MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THROUGH: DANIEL MICK, COUNSEL FOR REGIONAL TRIAL LITIGATION
LEO CAREY, DIRECTOR FIELD PROGRAMS
FROM: THOMAS J. SHEPICH, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Coverage of Wood Dust Under The Hazard
Communication Standard (HCS)
On September 9, 1986, a memo concerning the coverage of wood dust under the
HCS was sent to you. The memo established the agency's position concerning
citations for wood dust. Briefly, the memo stated that citations for wood
dust under the HCS would not be issued because the standard and preamble
could not support such citations.
The preamble to the expanded rule, page 31863, published on August 24 states
that OSHA never intended to exclude wood dust from the standard's coverage
under wood and wood products. In addition, the preamble states, "wood dust
is a recognized health hazard, with exposure limits recommended by the
American Conference of Governmental Industrial Hygienists (ACGIH) to control
employee exposure to the substance." Under the provisions of the HCS, this
means that wood dust is to be considered a hazardous chemical (paragraph
(d)(3)(ii), and therefore subject to the requirements of the rule including
material safety data sheets and training.
The agency believes that the language used in the preamble to the expanded
rule satisfies the need for public notice, and thereby supports the coverage
of wood dust. Effective immediately, wood is covered and appropriate
enforcement actions shall proceed. If you have any questions or need
assistance in this matter contact Roy Gibbs or Steve Simon at (FTS) 523-8036.. |
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