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Cottonseed Statistics
| Newsletter |
Mexico
Consultant's Reports
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Dear Sir or Madam:
The "Hazard Communication" (29 C.F.R. l9l0.l200) standard requires chemical manufacturers and importers to assess the hazards of chemicals which they produce or import, and the manufacturing sector to provide information to their employees concerning hazardous chemicals by hazard communications programs including; container labels, material safety data sheets, training, and access to written records. The compliance date for all provisions of the standard, including initial training for all current employees, was May 25, l986.
The criteria for determining whether a substance is a "Hazardous Chemical" is divided into two categories i.e.; physical hazards criteria and health hazards criteria.
OSHA defines a "Physical Hazard" as a "chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophonic, unstable (reactive) or water-reactive." Cottonseed linters do not meet the criteria set forth for the determination of a physical hazard.
The "Hazard Communication" regulation defines a flammable material as follows "(iv) "Solid, flammable" means a solid other than a blasting agent or explosive as defined in l9l0.l09(a), that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard. A chemical shall be considered to be a flammable solid if, when tested by the method described in l6 CFR l500.44, it ignites and burns with a self-sustained flame at a rate greater than one-tenth of an inch per second along its major axis." We are not aware of any studies which indicate that cottonseed linters meet the above criteria.
The standard defines a "Health Hazard" as a "chemical for which there is statistically significant evidence based on at least one study conducted through the use of established scientific principles that acute or chronic health effects may occur in exposed employees". The term "Health Hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. Appendix A of the standard provides complete definitions and explanations of the scope of health hazards. We are not aware of any statistically significant evidence that would indicate that cottonseed linters meet any of the criteria for a health hazard.
Upon consulting with the OSHA regional office in Atlanta, a NCPA staff member learned that OSHA does not expect manufacturers to conduct lengthy tests on their products and such tests are not a requirement of the regulation. Appendix B of 29 CFR l9l0.l200 states that; "Hazard evaluation is a process which relies heavily on the professional judgement of the evaluator..." It would be impractical, if not impossible, for us to review all the literature looking for a health effect that may be related to exposure to cottonseed linters. In our search of the published literature, we have found nothing that indicates that workers exposed to cottonseed linters are at risk.
It is our opinion that cottonseed linters do not meet any of the criteria set forth to define a "Hazardous Chemical." A comprehensive hazard communication program including container labeling and other forms of warning, material safety data sheets and employee training are not required for cottonseed linters.
Sincerely,
Ben Morgan
Executive Vice President
© 2002 National Cottonseed Products Association. All rights reserved.