NIOSH Comments to DOL on the Mine Safety and Health Administration Advance Notice of Proposed Rulemaking on Hazard Communication by R. A. Lemen, July 30, 1988

摘要

The testimony concerns the proposed hazard communication standard of the Mine Safety and Health Administration (MSHA) and the views of NIOSH toward such a standard. NIOSH suggests that the ruling extend to all underground mining operations and incorporate all current enforceable MSHA regulations that are more stringent than the requirements in the OSHA proposed rules, including regulations concerning protective footwear, eye protection, personal protective clothing, material storage, warning signs, labeling of toxic materials, consumption of food or beverages in toxic materials areas, annual refresher training, and warning labels. Further areas of interest addressed in the testimony include duplication in standards, labeling and material safety data sheets, independent contractor regulation, the special needs of small mine operators, MSHA assistance in hazard determinations, evaluation of materials produced in a mine or imported, the likelihood of exposure, the written hazard communication program, labeling and other forms of warning, trade secrets, and economic impacts.