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NIOSH Testimony on the Hazard Communication Standard by J. D. Millar June 15, 1982.

NIOSH 1982 Jun:4 pages
This testimony contains information which demonstrates the support of NIOSH for a Hazard Communications regulation. NIOSH does, however, address several serious questions concerning the adequacy of the current proposed standard. Two major areas are considered in this testimony: scope of coverage and hazard definition. NIOSH opposes the exemption of importers from coverage by this rule as this exemption will place an increased burden on covered employers who will find it difficult to determine the contents and degree of hazard of imported chemicals. NIOSH also suggests that the rule be expanded to include other classes of industry beyond SIC Codes 20 to 39. A related problem with coverage concerns the common use of contract employees for construction and maintenance in the covered industries. NIOSH is also concerned about the exemption of piping systems from the proposed rule and suggests that laboratories in the covered industries should be included in the rule. The second major area of concern is the lack of detailed guidelines or scientific criteria for making the determination of whether a substance is hazardous. NIOSH believes that clear definitions for the various hazard determination terms used in the proposed standard are needed. NIOSH is also concerned about the lack of uniformity in the design of and information contained on labels generated by various industries.
NIOSH-Author; NIOSH-Testimony; Millar-J-D; Safety-practices; Regulations; Legislation; Worker-health; Work-environment; Health-hazards; Industrial-hazards; Occupational-hazards;
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NIOSH, 4 pages