Therefore, opinions expressed by these non-manufacturers who have no experience guinness beer crocs applying the definition, and have no responsibility to do so, are irrelevant as to whether the definition should be revised.
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The purpose of this standard, therefore, is to provide information on all hazardous chemicals to which employees could be exposed. guinness beer crocs The primary alternative suggested by representatives of the formaldehyde industry commenters is that OSHA exempt de minimis releases so that a manufactured item which releases “small” amounts of a hazardous chemical during normal conditions of use is still considered an article and not covered by the HCS. (See, e.g., Exs. 11-37, , , , , , , , , and ) (six of these commenters are formaldehyde – related organizations; two are construction representatives who do not have to apply the definition; one is a mining industry representative that is not covered by OSHA).
Several commenters indicated that the changes were a step in the right direction, but did not go far enough (Exs. 11-38, , and ). As OSHA noted in the NPRM, the definition of an article and application of that definition to determine whether an item is exempted, is an issue for chemical manufacturers and importers, not non-manufacturers. Non-manufacturers have no responsibility for applying the definition, and can rely on the evaluations performed by their suppliers. One commenter took issue with this statement (Ex. ), and indicated that non-manufacturing is concerned about articles as well. Some of these commenters supported the position that the article definition should be narrowed so as to result in fewer products being covered in non-manufacturing workplaces (see, e.g., Ex. , ). That is a different issue than claiming that the definition itself is unworkable, and OSHA is reiterating that application of the definition to manufactured items is an issue that is solely the concern of manufacturers.