard
carcinogens specifically exempt from some or all
(formaldehyde), and of the requirements of the Hazard
sensitizers Communication Standard. Two
HAZARDOUS (color developing agents)
CHEMICALS examples that are routinely found in
Determining whether a chemical photographic processing facilities
To determine if the OSHA Hazard is hazardous or not is the are consumer products and articles.
Communication Standard applies to responsibility of the manufacturer Consumer products are exempt
your facility, you must first or importer of the chemical. You do from the standard when used in a
determine if there are hazardous not need to make a separate frequency and duration equal to that
chemicals in your workplace. OSHA assessment of chemicals in your reasonably experienced by
estimates that there are over 575,000 workplaceyou can rely on the consumers outside the workplace.
chemical products that can be evaluation of the manufacturer or For example, if you are using
identified as hazardous. A importer. When a manufacturer has household cleaner for occasional
hazardous chemical is defined by determined a product is or contains cleaning, this chemical would not
OSHA as being either a physical a hazardous chemical, they are need to be included in your
hazard or a health hazard. required to provide a MSDS. program. However, if you are using
Information on the physical and/or this product to clean processors,
health hazards of a chemical is in the which is not its intended use (as
MSDS. labeled), this chemical must be
included in your program.

Chemical Hazardous Communication Information Flow

Manufacturers/ Distributors Employers


Importers (Stockhouse/Retail (Photographic
(Kodak) Sales) Processing Facility)

Determine Transmit MSDS Obtain and maintain


hazards MSDS

Develop and Maintain container Maintain and provide


provide MSDS labels labels and chemical
list

Label shipping Communicate infor-


containers mation to employees

2 Hazard Communication for Photographic Processing Facilities J-311


If you have an employee whose Employees Covered by the OSHA You can provide the workers
job requires daily use of this product Communication Standard employer with a copy of your
for janitorial services, the exposure written program as a means of
Personnel Examples
would be greater than experienced complying with these requirements.
Employees who work Photographic
by a consumer of the product and You may also want to establish a
with hazardous processor
this material would need to be chemicals operator,
facility sign-in policy and review
included in your program. Even if chemical these items with non-employees as
the consumer products in your mixing operator they enter your facility.
facility are not covered by the Employees who work Sales person
standard, it is a good idea to obtain around and may have who works in or
the MSDSs for these products and contact with hazardous near process-
STATE AND LOCAL
make them available to employees. chemicals ing area REQUIREMENTS
Articles are also exempt from the Employees of other Contract
In addition to the federal OSHA
standard. An article is a manu- companies who work in maintenance or
your facility who may janitorial staff, requirements for Hazard
factured item that:
have contact with vendors Communication, there may be
is not a liquid or a particle
hazardous chemicals additional state and local
is formed to a specific shape requirements that apply to your
the end use depends on the photographic processing facility.
products shape or design EMPLOYEES OF OTHER Some states may have Worker
COMPANIES Right-to-Know laws that have
does not release more than traces
of hazardous chemicals during additional requirements. These
If you have employees of other
use typically include additional
companies, such as maintenance
does not pose a physical hazard or information on chemical labels or
workers or vendors, working at
health risk to employees requirements for annual employee
your facility, you are responsible for
training. Local laws administered by
Photographic films, papers, and ensuring that they are informed of
fire departments or county agencies
processing equipment are con- any chemical hazards that they
may also have additional
sidered articles. might come into contact with.
requirements, such as facility hazard
Hazard communication training of
signs. Each state has an OSHA
those employees is the responsibility
EMPLOYEES COVERED BY of their employers.
consultation service and OSHA
THE OSHA HAZARD You must identify chemical
Area Offices that can help you with
COMMUNICATION hazards to which employees of other
the specific requirements for your
STANDARD companies may be exposed. They
area.
must also have access to MSDSs and
The purpose of the Hazard
information on your facilitys HEALTH AND SAFETY
Communication Standard is to
hazard labeling system. You must PROGRAM
communicate any potential hazards
also inform them of any protective
to employees who may be exposed
measures, such as Personal Your Hazard Communication
to hazardous chemicals. The
Protective Equipment (PPE) or Program is a key element in an
definition of employee includes
ventilation, that are required during effective Health and Safety
anyone who is compensated for
normal operating conditions or Program. There are several things
performing work at your facility.
foreseeable emergencies. you can do to ensure that your
This definition includes family
Please note that the use of PPE program is effective.
members who are paid for
requires specific employee training. Assign responsibilitiesMost
employment but are not an owner of
PPE training is the responsibility of OSHA Standards, including Hazard
the business. There are no
the employer. You may want to Communication, do not specifically
exemptions for small workplaces.
ensure that all employees of other require the assignment of responsi-
Any business with at least one
companies have received proper bilities as part of compliance.
employee is covered by this
training prior to using PPE at your However, defining and assigning
standard if hazardous chemicals are
facility. For additional information responsibilities for key activities,
present in the workplace.
on the OSHA PPE requirements, see such as maintaining labels,
KODAK Publication No. J-312, obtaining MSDS, or employee
Personal Protective Equipment training, will help ensure that these
Requirements in Photographic tasks are being performed.
Processing Facilities.

Hazard Communication for Photographic Processing Facilities J-311 3


Maintain programMake sure The location of and system for
that you keep your program up-to- WRITTEN PROGRAM maintaining MSDSs
date on any changes that take place How employee training is
in your facility. Also, make sure that accomplished
you keep up-to-date on any new How employees are informed of
requirements. Kodak, as your the hazards of non-routine tasks.
photographic product vendor, is a Non-routine tasks are things that
good source for this information. an employee does not normally
Ensure everyone in your facility do; therefore the employee may
works safelyThis not have received training on the
recommendation not only includes potential hazards of that task. This
your employees and yourself, it also can include things such as
includes contract workers who work occasional tank cleaning.
at your facility. You should have How employees are informed of
procedures to ensure that everyone the hazards from unlabeled pipes.
at your facility follows your Health This protects employees in the
and Safety Program. event of a leak from the piping.
Some facilities choose to label all
piping as a means of complying
COMPLIANCE with this requirement.
REQUIREMENTS Each facility that uses hazardous Provisions for employees of other
chemicals must develop, companies who work at your
A photographic processing facility is implement, and maintain a Written facility. This includes providing
required to have a Hazard Hazard Communication Program. them with:
Communication Program that The written program does not need access to MSDSs
includes the following elements: to be lengthy or complicated. information on employee
Written Hazard Communication Sample written programs are protection requirements during
Program available from Kodak and from normal operating conditions
List of hazardous chemicals that OSHA. The written program must and foreseeable emergencies
are known to be present in the be kept in the workplace and information on your facilitys
facility available to employees. If you labeling system
Labels that identify hazardous operate multiple facilities, each
chemicals and hazard warnings location must have a copy of their
Maintenance of Material Safety own written program specific to that Review
Data Sheets (MSDSs) location. If an employee works in
Develop a written program that
multiple locations, the written addresses labels/warnings, MSDSs,
program for that employee should training, non-routine tasks, unlabeled
be kept at the primary workplace. piping, and provisions for employees
The program must describe: of other companies.
The system of labels or other
forms of warning that you use at
your facility. This could be
warning labels available from
Kodak or another system such as
the Hazardous Materials
Identification System (HMIS).

4 Hazard Communication for Photographic Processing Facilities J-311


LIST OF HAZARDOUS LABELS AND OTHER
CHEMICALS FORMS OF WARNING

Portable containers are not


required to be labeled if the
hazardous chemical is transferred
Manufacturers, importers, and from a labeled container and is
distributors are required to properly immediately used by the employee
label any hazardous chemicals who makes the transfer. However, if
before they are shipped to your other employees are involved in the
As part of the written program, each photographic processing facility. transfer or the material will be used
facility must compile a list of all These labels include the product over several work shifts, a warning
hazardous chemicals in the identity, appropriate hazard label is required. It is a good idea to
workplace. The list should use the warnings, and the name and label all containers in the workplace
chemical identity, such as the address of the manufacturer or other with their contents and hazard
product or trade name (e.g. KODAK responsible party. information to make sure that
EKTACOLOR RA Developer Employers must make sure that employees are aware of any
Replenisher, KODAK RP X-OMAT the arriving container labels are potential hazards.
LO Fixer and Replenisher) that is intact and that any container that a Labels must be in English, legible,
used on the MSDS. The list does not hazardous chemical is transferred and prominently displayed. Torn or
have to include individual into is labeled with the chemical discolored labels should be replaced
components of mixtures or indicate identity and the appropriate hazard to ensure that employees can easily
the hazards of each chemical. You warnings. Containers are broadly read the information. You can use
can compile a list for the entire defined as anything that can hold a individual container labels or you
facility or lists for individual work hazardous chemical. In a can use signs or placards in lieu of
areas in the facility. You may also photographic processing facility, affixing individual labels to
want to include another reference, this includes storage and containers; be sure the same
such as product catalog number or replenisher tanks, processors, and information that is on the label is
manufacturer, to make it easier for silver-recovery systems. conveyed on the sign or placard.
employees to find information on
Labels in other languages may be
the MSDS or product label.
used in addition to the English labels
You may want to include all
if they will assist in better
chemicals in the workplace on your
communicating the hazard
chemical list and designate those
information.
that are hazardous chemicals.
The list must be kept in the work
place and be readily available to
employees. The list can be posted or
you may want to use it as an index to
the MSDSs.

Review

Compile a list of all hazardous


chemicals in the workplace.

Hazard Communication for Photographic Processing Facilities J-311 5


Your labeling system must MSDSs to chemical users.
include the chemical identity and MATERIAL SAFETY DATA Information on MSDS distribution
appropriate hazard warnings. You SHEETS (MSDSs) requirements is included in
will need to select a hazard warning Appendix A.
system. Hazard warnings that You must make sure that you
convey the hazards associated with have a MSDS for each hazardous
the container contents can be words, chemical that you receive at your
picture, or symbols. Labels using facility. If your supplier does not
plain English hazard warnings are provide you with a MSDS, contact
available for most Kodak the supplier and request the MSDS.
photographic processing chemicals. If you need a MSDS for any Kodak
You can also create your own labels product, call the Kodak Information
for Kodak products by referring to Center at (800) 242-2424, ext. 25.
Section 16 of the MSDS which If you have questions about the
contains label statements for the information contained in a MSDS,
products. contact the manufacturer or
importer of the chemical. For health
Dilute Solution Containing: Attach to Replenisher Tank Chemical manufacturers and and safety questions about Kodak
and/or Process Machine Tanks
KODAK EKTACOLOR PRIME Developer Replenisher
WHEN DILUTED FOR USE AS RECOMMENDED: importers are responsible for products, call (585) 722-5151.
CONTAINS:
Water
Potassium carbonate
CAS Reg. #
007732-18-5
000584-08-7 developing a MSDS for each The MSDS for each hazardous
Triethanolamine 000102-71-6
N,N-diethylhydroxylamine
4-(N-ethyl-N-2-methanesulfonylaminoethyl)-2-methylphenylenediamine
sesquisulfate monohydrate
003710-84-7

025646-71-3 hazardous chemical that they chemical that you are currently
WARNING!
MAY CAUSE ALLERGIC SKIN REACTION produce or import. Each MSDS must using must be readily available to
Avoid contact with eyes, skin and clothing.
Wash thoroughly after handling.
be in English, but like the hazard employees during each workshift.
FIRST AID: In case of eye contact, immediately flush eyes with plenty of water for at least 15 minutes.
In case of skin contact, wash skin with soap and plenty of water. Get medical attention if symptoms occur.
Remove contaminated clothing and shoes. Wash contaminated clothing before reuse. Destroy or thoroughly warnings, can be produced in other You can keep MSDSs in a single
clean contaminated shoes.

Keep out of reach of children. languages as supplemental location for the entire facility or
For additional information, see Material Safety Data Sheet (MSDS).
Concentrate (not dilute solution) This label is for use only information to help users better place them in the individual work
Manufactured by with the indicated KODAK product.
Eastman Kodak Company
Rochester, New York 14650
Product information: 1-800-242-2424 Emergency information: (716) 722-5151 understand the hazards associated areas where the chemicals are used.
with the chemicals in the workplace. MSDSs are typically maintained in
Some facilities may choose to use paper form, but you can keep them
Each MSDS must contain:
a hazard warning system such as the on microfilm or electronic formats as
Identity of the hazardous
Hazardous Materials Identification long as employees have ready access
chemicals in the product
System (HMIS). This system uses a to them.
numeric scale to depict the severity Physical and chemical
characteristics You may have to keep MSDSs for
of associated hazards. If you use a products that are no longer used as
system of this type, be sure to Physical and health effects, and
records of employee exposure. For
adequately train employees on how physical and health information
more information on retention of
to properly read labels. Placing a Exposure limits employee exposure records, see
poster with a definition of the Primary routes of entry KODAK Publication No. J-317,
system in the work area is a good Injury and Illness Management for
Precautionary and control
way to help employees understand Photographic Processing Facilities.
measures
and remember the numeric hazard
scales. Emergency and first aid
HMIS labels are available through information Review
safety equipment suppliers. HMIS Identification of preparer Obtain and make accessible to
codes for many Kodak products are Date of preparation employees a Material Safety Data
included on the MSDS. Sheet (MSDS) for all hazardous
Manufacturers and importers chemicals in your facility.
must provide the MSDS at the time
Review of initial shipment to distributors or
users. Kodak provides MSDSs by
Label all containers of hazardous
chemicals in your photographic
mail at the time of initial purchase of
processing facility including a product and with subsequent
replenisher tanks, processors, waste orders when changes have been
tanks/silver-recovery system. made to the MSDS. Distributors also
have requirements to provide

6 Hazard Communication for Photographic Processing Facilities J-311


EMPLOYEE INFORMATION AND TRAINING

All employees who may be Prior to reassigning employees to Training must include:
exposed to hazardous chemicals a new work area with hazards for The requirements of the OSHA
while performing their job must be which the employee has not Hazard Communication Standard
trained. This includes not only those received training. Training must
Operations in their work areas
individuals who work with the be done before the employee
where hazardous chemicals are
works in the new area. You may
chemicals, but others who may enter present
want to incorporate hazard
the areas where the chemicals are Location and availability of the
communication into your process
used, such as delivery and of retraining reassigned written program, list of hazardous
maintenance personnel. If your employees. chemicals, and MSDSs
photographic processing area is not Methods and observations used to
Annual Hazard Communication
segregated from other work areas in detect the presence or release of a
training is not required by OSHA,
your facility, you should consider hazardous chemical in the work
but may be required by your states
training everyone who works in the area such as visual appearance, or
Worker Right-to-Know laws. You
facility. odor. Odor is usually a good
may want to routinely conduct
Training must be conducted: method for detecting the presence
retraining to be sure that all of photographic processing
Prior to initial assignment for new
employees understand the hazards chemicals. Review the MSDS for
employees. Training must be
done before the new employee of the chemicals that they are specific information on chemical
works with any hazardous working with. odors (KODAK MSDS Section 9,
chemicals. You may want to Training should be conducted for Physical and Chemical
incorporate this training into new each employee to a level that is Properties).
employee orientation. appropriate for the hazards that The physical and health hazards
Prior to introducing new hazards they are likely to encounter while of chemicals in the work area. The
into a work area. This may include performing their job. An employee physical and health hazards of
any new processes or chemicals who mixes chemicals or works each chemical are described on
that had not been included in around processors may require the product label and in the MSDS
previous employee training. If a more extensive training on chemical (KODAK MSDS Section 3,
new process uses similar hazards than an employee who has Hazard Identification, and
chemicals to those already Section 11, Toxicological
infrequent contact with chemicals or
covered in existing employee Information).
works in an area adjacent to where
training, new training would not
chemicals are used.
be required.

Hazard Communication for Photographic Processing Facilities J-311 7


Measures to protect employees Details of the hazard training date, and verification of the
from workplace hazards such as communication program effectiveness of training. The
work practices, emergency including labeling system, verification of effectiveness can be
procedures, and personal MSDSs, and how employees can accomplished by using a simple test
protective equipment. obtain and use appropriate that the employee takes following
Information on the safe handling hazard information. Your
the training.
of chemicals is included on the facilitys written program should
MSDS (KODAK MSDS Section 7, include this information.
Handling and Storage and There is no requirement under the Review
Section 8, Exposure Control/
OSHA Standard to maintain Train all employees who may be
Personal Protection). Also see
training records. However, we exposed to hazardous chemicals while
KODAK Publication No. J-312,
Personal Protective Equipment for recommend that you keep training performing their job.
Photographic Processing Facilities records so you can verify that
and No. J-316, Emergency training has been conducted. If you
Preparedness for Photographic keep records, include the
Processing Facilities. employee's name and signature, the

Summary of Hazard Communication Recordkeeping Requirements


for Photographic Processing Facilities
Maintain current copies of:
Written Hazard Communication Program
List of Hazardous Chemicals
Material Safety Data Sheets (MSDSs) for hazardous chemicals used
Maintain training records (if documented)

Summary of Hazard Communication Training Requirements


for Photographic Processing Facilities
Conduct training:
Prior to initial assignment for new employees
Prior to introducing a new hazard into the workplace
Prior to reassigning employee to new area with new hazards
Annual retraining is recommended, but is not required
Training covers:
OSHA Hazard Communication Standard
Operation where hazardous chemicals are present
Location and availability Written Program, Chemical List, MSDSs
Physical and health hazards of chemicals in the work area
Methods and observations used to detect the presence or release of a hazardous
chemical in the work area
Measures to protect employees from workplace hazards
Detail of your facility Program including labeling system, MSDSs, and how employees
can obtain and use hazard information
Training records that verify effectiveness of training are recommended, but not required

8 Hazard Communication for Photographic Processing Facilities J-311


5. If MSDSs are missing, request needed MSDSs from
RECOMMENDED COMPLIANCE the manufacturer or distributor.
PROCESS 6. Establish a system to be sure that any new
hazardous chemicals are added to the List of
The following process can help photographic
Hazardous Chemicals and to ensure a MSDS is
processing facilities meet the requirements of the
received with each shipment. Make sure
Hazard Communication Standard. You may want to employees are trained in any new hazards before
assign responsibility for specific tasks to ensure that the material is used in the workplace.
your program is kept up-to-date. Some of the process
steps include recommendations not required by the 7. Review warning labels in your facility to ensure:
standard but may be helpful in ensuring that your a. Labels contain hazardous chemical identity
program is comprehensive. Of course, a facility may and appropriate hazard warnings. If a hazard
choose to follow a different process. rating system such as Hazard Material
1. Review state and local requirements to define any Identification System (HMIS) is used, be sure
additional hazard communication requirements. employees know the details of the system.
In most states, hazard communication b. Labels are affixed to each container of
requirements follow the federal OSHA hazardous chemicals in your facility
requirements. Check with your state to review any (including tanks, processors, etc.). (In some
additional state Right-to-Know requirements. cases, you can substitute signs or placards that
When reviewing any additional requirements, pay identify the containers and convey chemical
particular attention to annual training and identity and hazard warnings.)
additional labeling requirements.
8. Identify all contract workers and vendors
2. Develop or review your existing Written Hazard (employees of other companies) who work in your
Communication Program to ensure that it facility and provide them with a copy of your
contains: Written Hazard Communication Program.
a. Requirements for warning labels, MSDSs, and 9. Review all job tasks at your facility to determine
employee information and training the appropriate level of training that each task will
b. Methods of informing employees of the require. Employees who perform tasks that may
hazards of non-routine tasks result in regular exposure to a hazardous chemical
will need more extensive training on chemical
c. Methods of informing employees of the
hazards. For example, chemical mixing, silver-
hazards associated with chemicals in
recovery, chemical spill response, or processor
unlabeled pipes
maintenance operations.
d. Methods of how other employer(s), with
10. Establish a system to provide all employees with
employees in your facility, will be:
the appropriate level of training upon initial
Told how to access MSDSs for hazardous assignment, whenever hazards in your facility
chemicals that the contract workers may be change, or when reassigned to a job with new
exposed to while working hazards.
Informed of measures to be taken to protect 11. Make sure all employees who require training
employees during normal operating have been trained. Repeat Hazard Communication
conditions and in foreseeable emergencies training periodically for all employees. Document
Informed of the labeling system used in all training.
your facility 12. Annually review these process steps to ensure that
3. Develop or review the existing List of Hazardous your Hazard Communication Program reflects
Chemicals to ensure that the list includes all any changes in requirements, operations, or
hazardous chemicals found in your facility. personnel.
4. Review existing MSDSs to ensure that:
a. An MSDS for each hazardous chemical in the
facility is available
b. MSDSs are readily accessible to employees in
the facility
c. A specific location for MSDSs has been
designated

Hazard Communication for Photographic Processing Facilities J-311 9


SELF-ASSESSMENT CHECKLIST FOR HAZARD COMMUNICATION
The following checklist is provided to help managers of photographic processing facilities assess their compliance and
identify areas for improvement with their program.

Yes No

The photographic processing facility has a Written Hazard Communication Program


that meets all requirements outlined in this publication

The facility has a process for informing other companies with employees working at the
facility of hazard communication requirements

A list of all Hazardous Chemicals at your facility has been compiled

A MSDS for each hazardous chemical is available at your facility

Warning labels are on all containers of hazardous chemicals at your facility

All current employees received Hazard Communication training

Hazard Communication training is given to all employees prior to initial assignment,


when hazards in the workplace change, or when reassigned to an area with new
hazards

State or local Hazard Communication requirements, if any, have been implemented at


your facility

REGULATORY REFERENCES

Subject OSHA Standard


Hazard Communication 29 CFR 1910.1200
Written Program/List of Hazardous Chemicals 29 CFR 1910.1200(e)
Labels/Warnings 29 CFR 1910.1200(f)
MSDS Content and Distribution 29 CFR 1910.1200(g)
Employee Training 29 CFR 1910.1200(h)

Hazard Communication for Photographic Processing Facilities J-311 10


APPENDIX A WHOLESALE DISTRIBUTORS

If your facility or a portion of your facility is used for the Wholesale distributors are distributors that provide
distribution of photographic processing chemicals, hazardous chemicals to either another distributor or to
there are specific Hazard Communication requirements an employer, such as a photographic stock house
that apply to those operations. The type of distribution dealer. MSDSs for all hazardous chemicals that are
(wholesale vs. retail) will determine these distributed must be maintained and obtained if not
requirements. The following review of requirements is received from the manufacturer or importer. Wholesale
based on the distribution of sealed containers that are distributors need to provide MSDSs with the initial
not opened by employees under normal conditions, shipment and the first shipment after a MSDS update.
such as retail sales. Additional requirements for The MSDS can be provided with the shipment or sent
repackaging and bulk mixing photographic processing prior to or at the time of the shipment. Wholesale
chemicals for distribution are also provided. distributors who sell to employers over-the-counter
must also post a sign to inform those employers of the
availability of the MSDS. MSDSs must be provided
CHEMICAL DISTRIBUTORS upon request.
Distributors must ensure that labels on incoming
containers of hazardous chemicals are not removed or RETAIL DISTRIBUTORS
defaced. Distributors must maintain all MSDSs
received with incoming shipments and obtain any Retail distributors are distributors that sell hazardous
MSDS requested by an employee. MSDSs must be chemicals in a retail store, such as a photo or camera
readily accessible in the workplace. Employees must store. If a retail distributor sells to a commercial account
receive hazard communication training to the extent (generally in large quantities over time and at a
necessary to protect them from hazards in the event ofdiscount from regular retail price), MSDSs must be
a leak or spill. A written hazard communication maintained and obtained for all hazardous chemicals
program is not required for these operations, but may provided to the commercial accounts. The distributor
be a good idea to be sure that your program is must post a sign to inform the commercial account of
implemented and documented. the availability of the MSDS and must provide the
Distributors of hazardous chemicals are responsibleMSDS upon request. The MSDS is not required to be
for transmitting hazard information to users of the provided unless requested by the commercial account.
chemicals. This is accomplished primarily through the A retail distributor who does not have commercial
MSDS and the container labels. Distributors can be accounts is not required to provide MSDSs. Upon
request of a purchaser who has employees, the
classified as either wholesale or retail and have specific
requirements around the management and distribution distributor must provide the name, address, and
of MSDSs. telephone number of the manufacturer/importer/
distributor where the MSDS can be obtained.
MSDSs for Kodak products can be obtained directly
from Kodak by calling the Kodak Information Center at
(800) 242-2424, ext. 25.
Summary of Distributor Hazard Communication Requirements

Wholesale Wholesale Retail Distributor Retail Distributor


Requirement Description Distributor with Distributor without with Commercial without Commercial
Counter Sales Counter Sales Accounts Accounts
Written Hazard Communication Program No No Yes No
Ensure incoming labels are intact Yes Yes Yes Yes
Maintain received MSDSs Yes Yes Yes Yes
Obtain MSDS when requested by employee Yes Yes Yes Yes
Hazard Communication employee training Yes Yes Yes Yes
Obtain MSDS for hazardous chemicals that
Yes Yes Yes No
are distributed
Provide MSDS with shipment Yes Yes No No
Post Sign of MSDS availability Yes No Yes No
Provide MSDS to user upon request No (provide information
Yes Yes Yes
on how to obtain)

Hazard Communication for Photographic Processing Facilities J-311 11


REPACKAGING AND BULK MIXING CONTAINER LABELING
PHOTOGRAPHIC PROCESSING
CHEMICALS The label on a container of a hazardous chemical that is
initially packaged or repackaged for distribution must
Facilities that repackage or bulk mix photographic include:
processing chemicals for distribution are treated like The identity of the hazardous chemical (name from
manufacturers under the Hazard Communication MSDS)
standard. These facilities need to determine if the Appropriate hazard warnings
products they produce are hazardous chemicals and Name and address of the manufacturer
need to label containers and provide MSDSs.
There may also be additional labeling information
required by your state Right-to-Know laws.
HAZARD DETERMINATION

If you are repackaging a product, you can rely on the MATERIAL SAFETY DATA SHEETS
manufacturer to make the hazard determination. If the (MSDSs)
material is a hazardous chemical, the label and the
You will also be required to provide a MSDS for each
MSDS on the material you received will indicate the
hazardous chemical to your customers. Repackaged
hazards. If you are bulk mixing to a formula or
chemicals or mixed working strength solutions can use
producing working strength photographic processing
the MSDS provided by our supplier as long as the
solutions for distribution, you should check with your
name of the product is not changed. For renamed
supplier for assistance with this determination.
products or products that do not have an available
MSDS from your supplier, you are responsible for
generating and providing a MSDS.

12 Hazard Communication for Photographic Processing Facilities J-311


J-110 Formaldehyde Use in Photographic Processing
MORE INFORMATION Facilities
J-111 Determining Workplace Exposure to Formaldehyde
If you have environmental or safety questions about
Kodak products or services, contact Kodak J-112 Formaldehyde Emergencies
Environmental Services at 1-585-477-3194, between 8 J-113 About the OSHA Formaldehyde Standard
a.m. and 5 p.m. (Eastern time) or visit KES on-line at J-312 Personal Protective Equipment Requirements in
www.kodak.com/go/kes. Photographic Processing Facilities
Kodak also maintains a 24-hour health hotline to J-313 Occupational Noise Exposure Requirements for
answer questions about the safe handling of Photographic Processing Facilities
photographic chemicals. If you need health-related J-316 Emergency Preparedness for Photographic
information about Kodak products, call Processing Facilities
1-585-722-5151. J-317 Injury and Illness Management for Photographic
For questions concerning the safe transportation of Processing Facilities
Kodak products, call Kodak Transportation Services at
1-585-722-2400.
Additional information is available on the Kodak
website and through the Canada faxback
system.
The products and services described in this
publication may not be available in all countries. In
countries other than the U.S., contact your local Kodak
representative, or your usual supplier of Kodak
products.
The following publications are available from Kodak
Customer Service or from dealers who sell Kodak
products.

For more information about Kodak Environmental Services,


visit Kodak on-line at:
www.kodak.com/go/kes
Many technical support publications for
Kodak products can be sent to your fax machine
from the Kodak Information Center. Call:
Canada 1-800-295-5531
Available 24 hours a day, 7 days a week
If you have questions about Kodak products, call Kodak.
In the U.S.A.:
1-800-242-2424, Ext. 19, MondayFriday
9 a.m.7 p.m. (Eastern time)
In Canada:
1-800-465-6325, MondayFriday
8 a.m.5 p.m. (Eastern time)

Hazard Communication for Photographic Processing Facilities J-311 13


This publication is a guide to the Federal Health and Safety Regulations that apply
to a typical photographic processing facility. Local or state requirements may also
apply. Verify the specific requirements for your facility with your legal counsel.

The photographs in this publication were taken with a


KODAK PROFESSIONAL DCS 420 Camera.

EASTMAN KODAK COMPANY ROCHESTER, NY 14650

Hazard Communication for Photographic Processing


Facilities Kodak, Ektacolor, X-Omat,
KODAK Publication No. J-311 and e mark are trademarks. Revised 4/99
CAT No. 869 6957 Printed in U.S.A.

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