Fed standards rewritten into 'plain language'
More federal safety standards are being rewritten into "plain language" to make them easier to understand, and the hazard communication standard is being changed so that a brick can no longer be listed as a hazardous chemical.
The federal Occupational Safety and Health Administration (OSHA) is rewriting worker protection rules for dipping and coating operations so that the requirements can be better understood. This is the second "plain language" initiative undertaken by OSHA. The dipping and coating standards, 29 CFR 1910.108, are designed to protect workers from fire, explosion, and other hazards associated with those operations. The rewritten rules do not change any requirements for employers, but they make the standards much easier to understand. For instance, the old standard stated that, "When waste or rags are used in connection with dipping operations, approved metal waste cans shall be provided and all impregnated rags or waste deposited therein immediately after use."
Instead, the newly rewritten standard states, "Rags or other material contaminated with liquids from dipping and coating operations must be placed in an approved waste can immediately after use. . . ."
In another move, OSHA is trying to make it easier for employers to comply with the agency's hazard communication standard. The standard requires employers to provide information about dangerous chemicals through substance labeling, material safety data sheets, and employee training. In a new directive, OSHA attempts to clear up some misunderstandings. For example, the directive clarifies the issue of electronic access to material safety data sheets, stating that employers may provide the sheets through computers, microfiche machines, the Internet, CD-ROMs, and fax machines. But employees also must be able to access hard copies of the sheets, and the employer must be able to provide the sheets to medical personnel in an emergency.
OSHA also is clarifying its policy on issuing citations for consumer products. In the past, employers have been cited for failing to adhere to the hazard communication standards when using common consumer products, not industrial or commercial-grade substances.
Now the citations will be issued only when the consumer product is used in a manner inconsistent with the manufacturer's intentions or when the exposure to the product greatly exceeds that expected of an ordinary consumer. OSHA provides the example of a windshield cleaning fluid that is intended for use in a car's closed windshield cleaning system. If a worker uses that same solution every day for cleaning windows by hand, the worker would be covered by the hazard communication standard even though the solution is a product intended for consumer use.
The policy clarification also means that OSHA compliance officers must describe the specific hazardous chemical in the product. OSHA will no longer issue citations stating that the hazardous chemical was "brick" or "glue." From now on, the compliance officer must specify that the material was a specific substance like toluene, silica, methyl ethyl ketone, or sodium hydroxide.
The new directive is CPL 2-2.38D, "Inspection Procedures for the Hazard Communication Standard."
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