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Document for Public Review and Comment:

Current Intelligence Bulletin (CIB): A Strategy for Assigning the New NIOSH Skin Notations for Chemicals
NIOSH Docket 109

September 2008

Introduction and Purpose

The National Institute for Occupational Safety and Health (NIOSH) of the Centers for Disease Control and Prevention (CDC) is conducting a public review of the NIOSH document “CIB: A Strategy for Assigning the New NIOSH Skin Notations for Chemicals.”  This draft CIB was developed to provide the scientific rationale and framework for a strategy for the assignment of multiple skin notations capable of distinguishing between systemic, localized, and sensitizing health effects of dermal chemical exposures.  The strategy has been designed to 1) communicate the current state of knowledge on hazards to workers’ health from dermal exposures, 2) address the conceptual shortcomings of the current NIOSH skin notation represented by the symbol [skin], 3) recognize the health risks associated with contact of the skin with chemicals beyond dermal absorption, and 4) increase the transparency of the process for assigning the new NIOSH skin notations.. The overall goal of the review is to enhance the quality and credibility of Agency recommendations by ensuring that the scientific and technical work underlying these recommendations receives appropriate review by independent scientific and technical experts.

Charge to Peer Reviewers

The peer review charge was developed in accordance with Office of Management and Budget (OMB) guidelines, is consistent with NIOSH peer review practice, and is meant to ensure that credible and appropriate science is used in the development of the strategy for the assignment of the new NIOSH skin notations.
To facilitate review of this document, the peer reviewers have been asked to take the following questions into consideration:

  1. Are the proposed classes of skin notations appropriate?
  2. Are the proposed criteria for assigning each type of skin notation appropriate?
  3. Is the proposed assignment of multiple skin notations useful for protecting workers from dermal hazards?
  4. Should the SEN notation apply strictly to allergic contact dermatitis or is it appropriate to assign the SEN notation for other immune-mediate responses, such as respiratory sensitization, airway hyperactivity and mucosal inflammation, associated with dermal exposure to a compound?
  5. Does the proposed harmonization scheme found in Appendix G.2 link the new NIOSH skin notations and the GHS assignments sufficiently?
  6. Should additional information be included within document? If so, what?
  7. Do the data cited support the objectives of the document?
  8. Are the conclusions appropriate in light of the current understanding of the toxicological data?

Public Meeting

A public meeting will be held on Thursday, November 6, 2008 from 9:00 a.m. to 4:00 p.m. at the Robert A. Taft Laboratory in Cincinnati, Ohio, as a forum for scientists and representatives of government agencies, industry, labor, and other stakeholders to discuss the document. The meeting will be open to the public, limited only by space available. Due to limited space and security clearance requirements, notification of intent to attend the meeting must be made to the NIOSH Docket Office no later than October 22, 2008. Persons wanting to provide oral comments at the meeting are requested to notify the NIOSH Docket Office no later than October 22, 2008 at 513-533-8611 or by email at nioshdocket@cdc.gov. Priority for attendance will be given to those providing oral comments. Other requests to attend the meeting will then be accommodated on a first-come basis. Unreserved walk-in attendees will not be admitted due to security clearance requirements.

Non-U.S. Citizens: Because of CDC Security Regulations, any non-U.S. citizen wishing to attend this meeting must notify  the NIOSH Docket Officer no later than October 15, 2008.

Current Intelligence Bulletin (CIB): A Strategy for Assigning the New NIOSH Skin Notations for Chemicals September 9,, 2008

DRAFT-CIB-Skin-Notation-Strategy.pdf
(416kb; 115 pages)
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Time Frame for Review

Written comments on the document will be accepted from October 1, 2008 through November 7, 2008.   Written comments can be submitted at the Public Meeting or sent to the NIOSH Docket Office, Robert A. Taft Laboratories, 4676 Columbia Parkway, MS C-34, Cincinnati, Ohio 45226 by the close of business on November 7, 2008. All material submitted to the Agency should reference docket number NIOSH-109. All electronic comments should be formatted as Microsoft Word and make reference to docket number NIOSH-109.

Comments will be accepted until 5:00 p.m. ET on Novemebr 7, 2008

To submit comments regarding this draft publication, please use one of these options:

  • Send NIOSH comments using this online form

  • Send comments by email.

  • Fax comments to the NIOSH Docket Office: 513-533-8285

  • Send by Mail to:
    NIOSH Mailstop: C-34
    Robert A. Taft Lab.
    4676 Columbia Parkway
    Cincinnati, Ohio 45226

NIOSH Draft Documents for Public Review


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