data available elsewhere on MSDSs and in training. speak of the devil ozzy osbourne crocs Additionally, MSDSs cannot be substituted for labels – they serve different purposes and contain information presented in a different fashion.
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If this is the case, they are already in compliance with the rule so there should be no problem with this provision. The exemption was also supported (Ex. 11-67). speak of the devil ozzy osbourne crocs It is possible for someone following the guidance in the ANSI standard to construct a label that is complete enough to satisfy the requirements of the HCS. OSHA’s concern is that information may be eliminated from some labels based on the “exposure assessment” factor, and employers will not be in compliance with the HCS. The inability of the producer or importer to accurately predict downstream exposures, and thus the need for complete disclosure of hazards, was discussed in the original final rule , and is still applicable. The ANSI standard, on the other hand, specifically states that the labeling
recommendations are not based only on the inherent properties of the chemical, but are directed to the avoidance of hazardous exposures resulting from customary and reasonably foreseeable occupational use, misuse, handling and storage. The health hazard evaluation also refers to an exposure assessment being performed. An objection was raised about the public’s opportunity to comment on the final ANSI standard before addressing it in the HCS (Ex. ). The ANSI standard was finalized prior to the publication of the HCS NPRM, and was available in the docket as Ex. 4-110. As OSHA specifically solicited comments on this issue in the NPRM, the public was given an opportunity to provide input. One commenter (Ex. 11-86) thought in-plant labels should only have the name of the chemical, not the hazards. OSHA does not agree with this – the label must provide hazard information to be an effective reminder of the more detailed