Reader response to hazcom story in December EPM

By Stephen Wieroniey | December 05, 2014

Letter to the Editor: 

I recently read “Clear Sign of Confusion,” a feature in the December issue of Ethanol Producer Magazine regarding perceived conflicts between the revised Hazard Communication Standard and the Hazardous Materials Identification System. 

Although it is true that the HMIS Hazard Rating is different from the GHS Hazard Classification category, American Coatings Association and OSHA do not believe there is a conflict. The Globally Harmonized System hazard classification category is not meant to provide hazard communication information to the user. However, the HMIS Hazard Rating is meaningful for each type of hazard, and gives the employee information on the severity of the hazard associated with the use of the substance. The GHS hazard classification category is not required on the label, so the employee who uses HMIS will not see this perceived conflict. The use of HMIS requires training on the meaning of the HMIS Hazard Rating and the required employee responses, which will mitigate any perceived confusion. ACA has developed a new HMIS Implementation Manual (fourth edition) to guide employers in continued effective use of this important compliance tool, which will be available at the ACA website by the end of the year.

Sincerely, 
Stephen Wieroniey
American Coatings Association