NIOSH Testimony on Hazard Communication by J. D. Millar, December 6, 1988.
NIOSH 1988 Dec:4 pages
This testimony was presented in support of earlier information concerning OSHA's final rule to extend coverage of the Hazard Communication Standard to those workers in nonmanufacturing employment as well as those employed in the manufacturing sector. The concept of hazard communication in the workplace was fully supported by NIOSH. It would be desirable to achieve uniformity in the design of and information contained on labels generated by the various industries. One general concern about the OSHA rule was the lack of detailed guidelines on scientific criteria for making the determination of whether a substance is hazardous. The efforts of NIOSH which would be useful as a source of information in determining hazards were again cited. A total of 129 Criteria Documents and 50 Current Intelligence Bulletins have been transmitted from NIOSH to OSHA, each of which would be useful for this purpose and should be included in the resource tools used to establish which chemicals are dangerous. NIOSH agreed with OSHA's view that the extent of risk or size of employer should not be determining factors with regard to a decision as to whether the information must be conveyed. Consumer products used in an industrial setting may carry hazards beyond those anticipated in the home and should also be covered in the label requirements. Material safety data sheets would provide a base determination of hazard potential and enhance the ability of both employers and workers to identify hazardous chemicals.
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