On Tuesday September 21, Gary Jones, Director, Environmental Health and Safety for PRINTING United Alliance, provided testimony on the proposed changes to the Occupational Safety and Health Administration (OSHA)’s Hazard Communication Standard (HCS). The public hearing, held as a part of the rulemaking process, continues OSHA’s progress to updating the HCS to align with the seventh version of the United Nation’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The current version of the HCS, last revised by OSHA in 2012, is based on the third version of the GHS program.
PRINTING United Alliance’s comments focused on three important topics:
- The proposed requirement that importers and manufacturers anticipate every conceivable use and any subsequent hazards associated with that use and provide an appropriate warning.
- Recognition by the Agency that use of a color-coding system for secondary container content identification provides adequate in plant labeling
- Provide clarity on what constitutes an “Injurious and Corrosive Material”
One of the changes that OSHA proposed was to have importers and manufacturers predict how downstream end users will use their products and provide any subsequent hazard warnings on each of those uses. In its written comments, and supported by verbal testimony, Jones reiterated the Association's request for OSHA to remove this provision as it is virtually impossible for importers and manufactures of products to meet. Importers and manufacturers do not have a complete understanding of the hazards associated with the products they sell, nor do they have the resources to investigate and track how their products are used and, in some cases, misused by their customers.
Color coding for secondary container content identification continues to be a prominent issue for the printing industry as it is a frequent practice to store and dispense cleaning solvents in smaller containers such as a squirt bottle. Jones indicated in his public testimony that it is a constant battle to ensure that all secondary containers used for dispensing solvents have legible labels as the cleaning solvent can dissolve the ink on the label or the adhesive keeping the label on the container.
Color coding that uses dedicated containers along with an accompanying poster with all the required information at each workstation is a solution that works for the printing industry. Because a request for a letter of interpretation and a variance was denied, the only option is to change the regulation and OSHA was requested to revise the regulation by changing just one word and this would allow for colored coded containers and workplace posters. Once again, he urged OSHA to recognize this labeling system as an in-plant warning label program.
The final issue addressed was a request that OSHA revise its first aid regulation to provide a definitive definition for an “Injurious Corrosive Material.” Jones stated that OSHA’s regulation does not clearly specify what this means. With the release of the revised HCS in 2012, the printing industry experienced a rapid and sudden increase in the “corrosive” hazard statements and pictograms being placed on many materials that were historically not classified as such. Jones offered the example of water-based coatings which do not pose a concern. However, due to a slightly elevated pH these materials now carry the corrosive hazard statement and pictograms. These statements and pictograms could indicate that an “injurious corrosive material” is in use requiring an eyewash and/or trenching station nearby.