Resources that deal with chemical
characteristics,
hazards, and permissible exposure
levels.
The National Safety Council maintains this site on Computer-Aided
Management of Emergency Operations.
This site accepts
chemical name, CAS Number, molecular formula, or molecular weight and returns
physical characteristics (melting and boiling points, evaporation rates, etc.)
as well as reference numbers (CAS numbers, RTECS number, EPA code, and DOT
number). Very handy if one is trying to
review or write an Material Safety Data Sheet or review the adequacy of an
existing one.
This page
contains information on a number of chemicals that have been evaluated by the
National Toxicology Program.
The National Oceanic and Atmospheric Administration has free program to
assess the reactivity of substances and mixtures called the Chemical
Reactivity Worksheet
The US Fire Administration has prepared this Hazardous Materials Guide
The National Fire Protection Association (NFPA) maintains this page
16
CFR 1500 - CPSC regulations relating to the Federal Hazardous Substances Act
The Law.com website has this
analysis of a ruling concerning the pre-emption of state statutes regarding
labeling of a flammable chemical by the Federal Hazardous Substances Act
Order
page for ANSI Z 129.1, Hazardous Industrial Chemicals - Precautionary Labeling
The Hazard Communication Standard
sets out the training and other requirements for employers of workers who may
be exposed to hazardous or toxic chemicals. Section 3 of the preamble
to the Hazard Communication Standard contains some interesting and illuminating
comments by OSHA on the (lack of) effectiveness of warning labels in the
absence of proper training and supervision. The following comments are
excerpted from this section.
Some of the comments on the role of labels versus data sheets revealed a
lack of information on the part of the participants regarding available
research on the role of labeling. For example, one commenter indicated that
there are "hundreds" of studies that indicate labels are effective,
and thus the preferred means of transmitting information (Ex. 11-108). When
asked during the hearing to provide a bibliography of these studies (Tr.
3-182), the American Dental Trade Association suggested that OSHA consult the
ANSI labeling standard for such a bibliography.
The ANSI labeling standard does not contain any such information. The
one study referenced is one on symbols that was conducted in conjunction with
the development of the standard. That study concluded that many commonly used
symbols are not well - recognized, and thus are not effectively transmitting
hazard information. Based on that study, the ANSI committee decided not to
include requirements for symbols in the standard. Ex. 49.
The chairman of the ANSI committee testified on behalf of the Chemical
Manufacturers Association (Tr. 6-6-39). He is also chairman of the Board of a
professional society (formerly the American Conference on Chemical Labeling but
now the Society for Chemical Hazard Communication) of experts on labeling and
material safety data sheets. OSHA asked him if he or the ANSI committee were
aware of "hundreds" of studies regarding the effectiveness of labels,
and he replied: "No, I am not aware of any studies of that nature."
Tr. 6-29. Mr. Talcott further indicated that "a full hazard communication
program really includes the label, a properly constructed label, but it has
other parts. And the data sheet, as well as the hazard determination and
training programs serve very vital parts in that full hazard communication
program. And I think OSHA has properly recognized that there are multiple
parts, and a label alone is not going to be a full hazard communication
program." Tr. 6-28-29.
In fact, although there have been various labeling requirements and
practices for many years, there is little evidence that labeling results in a
change in behavior without the availability of other information and communication
mechanisms. See Ex. 71-23A, Handbook of Chemical Industry Labeling: "[T]he
editors have found no published research which clearly isolates the effect of a
given label on a specific chemical product from the effects of other factors
including inserts, training, general media information, advertising and
promotion or consumerist activities."
It should also be noted that it was suggested that the labeling
requirements of the ANSI standard result in enough information for workers. Yet
the ANSI committee specifically addressed this issue in the preamble to the
standard: "Precautionary labels are not intended to include all
information on the properties of a chemical nor the complete details of its
handling under all conditions. Such information is more appropriately provided
through other means, such as material safety data sheets, technical bulletins,
training, or other communications intended to enhance and supplement the
label." Ex. 49.
Clearly, the genesis of many of the comments received
opposing the MSDS requirements is simply that these commenters do not want to
deal with them, rather than any objective evidence that they are not necessary.
As has been discussed at length in previous HCS Federal Register
documents (see preambles to original NPRM and final rule), the effectiveness of
a hazard communication program relies on the three-pronged approach in the HCS
(labels, MSDSs, and training). Each serves a different purpose, and they are
all interdependent on each other. No information provided during this
rulemaking proceeding has altered that finding.
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