AIHA Offers OSHA Feedback on Hazard Communication

June 29, 2004
OSHA has asked the public for comments on the agency's efforts to improve the accuracy and quality of Material Safety Data Sheets (MSDSs) and the training of workers in chemical hazards.

The American Industrial Hygiene Association (AIHA) has obliged, by providing some constructive criticism on two draft documents pertaining to the agency's hazard communication standard: OSHA's Guidance for Hazard Determination and the OSHA Hazard Communication Model Training Program.

"AIHA appreciates the opportunity to provide input in support of the overall goal to improve the accuracy, quality, and maintenance of MSDSs and the training of workers in chemical hazards," said AIHA President Donna Doganiero, CIH.

The association's Stewardship and Sustainability and Communication and Training Methods committees held a meeting May 12 to discuss and develop feedback to OSHA's proposed documents. The comments are reflected in a June 16 letter to OSHA.

AIHA encouraged the agency to define more clearly the different audiences for these documents, put a process in place to ensure the learning needs of these groups are met, and distinguish regulatory elements from best practices that exceed OSHA requirements.

While the AIHA reviewers approved of the inclusion of best practices, they thought these practices should be identified as such, in order not to create de facto rulemaking.

An example cited in the association's letter is OSHA's recommendation that tests be performed as part of hazard determination. "This is not required by the OSHA Hazard Communication standard and has the potential to cause conflicts as to whether to follow the standard or the more prescriptive guidance document."

The association also suggested simplifying the documents to be appropriate tools for individuals without extensive health and safety training and providing supplemental information on the OSHA Web site for those who seek further direction or information.

AIHA and OSHA signed a strategic alliance agreement in October 2002, which was recently renewed. As a part of this ongoing relationship, the association promised to work with OSHA to understand the agency's hazard communication goals and the audiences OSHA is aiming to serve with the Model Training Program for Hazard Communication and Guidance for Hazard Determination.

The complete transcript of AIHA's comments can be found on the Government Affairs page of the association's Web site.

Sponsored Recommendations

Free Webinar: ISO 45001 – A Commitment to Occupational Health, Safety & Personal Wellness

May 30, 2024
Secure a safer and more productive workplace using proven Management Systems ISO 45001 and ISO 45003.

ISO 45003 – Psychological Health and Safety at Work

May 30, 2024
ISO 45003 offers a comprehensive framework to expand your existing occupational health and safety program, helping you mitigate psychosocial risks and promote overall employee...

DH Pace, national door and dock provider, reduces TRIR and claims with EHS solution

May 29, 2024
Find out how DH Pace moved from paper/email/excel to an EHS platform, changing their culture. They reduced TRIR from 4.8 to 1.46 and improved their ability to bid on and win contracts...

Case Study: Improve TRIR from 4+ to 1 with EHS Solution and Safety Training

May 29, 2024
Safety training and EHS solutions improve TRIR for Complete Mechanical Services, leading to increased business. Moving incidents, training, and other EHS procedures into the digital...

Voice your opinion!

To join the conversation, and become an exclusive member of EHS Today, create an account today!