ASSE Urges Inclusion of Control Banding in GHS-Aligned HCS

DES PLAINES, IL -- Control banding should be included in OSHA’s realigned Hazard Communications Standard and it should be finalized soon, the American Society of Safety Engineers testified at a public hearing Friday.

ASSE professional member and chair of the ASSE Global Hazard Communications (GHS) Task Force Donald Garman, CSP, testified at OSHA’s public hearing on a proposed rule to align its HCS with the United Nation’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Garman said ASSE supports the goals of the proposed rule.

“ASSE applauds OSHA for its leadership in undertaking this effort. We agree with much of what has been proposed and urge that a final rule be promulgated as soon as possible. Our members, many already working to harmonize their employers’ efforts to comply with OSHA and international hazard communication requirements, tell us their employers will, in the long term, benefit from the greater competitiveness in a global marketplace that harmonized hazard communications will bring. It will also provide uniformity and increased worker safety and health.”

Garman said one area of concern was the issue of control banding (CB) and urged that it be included in the standard.

According to the National Institute of Occupational Safety and Health (NIOSH), CB is a technique used to guide the assessment and management of workplace risks. It is a generic technique that determines a control measure (for example dilution ventilation, engineering controls, containment, etc.) based on a range or “band” of hazards (such as skin/eye irritant, very toxic, carcinogenic, etc) and exposures (small, medium, large exposure).

It is an approach that is based on two pillars; the fact that there are a limited number of control approaches, and that many problems have been met and solved before. CB uses the solutions that experts have developed previously to control occupational chemical exposures, and suggesting them to other tasks with similar exposure situations. It is an approach that focuses resources on exposure controls and describes how strictly a risk needs to be managed. NIOSH notes that it considers CB a potentially useful tool for small businesses. 

“The HazCom Standard now is largely a paper exercise that causes employers to focus on written programs, labels, and training,” Garman testified. “It requires employers to provide a system, but one that results in employees looking only at the MSDS of single materials without any understanding of the larger system. So, the employee makes decisions with little guidance on how to consider classifying hazards, scale of use, ability of materials to become airborne, or controls like PPE and mechanical ventilation.”  

Garman noted that ASSE members are already using CB to help employers develop hazard communications, especially employers who are operating internationally.  He said ASSE is concerned that OSHA could face a need to revise the standard to incorporate control banding late in the process if they don’t do it now. 

Garman also discussed other issues involving the ruling in his testimony and noted that ASSE and its members were available at all times to assist in the next steps of revising the standard.

“On behalf of my fellow ASSE members, thank you for your diligent work on the advancement in this nation’s commitment to occupational safety and health that this rulemaking represents,” Garman said.