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.