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|Title: 12/01/1998 - Hazard determination; labeling of solid materials.|
|Record Type: Interpretation||Standard Number: 1910.1200(d); 1926.59(d); 1910.1200(f)(2); 1926.59(f)(2)|
December 1, 1998
Mr. J. J. Wherry
Grinding Wheel Institute
30200 Detroit Road
Cleveland, Ohio 44145-1967
Dear Mr. Wherry:
We have received your letter of August 6, addressed to Mr. John B. Miles Jr., Director, Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP), in which you asked questions regarding labeling under the Hazard Communication Standard (HCS), 29 CFR 1910.1200. Thank you for your inquiry. For clarity, your questions are paraphrased below.
The HCS does not require testing to determine the presence of a hazardous chemical. The rule covers chemicals which are "known to be present." The release of a very small quantity (that is, a few molecules or trace amounts) of a hazardous chemical is not covered by the rule. For instance, one may assume that an item, such as newly varnished furniture, emits chemicals. This, however, would not be covered under the HCS.
This definition of the article exemption has not changed since the standard was originally published in 1983. In 1994, the definition was amended to provide clarification. Further guidance is provided on page 31865 of the Federal Register, Volume 52, Number 163, published on Monday, August 24, 1987.
There is no pre-set list of testing requirements. Manufacturers may test a mixture "as a whole" or may rely on tests which have been scientifically conducted. The purpose of the hazard determination is to provide known information for the elements listed under paragraph (g) of the standard. It is the manufacturer's prerogative to "test as a whole" for any or none of these elements.
Labeling requirements for items which are solid materials, but do not classify as articles, are described in paragraph (f)(2) of the standard.
Protect your employees from sandblasting and paint spray with fresh air pumps and supplied air respirators from Safety Emporium.
Richard E. Fairfax
Directorate of Compliance Programs
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22657&p_text_version=FALSE