“ASSE applauds OSHA for its leadership in undertaking this effort,” Garman said. “We agree with much of what has been proposed and urge that a final rule be promulgated as soon as possible. Our members, many [of whom] already [are] working to harmonize their employers’ efforts to comply with OSHA and international hazard communication requirements, tell us their employers will, in the long term, benefit from the greater competitiveness in a global marketplace that harmonized hazard communications will bring. It will also provide uniformity and increased worker safety and health.”
Garman said one area of concern was the issue of CB and urged that it be included in the standard. According to the National Institute of Occupational Safety and Health (NIOSH), CB is a technique used to guide the assessment and management of workplace risks. It is a generic technique that determines a control measure (for example dilution ventilation, engineering controls, containment, etc.) based on a range or “band” of hazards (such as skin/eye irritant, very toxic, carcinogenic, etc.) and exposures (small, medium, large exposure).
It is an approach that is based on two pillars; the fact that there are a limited number of control approaches, and that many problems have been met and solved before. CB uses the solutions that experts have developed previously to control occupational chemical exposures, and suggesting them to other tasks with similar exposure situations. It is an approach that focuses resources on exposure controls and describes how strictly a risk needs to be managed. NIOSH notes that it considers CB a potentially useful tool for small businesses.
“The hazcom standard now is largely a paper exercise that causes employers to focus on written programs, labels, and training. It requires employers to provide a system, but one that results in employees looking only at the MSDS of single materials without any understanding of the larger system,” Garman said. “So, the employee makes decisions with little guidance on how to consider classifying hazards, scale of use, ability of materials to become airborne, or controls like PPE and mechanical ventilation.”
Garman noted that ASSE members already are using CB to help employers develop hazard communications, especially employers who are operating internationally. He said ASSE is concerned that OSHA could face a need to revise the standard to incorporate control banding late in the process if they do not do it now. Garman also discussed other issues involving the ruling in his testimony and noted that ASSE and it members were available at all times to assist in the next steps of revising the standard.