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The rule also took a performance – oriented approach to the presentation of information, jack skellington and sally we are simply meant to be retro poster allowing various formats to be used as long as the information required by the HCS was included.

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regarding these would be required on a label to comply and be considered appropriate. OSHA provided clarification regarding the Agency’s interpretations of these requirements in the preamble to the revised final rule. jack skellington and sally we are simply meant to be retro posterIn the NPRM, the Agency proposed to incorporate these clarifications into the text of the rule. Thus the new definition proposed was that “hazard warning” means “any words, pictures, symbols, or combination thereof appearing on a label or other appropriate forms of warning which convey the specific physical and health hazard, including target organ effects, of the chemical in the container. (See the definitions for “physical hazard” and “health hazard” to determine the hazards which must be conveyed.) This modification is being adopted in this final rule.

The Agency’s interpretation of the rule in requiring health effects information, including information on target organ effects, was challenged and upheld in Martin v. American Cyanamid, on No. (6th Circuit September 15, 1993.) In the development of the 1983 final rule, the Agency sought to require on labels that information that it considered to be necessary to employee protection, and which did not appear on many of the labels in use in industry at that time. It appeared to OSHA, based on the information available at that time, that labels frequently included precautionary information but infrequently enumerated the actual hazards of the chemical. In addition, the labels often lacked identity information. Thus OSHA chose to require that this limited information – the identity and hazards – be included on the label, while not precluding the addition of other types of information thought to be appropriate by the chemical industry.