This week, NPGA testified at an Occupational Safety and Health (OSHA) public hearing that was held to accept comments on the agency’s existing proposal to update its Hazard Communication Standard (HCS). OSHA is proposing updates to the HCS to align the standard with the U.N.’s Globally Harmonized System (GHS) of Classification of Chemicals. The agency’s primary goal for these changes is to align itself with the GHS system in order to foster international consistency and facilitate international commerce.
NPGA stated that while the goal of this effort is international harmonization, the U.S. propane industry is primarily a domestic industry and that NPGA’s members would not reap the benefits of these changes that other industries operating in international commerce would. We urged the agency to bear in mind the impacts on domestic industries that the proposed changes to the HCS would have.
NPGA, as well as numerous other hearing witnesses, also opposed the inclusion of a Released for Shipment date on hazard labels, which would be required every time a cylinder or propane container was filled. The inclusion of this date on the label could create confusion with other dates on the cylinder, e.g., requalification date, create inefficiencies in the labeling process and result in unnecessary cost burdens with no increased benefit in safety.
NPGA did support OSHA’s efforts to codify the elements of a recently published Memorandum of Understanding (MOU) between OSHA and DOT. The intent of the MOU was to clarify each agency’s jurisdiction on matters of labeling containers that are used in the transportation of hazardous materials.
In light of questions and comments received from the agency during the hearing, NPGA will be submitting post-hearing comments, which will be accepted through the end of October.