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At a March 3 Informal Public Hearing in Washington, DC, ORC Senior Vice President Frank White and EHS Networks Director Ann Brockhaus voiced support for OSHA’s proposal to align its Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
“ORC wants to express its appreciation to OSHA for making this rulemaking a top priority,” said Mr. White in introductory comments before the reading of ORC’s testimony. “This is an important step in making OSHA a global leader in safety and health.”
Ms. Brockhaus then read ORC’s prepared statement before a panel of OSHA experts and a number of interested stakeholders. She pointed out that over 130 of the world’s leading companies in diverse industries are members of ORC’s occupational safety and health groups. Virtually all ORC member companies have significant global operations and therefore have a substantial interest in the consistent application of the GHS worldwide. While many of these companies provided a great deal of advice to ORC in the development of its comments, the comments are solely those of ORC and may differ from the views of individual member companies.
“Our increasing global interconnectedness and differing country approaches have now led to significant business support for the decade-long process to develop a globally harmonized system of classification and labeling of chemicals,” said Ms. Brockhaus. ORC’s statement emphasized four additional points with respect to the proposed rule:
- ORC agrees with OSHA’s approach limiting changes to the HCS, with few exceptions, to those required for consistency with GHS;
- Training and other compliance assistance resources will be essential to controlling implementation costs and ensuring compliance;
- ORC supports concurrent harmonization of hazard definitions in most OSHA standards;
o ORC agrees with member concerns that changes to definitions in 1910.106, Flammable and Combustible Liquids, while not increasing the scope of the standard, may cause confusion to workers who are familiar with National Fire Protection Association nomenclature for these materials.
- ORC agrees with OSHA’s proposal to add a definition for Unclassified Hazards to HCS;
o Combustible dust hazards, in particular, have caused serious loss of life and significant economic consequences and have not been adequately addressed under the current HCS.
During the question and answer period, an OSHA official followed up on the concern of ORC members that the changes to definitions in 1910.106 might be confusing. The official asked if training could overcome this confusion. “Yes,” replied Ms. Brockhaus, adding that this was not a reason to delay moving forward with the proposal.
Another OSHA official asked about a comment made in ORC’s previously submitted written comments that supported updating new and significant information about chemical hazards within three months. Ms. Brockhaus responded that nearly all ORC members who participated in preparing the written comments agreed that the three month provision is appropriate, given the kinds of software programs currently available.
An OSHA official asked if the agency had been successful in aligning its HCS with the GHS. “Yes,” replied Ann Brockhaus, “and our member companies agree that you did a good job – HCS now lines up nicely with the GHS.”
To read ORC’s testimony at the Informal Public Hearing go to: (see attachment).
| Attachment | Size |
|---|---|
| ORC Testimony OSHA GHS Hearing March 3 2010 FINAL.doc | 197 KB |
