OSHA Carcinogen
OSHA Celebrates World Cancer Day?

We all have reminders on our calendars for such things as holidays, birthdays, and appointments. As I looked forward to February for some planning purposes, the date of February 4th popped up as World Cancer Day. Is this a day to celebrate cancer? Does that even make sense when most of us upon hearing that word have some pretty strong negative reactions and emotions? This sent me on a path of fact checking. The purpose of World Cancer Day as established by the Union of International Cancer Control (UICC) is to raise awareness of cancer and to encourage its prevention, detection, and treatment. So, this day is similar to Earth Day or World AIDS Day then.

Since I work in the Regulatory World, I thought this would be an opportune time to talk about cancer in the realm of Hazard Communication. For many cancer is part of the acronym CMR which stands for materials that are carcinogenic, mutagenic or toxic to reproduction. In OSHA HazCom 2012, Appendix A Subsection 6 covers the definition, classification criteria, and cut-off values for carcinogens. Are those pieces of information really enough to classify all of your products? Granted the regulation points out in A.6.2.5.2 some factors to consider, but those exact particular factors can be hard to find in many full length cancer studies.

To make things a bit easier, OSHA has allowed for Continue Reading…

Department of Transportation Logo
Transition Period for Two US Labels Coming to an End

On July 20, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published Final Rule HM-218F, bringing changes to the 49 CFR Hazardous Materials Regulations (HMR). Most of the amendments that were adopted in the final rule were intended to eliminate, revise, clarify or relax regulatory requirements. Two hazard class labels were revised in the final rule and were given a transition period for compliance until October 1, 2014.

Class 6 Label Changes

Class-6-Transition-Period-for-Two-US-Labels-Coming-to-an-End

Removal of CDC information on the class 6 infectious label

Prior to HM-218F, labels for Class 6 Infectious Substances were required by the HMR to include references to the Centers for Disease Control (CDC). The final rule removed the previously required statement “In U.S.A. Notify Director—CDC, Atlanta, GA 1–800–232–0124” from the label text. As of October 1, 2014, the statement must not appear on the Infectious Substances label.

Class 9 Label Changes

Class-9-Transition-Period-for-Two-US-Labels-Coming-to-an-End

Removal of horizontal line on the class 9 miscellaneous label

In 49 CFR, the Class 9 label was different from international regulations by including a thin, horizontal line running across the label at its midpoint. This led to some shipments being delayed or having to be relabeled by international carriers because there was no line required in the international standards such as the International Civil Aviation Organization (ICAO) Technical Instructions and the International Maritime Dangerous Good (IMDG) Code. HM-215F removed the requirement for the line on the Continue Reading…