specific hazard communication provisions (57 FR 22290; May 27, 1992). corona extra beer crocs The requirements of this specific standard with regard to hazard communication now supercede the generic HCS provisions.
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(i.e., there is a specific subparagraph dealing with food and alcoholic beverages, another with drugs, and a third with cosmetics). Another commenter stated that adding the exemption corona extra beer crocs for fluids and particles confused the issue, and it should be deleted (Ex. ). OSHA does not agree. Fluids and particles never met the definition in the exemption anyway, and stating that explicitly ensures the definition is interpreted correctly and is consistent with EPA’s definition of an article. One commenter indicated that most medical devices are articles (Ex. ) – OSHA agrees that this is probably true, since medical devices include such items as crutches, etc. Where this is not true and hazardous chemicals are not completely bound up in the medical device, it would not be an article.
It was also noted that trace amounts will be difficult to determine (Ex. ). It was also suggested that for polymers, the primary concern should be what employees are exposed to, not simply the constituents (Ex. 11-51). This is true for all articles, and is the approach OSHA has adopted. A number of other comments were also received. One suggestion (Ex. 11-51) was that further consideration should be given to exempting those amounts not known to cause adverse health effects. Similar to the arguments regarding de minimis cut-offs, this suggestion presumes a “bright line” determination of when risks will occur and knowledge of downstream exposures. This approach is not consistent with the intent of the HCS to prevent effects from occurring by providing information prior to putting the employee at risk. OSHA recently published a new final rule on formaldehyde which revised the substance –