These comments, which were provided by the AIHA Stewardship and Sustainability Committee with assistance from individual AIHA members, address several key topics of the proposed revision that are relevant to AIHA membership. In its responses, AIHA expresses support for the Hazard Communication Standard (HCS) modification and its necessity in the workplace, according to an AIHA press release.
“As the premier association of occupational and environmental health and safety professionals, AIHA members serve on the front line of worker health and safety. AIHA members, as well as employers, rely on federal and state rules and regulations to improve the health and safety of the workplace and protect employees from hazards, including hazards associated with chemical manufacturing, labeling, and handling. We applaud the agency for taking this step in proposing this rule,” stated AIHA President Cathy Cole, CIH, CSP, in an accompanying letter to OSHA.
Cole went on to say that one of the Stewardship and Sustainability Committee’s goals is to “… increase the awareness and understanding of the Globally Harmonized System (GHS) among AIHA members, including providing comments on related regulations being proposed that affect product health and safety.”
The recommendations provided by AIHA specifically focus on hazard classification, chemical labeling, Safety Data Sheets (SDSs), labeling language modifications and definitions, and the scheduling of employee training once these changes are implemented.
In its comments on the proposal, AIHA emphasizes its support of
- the adoption of the detailed GHS criteria and weight of evidence approach to hazard evaluation and classification;
- the approach OSHA has taken to require the GHS precautionary statements to be on HCS labels;
- the modification of the language required for signs and labels to bear the same hazard statements that are required for all chemicals of the same classification;
- the immediate training of employees upon the issue of the final standard.
AIHA also conveyed its support of the efforts of OSHA to work with the international community in the development of criteria for combustible dust as part of the GHS regulations and encouraged the proposed development of a database of classifications.
In addition to supporting many parts of OSHA’s proposal, AIHA suggested enhancements to certain sections, such as an inclusion of a non-mandatory appendix to the HCS that contains reference to the Threshold Limit Values (TLVs) and other occupational exposure limits like Workplace Environmental Exposure Levels (WEELs).
