Unfortunately, some of the comments indicate that the employers proud to have served marine veteran crocs do not want more information about the chemicals they use. For example, the Coalition submitted an analysis
proud to have served marine veteran crocs
When asked during the hearing to provide a bibliography of these studies (Tr. 3-182), the American Dental Trade Association suggested that OSHA consult the proud to have served marine veteran crocs ANSI labeling standard for such a bibliography. OSHA believes that the fact that MSDSs need to be improved is not an indication that they should be discarded in favor of the limited information on labels. The appropriate response to the problem is to improve the MSDSs, not to remove protections from employees by limiting the information that is available to them. Furthermore, labels simply cannot provide all of the information that is required to be disclosed. The label format is limited by size, and the effectiveness of a label in serving its primary purpose – to provide an immediate visual warning – will be impeded by information overload if all possible
information is required to be included on a label. Participants arguing that MSDSs have information overload have missed the key difference in the roles of labels and MSDSs. Labels are subject to the overload argument because they are intended to provide an immediate warning – a purpose that research has shown cannot be met if there is too much information on the label. On the other hand, MSDSs are reference documents, not an immediate warning mechanism. Proper implementation of the HCS results in both employers and employees being educated about the hazards of chemicals in their workplaces. Statements such as these trivialize the importance of the information conveyed. For example, many paints contain solvents that are neurotoxins. Application can generate vapors that can impair a worker’s ability to function and may lead to accidents such as falling off ladders.