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ASSE says revised OSHA hazcom rule should address control banding (1/5)

January 5, 2010
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The American Society of Safety Engineers (ASSE) President C. Christopher Patton, CSP, noted in a letter sent recently to Assistant Secretary of OSHA David Michaels that ASSE supports the goal of the Hazard Communication proposed rule, a rule that seeks to ensure that the hazards of all chemicals produced or imported are evaluated and communicated to employers and employees, according to an ASSE press release. ASSE notes that modifying OSHA’s existing Hazard Communication Standard (HCS) is a step forward in harmonizing chemical hazard communications worldwide and will help U.S. employers compete in the international marketplace as well as increasing work safety.

“Modifying OSHA’s existing HCS to incorporate major portions of the United Nations' (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is necessary to help this nation’s workers deal with the increasingly difficult challenge of understanding the hazards and precautions needed to handle and use chemicals safely in the world marketplace,” Patton wrote. “At the same time, harmonizing hazard communications with GHS will help U.S. employers compete in that marketplace by lessening the burden of conforming with different regulations and by ensuring their products will meet hazard communication requirements in other nations.”

Patton applauded OSHA for its leadership in undertaking the HCS rulemaking and urges every possible step be taken to achieve a final rule as soon as practical.

“However, ASSE is disappointed to see that control banding has been largely ignored in the development of the revised standard,” Patton said.

In June 2005, ASSE published Control Banding and the Future of the HazCom Standard (http://www.asse.org/professionalaffairs_new/positions/hazcom.php), a position paper that urged OSHA and the Mine Safety and Health Administration (MSHA) to consider the use of Control Banding (CB) models in a revised HCS. From the ASSE review of the leading international resources on CB – the HSE/COSHH-Essentials process (http://www.coshh-essentials.org.uk/) as well as the International Labor Organization’s Tool Kit (http://www.ilo.org/safework/lang--en/index.htm) – ASSE believes OSHA should update the HCS to incorporate elements of CB.

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), according to the National Institute of Occupational Safety and Health (NIOSH). 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.

“When this nation is so close to harmonization with GHS, it would be unfortunately short-sighted not to take the extra step of incorporating control banding since many of the necessary tools to do so are already included in this rulemaking,” Patton said. “To do so would advance harmonization a significant step further and avoid the need for future rulemaking, which ASSE firmly believes will be necessary as control banding becomes more widely accepted in the international marketplace.”

In his letter, Patton outlined ASSE’s more specific comments concerning issues and questions asked in the rulemaking. Those comments include need and support for the standard; its economic impact and economic feasibility; implementation resources; reducing the impact on small businesses; opposing the exclusion of three physical and health hazard classes and overall hazard classification; label layout; safety data sheets; references – ASSE suggests OSHA reference in the standard a variety of scientific and authoritative references for end users; earlier effective dates; outreach needs; and proposed alternative implementation approaches.

In conclusion, Patton noted, “Harmonizing this nation’s hazard communications with the international marketplace is both a safety and health issue for this nation’s workers and a competitive issue for its employers. Daily, our members experience the reality that we live in a world of commerce that is becoming more and more interconnected. They need the tools to help both the employees and employers with whom they work. To that end, all employers should be required to adopt a revised HCS.”

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