Hazard communication for chemicals in office humidifiers

May 8, 1991

Mr. Walter A. Macht, P.E.
Assistant Vice President
Environmental and Regulatory Affairs
Betz Entec, Inc.
[Recipient address omitted]
Dear Mr. Macht:

Thank you for your letter of March 28, regarding the application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200, to chemicals used in humidification systems in office areas. This letter is also in follow-up to the discussion held between you and Ms. Melody Sands of my staff on this same topic on April 26.

You attached to your letter a copy of an article from the March/April, 1990, issue of a trade journal entitled Engineered Systems which claimed that OSHA's HCS required employers to do such tasks as retain a legal firm, contract with environmental consulting engineers to "make" an environmental impact study of humidification systems which are "chemically dependent," submit a plan for OSHA approval, and several other items. These efforts are not required under the HCS. I am enclosing for your information a recently-revised booklet on the HCS entitled "Chemical Hazard Communication," along with a copy of the standard itself and OSHA's compliance directive for the HCS, CPL 2-2.38C, which will help clarify the misconceptions set forth in the trade journal article and provide information on employer responsibilities under the HCS.

Your specific question concerned whether the HCS applies to office workers who may be exposed to trace amounts of chemicals emitted from steam humidification systems which are part of the overall heating, cooling and ventilation system of the building. As discussed with you on the telephone, the requirements of the HCS would apply to employers of personnel such as maintenance workers, building engineers, or any other employees who would be exposed or potentially exposed by handling or storing the anti-corrosive chemicals or actually adding them to the humidification system. The chemical manufacturer or distributor of the chemicals is responsible for transmitting with the initial shipment a material safety data sheet (MSDS) which provides information on the chemical and safe handling procedures, among other things. The receiving or downstream employer must make the sheets available to all employees working with these chemicals as part of his overall hazard communication program. Such employees who are or may be exposed in their workplace need the protections afforded by the information that must be provided to them in their workplace hazard communication program.

However, employees such as office workers who may be incidentally exposed to the chemicals in trace amounts from the humidification system would not be covered under the provisions of the HCS. These workers' exposures would be the same as the general public or other people in the building. According to the preamble to the final Hazard Communication Standard (Federal Register, Vol. 52, No. 163, August 24, 1987, pg. 31862), "...to the extent that workers are exposed to the substances in a manner similar to that of the general public, there is no need for any HCS requirements."

We hope this discussion and enclosed information will be helpful to you in clarifying the issues you raised. Please feel free to contact us again if we can be of further assistance.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

Enclosures

[The requester's March 28, 1991 letter and enclosed trade-journal excerpt reproduced on the OSHA page are omitted here.]