The American Industrial Hygiene Association (AIHA) participated in a public hearing hosted by OSHA to discuss modifications to the hazard communication standard (HCS) to conform to the United Nations’ Globally Harmonized System of classification and Labeling of Chemicals (GHS).
“AIHA shares the concerns that inaccurate, incomplete and outdated material safety data sheets (MSDSs) can increase risks of illnesses and injuries and environmental consequences arising from the handling, storage, transportation and use of hazardous chemicals,” said AIHA President Cathy Cole, CIH, CSP. “Industrial hygiene, safety, emergency response and environmental health professionals rely on MSDSs as a source of information to assist employers and employees properly manage hazardous chemicals.”
In the proposal comments, AIHA discussed parts of the OSHA proposal that it supports and gave recommendations regarding areas of concern. Cole further stated, “AIHA agrees the proposed modifications to HCS will improve the quality and consistency of hazard communication information provided to employers and employees.”
One of the recommendations that AIHA makes is on the proposed requirement that OSHA permissible exposure limits (PELs), as well as other exposure limit used or recommended by the chemical manufacturer/importer are included on the safety data sheet. AIHA believes that if OSHA allows the inclusion of other occupational exposure limits used or recommended by chemical manufacturers, importers, or employers, then the agency must take this a step further and add a non-mandatory appendix to the HCS to incorporate reference to the TLVs and other occupational exposure limits like the workplace environmental exposure levels (WEELs).
AIHA cited several explanations as to why the requirement should be extended to include these additional occupational exposure limits. The association also requests that OSHA work with stakeholders to address the issue of updating PELs. In its conclusion, AIHA highlights parts of OSHA’s proposal that it supports, including the proposed implementation schedule in the proposal.
“The GHS, when fully implemented, will facilitate international trade in chemicals and provide a recognized framework that adds to the protection of employers and employees,” said Cole. “AIHA pledges our full assistance to OSHA, other regulatory bodies, industry and the international community to see that the GHS accomplishes its intended objectives. AIHA’s concern continues to be the prevention of health risks to workers and others”.
AIHA’s full comments are available for review.