![]() ![]() ![]() I am referring to the classification of an article under the OSHA Standard, 1910.1200, (b) (5). However I have been trying to obtain a definitive answer from Occupational Safety and Health office, both in Illinois and Washington DC, thus far with no success. I would like to apologize for this intrusion into your busy schedule. If I can be of further assistance please feel free to contact me again. In these instances the article exemption would not apply. However, there may be, circumstances beyond our ability to anticipate that may result in exposure to employees. In most cases, based on our experience thus for, drill bits will be considered "articles" under the Hazard Communication Standard. Consequently, a blanket exemption for specific products cannot be given by OSHA. The Occupational Safety and Health Administration (OSHA) cannot make an across-the-board determination of a products' exclusion as an "article." The standard's definition by its very wording imposes the need to make case-by-case evaluations. If your hazard determination indicates that downstream employees will not be exposed to any hazardous chemicals contained in your drill bit, then your product would meet the definition of an article. The Hazard Communication Standard requires "chemical manufacturers" to evaluate the chemicals produced in their workplace to determine if they are hazardous. Your letter states that you have been informed that if the drill bit is used properly, with a coolant, no dusts will become airborne and that the steel will not heat up to the 1200-degree temperature necessary to release a toxic gas. " Many items appear to meet the definition in their manufactured form, but, manufacturers must consider their products' end use before the "article" exemption may apply. not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use. ![]() The key to the definition of an "article," and thus exemption, is the requirement that the manufactured item does ". The "article" exemption can pose difficulties for manufacturers in determining whether their products meet the definition. Specifically, you asked if a drill bit meets this definition. This is in response to your letters of August 19 and 26 regarding the "article" definition given under the Hazard Communication Standard. ![]()
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |