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downstream along with the chemicals. (Paragraphs , ). cycling ride think less ride more retro poster Third, all employers must develop a written hazard communication program and provide information

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amendments to the existing HCS to enhance its effectiveness. The information provided under hazard communication will also enable health and safety professionals to provide better services cycling ride think less ride more retro poster to exposed employees. (E.g., Exs. 4-153, 71-37.) Medical surveillance, exposure monitoring, and other such services will be enhanced by the ready availability of health and safety information. The three information components in this system – labels, material safety data sheets, and worker training – are all essential to the effective functioning of the program. The MSDSs provide comprehensive technical information, and serve as a reference document for exposed workers as well as health professionals providing services to those workers. The labels provide a brief synopsis of the hazards of the chemicals at the site where the chemical is used in the work area.

Training ensures that workers understand the information on both MSDSs and labels, know how to access this information when needed, and are aware of the proper protective procedures to follow. Each component effectuates the others. See General Carbon Co. v. OSHRC, 860 F.2d 479, 481 (DC Cir. 1988). The purpose of the HCS is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. In broad outline, the HCS achieves its purpose by an integrated three pronged system. First, chemical manufacturers and importers must review available scientific evidence concerning the physical and health hazards of the chemicals they produce or import to determine if they are hazardous. (Paragraph ). Second, for every chemical found to be hazardous, the chemical manufacturer or importer must develop comprehensive material safety data sheets and warning labels for containers and send both