One was that training could still be done, based on the labels, black cat and sink co wash your paws retro poster rather than totally exempting the products from coverage (Ex. ). As has been fully described in both the NPRM preamble and this document,
black cat and sink co wash your paws retro poster
a hazardous chemical under the rule, and to OSHA “adopting” the ACGIH TLV for grain dust (see, e.g., Exs. 5-2, 5-16, 5-21, 5-32, 5-43, 5-57, 5-104, and 5-124). black cat and sink co wash your paws retro poster The majority of the comments on this subject submitted in response to the NPRM still objected to coverage of grain dust (see, e.g., Exs. 11-43, 11-53, 11-63, 11-77, , and ). Some indicated that OSHA’s rule on grain handling already adequately covers training of workers (Exs. and ). OSHA’s position on this issue remains the same – grain dust meets the definition of a hazardous chemical under the HCS, and is fully covered by the rule. To the extent that workers are already trained, this merely minimizes the burden of compliance.
However, since any dust or particulate can potentially be a “nuisance,” OSHA decided as a matter of interpretation to limit coverage of this part of the rule to those nuisance particulates that were specifically listed at that time in Appendix D of the TLV booklet. OSHA further determined that if a substance listed in Appendix D was not included in an employer’s hazard communication program, a de minimis notification would be issued as long as the substance did not pose a covered physical or health hazard other than its nuisance characteristics. A de minimis violation is one involving a technical violation of a rule, but which bears no relationship to safety or health. A de minimis violation has no penalties associated with it, and the employer has no duty to abate the condition. There were a few other comments received regarding this issue as well.
18×12, 24×16, 36×24, 48×32