SPEAK NOW OR FOREVER HOLD YOUR PEACE

If you have professional or even personal issues with the present 1910.1200 Occupational Health and Safety Administration’s (OSHA), Global Harmonization Standard (GHS), Hazard Communication requirements then, you should check out the February 16, 2021 proposed rule and it’s comment period. It’s being updated to ensure the standard reflects lessons learned from past industrial experiences, the current state of scientific knowledge and other international and federal agency input. You now have a chance to be heard.

 Download: The February 16, 2021 Proposed rule and Preamble 

OSHA first established the 29 CFR 1910.1200, “Right to Know'' requirements back in 1983, then in 2012 harmonized it with with the United Nations, Globally Harmonized System of Classification and Labelling of Chemicals (GHS), to provide workers with the tools and training to recognize health hazards encountered in the workplace, with the goal of identifying, understanding, and communicating the hazards of the chemicals that they come in to contact with before they experience casual, acute or chronic exposure.

The proposed rule’s comment period ends April 19, 2021. So if you have concerns, (or even want to request the need for a public hearing), on OSHA adding definitions, implementing enforcement policies, incorporating compliance directives and international requirements, let them know. 

See the Guidance documents and FAQ, on OSHA’s Hazard Communication webpage.

In addition to international recommendations and evolving scientific knowledge, the proposed rule hopes to incorporate past Letters of Interpretation (LOI) issued by OSHA in regards to the labeling of small containers, pictogram provisions, the marking of shipping containers and the use of concentration ranges for trade secrets. 

Browse the 1910.1200 Hazard Communication Letters of Interpretation, (LOI). 

OSHA believes many SDS’s lack adequate information to communicate hazards and precautions. In studies they found that data on individual ingredients within mixtures was missing and in many cases information on hazard characterization and classification could be “ambiguous and almost entirely incorrect”. 

With this in mind, OSHA has raised additional concerns with and is requesting comments on, exposure to engineered nanomaterials like silver, silica and titanium dioxide which can be taken up in the lungs causing inflammation, tissue damage, fibrosis and tumour generation. They have concerns over the manufacture, use and disposal of these nanomaterials, as they may penetrate cell membranes and cause damage to intracellular structures and cellular functions. Their concerns range from antimicrobials in clothing to materials that come into contact with food.

The proposed rule’s contact is Frank Meilinger, Director of Office of Communications, telephone: (202) 693–1999; email: meilinger.francis2@ dol.gov. However, it notes for general information and technical inquiries to reach out to Maureen Ruskin, Acting Director, Directorate of Standards and Guidance, telephone:(202) 693–1950; email: ruskin.maureen@dol.gov.

We will of course cover the OSHA GHS proposed changes and clarifications in my future seminars and blogs. But, in the meantime if you have specific questions, or just lonely, call or email us. 

Robert J Keegan 
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc.
Hazmat.tsp@gmail.com