This would be useful chemical hazard information for employees mickey mouse painting crocs involved in administering the products even though employee protection is not the primary purpose of the information presented.
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It is clear from the comments of worker representatives and others that the proposed alternative does not provide adequate information, and is not as effective as having MSDSs. mickey mouse painting crocs On the other hand, a number of commenters indicated that package inserts and PDR entries are not acceptable alternatives to MSDSs (Exs. 11-7, 11-21, 11-69, , , and ). Concerns expressed by these commenters included the fact that the information on the package inserts and PDR entries is not clear or easily understood, and the information is not comparable to that included on MSDSs. Additionally, some of these commenters suggested that other items regulated by FDA should also be allowed to be accompanied by package inserts instead of MSDSs (Exs. 11-48, 11-96, and ). The Agency invited comment on this issue, particularly from employees who would be affected
by the modification to ensure that they agree that this information is adequate for their protection. The existing exemption for labeling would remain in effect, employers would still have to have hazard communication programs where covered, and training would have to be given to those employees who have not previously been trained regarding the hazards and protective measures. OSHA proposed to modify the definition of “material safety data sheet” under the rule to indicate that a package insert approved by FDA, or an entry in the PDR prepared in accordance with FDA’s requirements, be considered in compliance with the HCS requirements for a MSDS for these products. In addition, the exemption regarding solid drugs was corrected to read “e.g., tablets or pills” rather than “i.e.” as is currently indicated in the revised final rule (see, e.g., Exs. 5-77, 5-85, and 5-102).]
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