OSHA’s modified hazard communication standard (HCS) mandates a highly controversial and divisive issue that was not addressed in the preamble. The issue may be the most important risk for chemical exposures. And the issue is something that OSHA most likely does not have the authority to regulate.
The term “unborn child” is the “hazard statement” that describes the classification of developmental toxicants (ref. C.4.10 FR pg. 17845). The lack of discussion on these words in the preamble may imply that everyone knows what “unborn child” means and how it should be applied. In this regard, OSHA and interested parties to the HCS are either naïve or cunning.