Members: Submit Comments on
OSHA Activity
AIHA® requests members’ assistance
on two important issues impacting
the health and safety of workers:
OSHA’s proposed rule to adopt the
Globally Harmonized Hazard Com-
munication System and the agency’s
advance notice of proposed rule-
making (ANPR) for a combustible
dust standard. For more information
or to submit comments, contact
Aaron Trippler, director of govern-
ment affairs, at atrippler@aiha.org.
GHS
When OSHA published its ANPR on
the Globally Harmonized System of
Classification and Labeling of
Chemicals (GHS) in 2006, the
agency requested input about
whether it should continue to require the ACGIH® Threshold Limit
Values (TLVs®) to be included on
safety data sheets (SDS).
AIHA recognized that hazard
classification under GHS is based on
a review of the available data and
not on lists of hazardous chemicals.
However, AIHA felt that this shift in
hazard determination would take
time and that continuing to require
OSHA Permissible Exposure Limits
(PELs) and TLVs on SDS would enhance worker protection. AIHA encouraged OSHA to include TLVs and
other relevant exposure guidelines
on SDS. AIHA also recommended
that, if OSHA decided not to require
inclusion of TLVs, the agency add a
non-mandatory appendix to the
Hazard Communication Standard
that would include references to
TLVs.
On Sept. 30, 2009, OSHA pub-
lished in the Federal Register a pro-
posed rule to align OSHA’s Hazard
Communication Standard with pro-
visions of GHS. AIHA believes that,
if adopted in its current form, the
proposed rule will delete the TLVs
from the standard. In response,
AIHA plans to present comments at
public hearings on GHS. However,
member involvement is also neces-
sary to provide OSHA with com-
ments that reflect the wishes of the
AIHA membership and the industrial
hygiene profession.
Combustible Dust
On Oct. 21, OSHA published an
ANPR as an initial step in development of a standard to address the
hazards of combustible dust.
Members may provide comments
to AIHA on this ANPR either individually or through a volunteer
group. All comments will be submitted to the AIHA Board of Directors
for approval. Approved comments
will be forwarded to OSHA for consideration. Comments submitted for
consideration by AIHA must be received by Jan. 1, 2010.
Members may also submit individual comments directly to OSHA
through the process outlined in the
ANPR. Links to the ANPR and additional documents are available at
www.aiha.org/news-pubs/govtaffairs/
Pages/ AIHAGovernmentAffairs.aspx.
OSHA’s deadline for comments is
Jan. 10, 2010.
AIHA may also draft comments
for presentation at future public
hearings to be conducted by OSHA.
