HAZARD COMMUNICATION (HAZCOM) Position
Hazard Communication refers to informing employees about chemical hazards and how to protect themselves from such hazards. The term “chemical hazards” is intended to be used broadly to include physical and chemical hazards, but does not usually refer to biological or radiological hazards.
The Mine Safety & Health Administration (MSHA) is the lead federal agency that regulates mine sites; however, the Occupational Safety & Health Administration (OSHA) regulates ready-mix and asphalt plants, some of which are physically co-located with mining operations. MSHA and OSHA are sister agencies within the U.S. Department of Labor. The two agencies have separate, yet very similar, hazard communication (HazCom) regulations. OSHA promulgated its first HazCom in 1983. MSHA’s HazCom rule became effective in June 2002
NSSGA supports full disclosure of chemical hazard information to miners and the means to protect them from exposure. MSHA’s Hazard Communication regulation (30 CFR 47) was promulgated to enhance the hazard training already required for the aggregates and other mining industries. A similar rule for other sectors of U.S. industry has been in effect for many years, but enforcement of that regulation by OSHA has resulted in an abundance of citations for paperwork violations that have little or no relationship to accomplishing the laudable goals of the regulation. NSSGA encourages MSHA to follow a different enforcement path, and to cite operators only for any violations that, if left uncorrected, put miners at risk of being harmed by chemical overexposures. NSSGA also encourages the agency to provide a wide variety of compliance tools for operators, especially small operators, and has pledged to assist the agency in developing compliance materials.
- NSSGA members are committed to safety training and education to assure prevention of accidents or health concerns resulting from hazardous materials at the workplace.
- NSSGA implores MSHA to use common sense in enforcement of its Hazard Communication rule by citing operators only for alleged deficiencies that could increase the risk of miners’ over exposure to hazardous chemicals.
- NSSGA does not wish to see the agency turn HazCom into an exercise of citations for trivial paperwork violations and will closely monitor the agency to assure this does not happen.
- NSSGA has pledged to assist MSHA with development of high-quality compliance materials, especially useful tools for small operators.
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