Abstract
The Occupational Safety and Health Administration's (OSHA) ability to issue specific exposure regulations on the large number of chemicals in commerce is limited by resources and the cumbersome process that must be followed to issue these regulations. Further, OSHA is strained to make its presence felt in the large number of facilities where chemicals are used. The Agency and industry both would be better served if there were a more flexible method of establishing exposure limitations, and having these apply to downstream users. We propose that OSHA's current regulatory efforts be supplemented with new approaches based on the greater use of generic “how-to,” performance-type, industrial hygiene guidelines in conjunction with the use of an “operational” material safety data sheet (MSDS). The “operational” MSDS would provide the substance-specific information needed to use the generic “how-to” standards effectively in the characterization, communication, and management of the risks arising from each material's hazards. Requiring that all precautionary statements on an MSDS be “operational” would also decrease the use of overwarning by firms as a low cost tactic for avoiding liability. An additional component of this proposal is the use of third-party compliance personnel, who would periodically make site visitations to assist and certify that good hygiene practices were being followed. This would include verification that downstream chemical users had in place procedures to follow supplier exposure limit information.