OSHA is now practicing theology with its latest interpretation concerning labeling requirements regarding the revised Hazard Communication standard (HCS 2012), 29 CFR 1910.1200.

How many angels can dance on the head of a pin? How much information must you get on your GHS compliant label?
How many angels can dance on the head of a pin? How much information must you get on your GHS compliant label?

5 milliliter vials, 50 milliliter bottles- Doesn’t make a difference to the theologians at OSHA- You MUST GET ALL THE REQUIRED INFORMATION ON THE LABEL ATTACHED TO THE VIAL!
This is a 5 ml bottle. Its label must contain...
This is a 5 ml bottle. Its label must contain…

In a letter of interpretation to the NIST– A division of the United States Department of Commerce- the High Priests at OSHA have made GHS labelling a matter of faith.
You can do it. You must do it. SOMEHOW.
Here’s what needs to be legible on the label on the 5 milliliter vial:
“Paragraph 1910.1200(f)(1) requires the chemical manufacturer, importer, or distributor to ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information: (1) a product identifier; (2) signal word; (3) hazard statement(s); (4) pictogram(s); (5) precautionary statement(s); and (6) the name, address, and telephone number of the responsible party.”
Here’s OSHA’s Offical Lable Layout. On my screen it measures 150% taller than the vial, and it is basically illegible, and the manufacturer name and address fields have been abridged to two words :
No mention of recognizing the hazards of placing a big long fold out label on a tiny vial of a hazardous substance. No consideration for the fact that perhaps a paper label might in fact react with the contents of the small contqiner in case of contact.
Nope, For the theologians at OSHA it is just DO AS WE SAY TO because that is how it is printed in the SCRIPTURE of  Paragraph 1910.1200(f)(1).
It’s a matter of faith. Not critical thinking.
Blind, authoritarian faith.

The new HAZCOMM 2012 ‘Right to Understand’ will impact 5 million businesses at an OSHA estimated cost of only $201 million dollars.

Thats just $40 per workplace to cover:

  • Cost of classifying Chemical hazards to meet the new GHS criteria;
  • Cost to revise Safety Data sheets and labels to meet the new format and content requirements;
  • Cost to train 43 million employeeson the new format and content of material symbols and data sheets;
  • Cost to management of those 5 million workplaces to become familiar with the new GHS requirements, assess, revise, develop and implement new compliance materials needed to adopt GHS;
  • Cost for printing new packaging and labels in color;

OSHA thinks that we can do it for $201 million a year- that’s just $40 per workplace!

OSHA says this is all it will cost your shop to adopt this new standard, become familiar with its requirements, reclassify all your chemicals, train your people, change all labels and data sheets. WHAT were they thinking?

Using Department of Labor enforced Federal Minimum Wages, $7.25 an hour, that means that they think that it will only take 5,5 hours to get a shop into compliance.

(Please, correct my math if I’m wrong!)

5-1/2 hours!

The PDF of the final rule is 858 pages!

Just to read that in 5.5 hours would mean reading 156 pages per hour.

At a nickel a page, just printing the final rule puts us over at $42.90.

Who the heck does these estimates? What were they thinking?

We really understand that regulations can provide a benefit to workers, companies and communities.

Especially where hazardous chemicals are involved.

But when the regulators underestimate the potential costs of adoption and compliance by such a large factor, it makes us wonder what other assumptions are they working under that are just as wrong?

P.S.  Do you think that OSHA or OIRA actually have  employee’s that can read 156 pages of federal technical regulation in an hour? At $7.25 an hour?