when exposures are greater or more frequent than typical public use of the chemical would generate.” in this classroom we all belong we are a team back to school poster 52 FR 31863. This appeared to OSHA to be a reasonable accommodation for
in this classroom we all belong we are a team back to school poster
not whether it would be less burdensome to completely exempt the products. A total exemption for consumer products would not adequately protect employees, in this classroom we all belong we are a team back to school poster and since the Agency has determined that these employees are at significant risk of experiencing adverse health effects if the workplace use of consumer products is not covered, then OSHA would not be meeting its statutory mandate. Another suggestion submitted (Exs. 5-84, 5-93), and endorsed by OMB in its paperwork decision (Ex. 4-67), was to use the same consumer product exemption adopted by Congress in the community right-to-know provisions of the Superfund Amendments and Reauthorization Act of 1986, Public Law (Ex. 4-16), which is being implemented by the Environmental Protection Agency.
The exemption would then be for “any substance to the extent that it is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use by the general public.” As OSHA noted in the NPRM, this exemption is not related to the extent of employee exposure to chemicals that are hazardous – which is the concern of OSHA in the HCS – and it is not appropriate for this rule. NIOSH also noted that “consumer products” are defined by EPA and OSHA for different purposes, and should not be summarily grouped together (Ex. ). OSHA further stated that this exemption “strikes a balance between the practical considerations of acquiring and maintaining material safety data sheets on CPSC regulated products which employees are exposed to at home as well as at work, and the worker’s need for more hazard information than a CPSC label