1910.1200 — “we don’t have chemicals here” is wrong in every data center.
The building is full of them. They are just in equipment rather than in drums, which is precisely why the program is usually thin and the SDSs are usually somewhere else.
§ What is actually in the building
| Material | Where | Why it matters |
|---|---|---|
| Sulfuric acid electrolyte | Flooded and VRLA batteries | Corrosive; drives 151(c) and 70E 360 |
| Lithium cell electrolyte / off-gas | Li-ion UPS and BESS | Flammable, toxic decomposition products |
| Diesel fuel | Day tanks, main tanks, transfer | Combustible; spill and vapour |
| Ethylene / propylene glycol | Chilled water loops | Toxicity differs sharply between the two |
| Refrigerants | CRAC/CRAH, chillers | Asphyxiant; oxygen displacement in a closed room |
| Clean agent suppression | Data halls, electrical rooms | Oxygen displacement, discharge velocity |
| Contact cleaners / solvents | Electrical maintenance | Flammable; often brought in by the vendor |
| Water treatment chemicals | Cooling towers | Biocides, corrosion inhibitors — frequently missed |
§ What the written program must do
List the hazardous chemicals known to be present, using a product identifier that matches the SDS and the label.
Describe labelling — how shipped containers are handled and how workplace containers get labelled.
Describe SDS handling — how they are maintained and how employees reach them.
Describe training — at initial assignment and whenever a new hazard is introduced.
Cover non-routine tasks and chemicals in unlabelled pipes — the glycol loop and the fuel line both qualify.
Cover other employers — how contractors get told what is here and how you get told what they brought.
§ Readily accessible means readily accessible
Electronic SDS access is acceptable, with conditions OSHA has been consistent about: no barriers to access, employees trained on the system, and a backup for power or network failure.
A network-hosted SDS library is unreachable during exactly the event where you need it — a power incident, a fire alarm, a network outage. If the plan for a battery spill depends on a browser reaching a vendor portal, the plan does not work. Keep a paper set in the battery room and the generator building.
NFPA 70E Article 360 is explicit about the SDS being available where batteries are worked on. That is a 70E requirement and a HazCom requirement, and it is the same sheet of paper. Satisfy both in one place.
The chemical nobody inventories is the one the vendor brought — the contact cleaner in the switchgear tech’s bag, the epoxy in the cable splicer’s kit. Under the multi-employer doctrine that is your worksite.
§ The multi-employer piece
- You must inform other employers of the hazards their people may be exposed to here, and how to reach the SDSs.
- They must inform you of what they bring in. Put it in the work order, not just the contract.
- The labelling system has to be explained to them — including any workplace-specific labels you use.
- See the multi-employer worksite doctrine for how citations attach.
A HazCom program built around the janitorial closet — floor cleaner, glass cleaner, all correctly listed — with no entry at all for the 480 flooded cells in the battery room, because “that is equipment, not a chemical.”
Batteries are four hazards, not one
Article 360 puts chemical alongside thermal, shock and arc flash. If your battery training only covers the electrical hazard, three quarters of the article is missing.
See the schedule Bring it onsite