February 21, 1997

Charlie Crawford
Kaiser Permanente NW
2701 NW Vaughn, Suite 150
Portland, OR 97210-5398

Mr. Crawford:

This letter is in response to your letter of February 5, 1997, regarding the applicability of OAR437-02-1910.1200, "Hazard Communications," to drugs.

You explained that containers of liquids, creams, and gels are re-labeled by pharmacy staff and provided to patients for self-administration. In this instance, the standard only applies to pharmaceuticals that the drug manufacturer has determined to be hazardous and that are knownto be present in the workplace in such a manner that employees are exposed under normal conditions of use or in a foreseeable emergency. The pharmaceutical manufacturer and the importer have the primary duty for the evaluation of chemical hazards. The employer may rely upon the hazard determination performed by the pharmaceutical manufacturer or importer.

We hope this answers your question regarding this matter. If you have any questions or if wecan be of further assistance, please contact David McLaughlin at (503) 378-3272.

Sincerely,

Marilyn K. Schuster, Manager
Standards and Technical Resources Section
Oregon Occupational Safety and Health Division