Comments on: OSHA Requests Comments on Change in HAZCOM Standard http://ohshub.com/osha-requests-comments-on-change-in-hazcom-standard/ Health & Safety at the Center of Our World Mon, 25 Apr 2011 01:44:53 +0000 hourly 1 http://wordpress.org/?v=3.3 By: admin http://ohshub.com/osha-requests-comments-on-change-in-hazcom-standard/#comment-31 admin Sun, 18 Oct 2009 23:58:03 +0000 http://ohshub.com/?p=678#comment-31 John, I tend to agree with you on OSHA's weakness from the HAZCOM standpoint. In addition to the example you pointed out (i.e. 2 raw materials create a more hazardous material), consider their past stances on products such as icynene where only the final product was subject to scrutiny - the people exposed to the precursors where afforded little protection (check out some their recent interpretation letters). Combustible dust is most likely only going to grow in size. It will be interesting to see where we with this issue in 15 years. -George OHShub.com John,

I tend to agree with you on OSHA’s weakness from the HAZCOM standpoint. In addition to the example you pointed out (i.e. 2 raw materials create a more hazardous material), consider their past stances on products such as icynene where only the final product was subject to scrutiny – the people exposed to the precursors where afforded little protection (check out some their recent interpretation letters).

Combustible dust is most likely only going to grow in size. It will be interesting to see where we with this issue in 15 years.

-George
OHShub.com

]]> By: John Astad http://ohshub.com/osha-requests-comments-on-change-in-hazcom-standard/#comment-30 John Astad Sun, 18 Oct 2009 22:02:27 +0000 http://ohshub.com/?p=678#comment-30 OSHA needs to fix their own HAZCOM standard before global harmonization. Many aspects of GHS are fine concerning consumer protection, pesticides, and transportation yet communicating and managing the hazards in the industrial manufactruing sector is weak. For example, there is no provision in the current OSHA HAZCOM standard in addressing physical hazards that midstream users are exposed to in the life cycle where the raw material has changed from a seemingly harmless product into one that evolves into a potentially explosive atmosphere with combustible dust. An excerpt from the HAZCOM proposed rule states this issue succinctly: "That is, chemical manufacturers and importers tend to have greater knowledge and scientific expertise with respect to the composition of the chemicals they make or import. See 48 FR 53306, 53322." "Therefore, they are usually in the best position to assess the inherent hazards associated with them. Id. However, it is the downstream users and their employees who tend to have the best information about the means and methods of exposure, and are therefore usually in the best position to determine the risk arising from the use of the chemical in their workplaces. See 48 FR 53295–96, 53307; 59 FR 6132." From what I can gather from the above, downstream users must have their combustible dust tested for ignition sensitivity and explosion severity in providing supplemental information to the initial MSDS. OSHA needs to fix their own HAZCOM standard before global harmonization. Many aspects of GHS are fine concerning consumer protection, pesticides, and transportation yet communicating and managing the hazards in the industrial manufactruing sector is weak.

For example, there is no provision in the current OSHA HAZCOM standard in addressing physical hazards that midstream users are exposed to in the life cycle where the raw material has changed from a seemingly harmless product into one that evolves into a potentially explosive atmosphere with combustible dust.

An excerpt from the HAZCOM proposed rule states this issue succinctly:

“That is, chemical manufacturers and importers tend to have greater knowledge and scientific expertise with respect to the composition of the chemicals they make or import. See 48 FR 53306, 53322.”

“Therefore, they are usually in the best position to assess the inherent hazards associated with them. Id. However, it is the downstream users and their employees who tend to have
the best information about the means and methods of exposure, and are therefore usually in the best position to
determine the risk arising from the use of the chemical in their workplaces. See 48 FR 53295–96, 53307; 59 FR 6132.”

From what I can gather from the above, downstream users must have their combustible dust tested for ignition sensitivity and explosion severity in providing supplemental information to the initial MSDS.

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