Standard Interpretations - Table of Contents|
| Standard Number:||1910.1200(d); 1910.1200(f)(2)|
1. What tests or exposure scenarios are required to establish a standard of proof for the article exemption?The HCS does not require testing to determine the presence of a hazardous chemical. The rule covers chemicals which are "known to be present." The release of a very small quantity (that is, a few molecules or trace amounts) of a hazardous chemical is not covered by the rule. For instance, one may assume that an item, such as newly varnished furniture, emits chemicals. This, however, would not be covered under the HCS.
2. When testing "as a whole" for hazard determination, what are the full range of tests required to establish the presence or absence of a hazard?There is no pre-set list of testing requirements. Manufacturers may test a mixture "as a whole" or may rely on tests which have been scientifically conducted. The purpose of the hazard determination is to provide known information for the elements listed under paragraph (g) of the standard. It is the manufacturer's prerogative to "test as a whole" for any or none of these elements.
3. Grinding wheels, superabrasive products, and sandpaper do not create an exposure during shipment. Are these items subject to labeling provisions under paragraph (f)(1) or paragraph (f)(2) of the standard?We hope that this information is helpful. Please feel free to contact OSHA's Office of Health Compliance Assistance at (202) 693-2190 if further guidance is needed.
Labeling requirements for items which are solid materials, but do not classify as articles, are described in paragraph (f)(2) of the standard.
|Standard Interpretations - Table of Contents|