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Miller Engineering
Associates, Inc.
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888-206-4394 (toll free) or 734-662-6822
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(Company Info available by e-mail or overnighted hard copy)
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CHEMICALS page
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- Miller, J.M. (2007). "Hazard Communication Compliance", in Safety Engineering Handbook, American Society of Safety Engineers.
- Lehto, M.R., House, T.E. and Papastavrou, J.D. (2000). "Interpretation of Fuzzy Qualifiers by Chemical Workers," International Journal of Cognitive Ergonomics, Vol. 4, No. 1, pp. 73-88.
- Lehto, M.R. (1998).“The Influence of Chemical Warning Label Content and Format on Information Retrieval Speed and Accuracy,”Journal of Safety Research, Vol. 29, No. 1, pp.1-14.
- Lehto, M.R. and House, T.E. (1997). "Evaluation of the Comprehension of Hazard Communication Phrases by Chemical Workers," International Ergonomics Association 13th Triennial Congress, Tampere, Finland.
- Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1975). Psychomotor and Neuromuscular Changes in Workers Exposed to Inorganic Mercury. Journal of the American Industrial Hygiene Association, October.
- Miller, J.M. and Chaffin, D. (1973). Behavioral and Neurological Evaluation of Workers Exposed to Inorganic Mercury. (NIOSH Contract #5T01-0N00161-02).
- Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1973). An Evaluation of the Effects of Chronic Mercury Exposures on EMG and Psychomotor Functions (Final Report, NIOSH Contract #5T01-0N00161-02).
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The premiere standard for communicating hazards associated with chemicals found in
the workplace is the Occupational Health and Safety Administration (OSHA) Hazard
Communication Standard (HazCom) found in 29 CFR 1910.1200, which includes the
following sections:
(a) purpose;
(b) scope and application;
(c) definitions;
(d) hazard determination;
(e) written hazard communication program;
(f) labels and other forms of warning;
(g) material safety data sheets;
(h) employee information.
Prior to the HazCom’s promulgation in the mid-1980’s, there was no national requirement
that employees be provided information about the hazards associated with the chemicals
they were handling, or instructions for remedial action to avoid or minimize the risk
associated with those hazards.
Often Miller Engineering is hired to evaluate literature associated with hazardous chemicals.
As a result, we have created analysis processes, which have been peer reviewed & published,
for evaluating chemical product labels to section (f) above and for evaluating material safety
data sheets(MSDS) to section (g) above. Our chemical staff has evaluated hundreds of labels & MSDS using these procedures. Often times cases of this nature involve long histories of
employee exposure, therefore we typically track the scientific, medical, & corporate knowledge of the specific hazards of a given substance and compre this information with
government regulatory requirements for labeling & MSDS. |
The American National Standards Institute has published the following standards, which
are the primary consensus standards related to chemical hazard communication in the U.S.:
- American National Standard for Hazardous Industrial Chemicals - Precautionary Labeling
(ANSI Z129.1)
- American National Standard for Hazardous Industrial Chemicals - Material Safety Data
Sheets - Preparation (ANSI Z400.1)
ANSI Z129.1 provides recommendations for chemical label format, color, size, symbols,& wording. These aspects of a label are important in creating an effective warning that
workers will heed.
ANSI Z400.1 provides guidelines for preparation of MSDS in a method that more closely
resembles the Globally Harmonized System for Classification and Labeling of Chemicals
(GHS; see reverse) than the current OSHA HazCom standard does.
Similar to the our evaluations to OSHA standards, Miller Engineering has established processes for comparing chemical product label and MSDS language with the ANSI guidelines.
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The United Nations adopted the Globally Harmonized System for Classification & Labeling of Chemicals (GHS) in 2003. The purpose of the GHS was to
provide hazardous chemical classification systems definitions and outline
components to be included on hazardous chemical product labels providing
the opportunity for consistency between countries and even within a given
country.
A good example of inconsistency within a given country is the definition
of a flammable liquid. The following agencies differ in their classification
of flammable liquids: OSHA, National Fire Protection Association (NFPA),
the Department of Transportation (DOT), the Consumer Product Safety
Commission (CPSC), and ANSI in Z129.1. These flammable liquid definitions
differ from those in other countries as well, such as Canada’s WHMIS and
the EU’s definition. Harmonizing these definitions will provide interagency & intercountry consistency to the definition of flammable liquids by those
entities that choose to adopt the GHS guidelines.
Countries and agencies are not required to adopt the GHS guidelines. It is
up to each country, and each agency within that country, to determine if
and when it will implement the GHS guidelines.
In the United States, OSHA is now working to incorporate the GHS guidelines
into the HazCom. While it may take up to 10 years to implement, Miller
Engineering will stay current on the progress and incorporate the changes
into our analyses, evaluating literature to the regulations contemporary
to the time period of exposure. |
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Depending on the type of packaging, method of exposure, and chemical
properties of a hazardous chemical, additional product labeling may be
required other than that specified by OSHA.
Agencies such as the Department of Transportation, the Environmental
Protection Agency, and the Consumer Product Safety Commission all regulate
aspects of product labeling.
Further there are consensus organizations such as the National Fire
Protection Agency (NFPA) and the National Paint & Coatings Association
(NPCA) provide guidelines for information to include on product labels. |
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| Miller Engineering Associates, Inc., 2392 Fuller Ct., Ann Arbor,
MI 48105. |