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|Title: 09/25/1991 - Labeling Requirements for Crystalline Silica Products.
|Record Type: Interpretation
|Standard Number: 1910.1200
September 25, 1991
William B. Bunn, III, M.D., J.D., M.P.H.
Health, Safety & Environment
Manville Sales Corporation
Post Office Box 5108
Denver, Colorado 80217-5108
Dear Dr. Bunn:
Thank you for your letters of March 18 and August 19, regarding interpretation and application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200. We apologize for the long delay of this response. You specifically requested that we confirm three interpretations of the HCS; the following statements have been restated from your most recent request of August 19:
If a hazardous material such as crystalline silica is present in a finished product, and if, under normal conditions of use, an employee could be exposed to more than very small quantities of that material, appropriate material safety data sheets and labels must be prepared and utilized to communicate the hazard. If the release is a very small quantity, but it still poses a physical hazard or health risk to workers, data sheets and labels must be prepared and utilized.
The percentage cut-offs you referred to are in the hazard determination provisions of the rule. The hazard determination provisions are only applied to the release, or the chemical(s) employees are actually or potentially exposed to under normal conditions of use. For more complete explanation of this interpretation, please see the notice of proposed rulemaking (NPRM) published on August 8, 1988, pp. 29833 through 29898 (copy enclosed.)
Protect workers from airborne hazards with supplied air respirator systems like this one from Safety Emporium.
"Exposure calculations are not permitted in determining whether a hazard must appear on a label. If there is potential for an exposure other than in minute, trace or very small quantities, the hazard must be included when substantiated as required by the HCS. Suppliers may not exclude hazards based on presumed levels of exposure downstream (i.e., omitting a carcinogenic hazard warning because, in the supplier's estimate, presumed exposures will not be high enough to cause the effect). The hazard is an intrinsic property of the chemical. Exposure determines degree of risk and should be addressed in training programs by the downstream employer." (Emphasis added.)
Patricia K. Clark, Director
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=20406&p_text_version=FALSE