Hazard communication for vehicle maintenance chemicals

May 29, 1997

Mr. Chris Moore, President
Association of Civilian Technicians
Lone Star Chapter 100
[Recipient address omitted]
Dear Mr. Moore:

This letter is in response to your recent telephone inquiry concerning a MEMORANDUM FOR SEE DISTRIBUTION dated 20 December, 1996, that was sent to us for comment. Col. Barkley's statement about the Occupational Safety and Health Administration (OSHA) definition of a hazardous chemical is incorrect. In 29 CFR 1910.1200, OSHA simply states a hazardous chemical is any chemical which is a physical hazard or a health hazard. Antifreeze, oil and diesel are at the minimum irritants and, as such, would all fall under the category of "hazardous chemical." The material safety data sheets (MSDSs) for these chemicals should provide you with the health hazards information and the precautions to take if exposed to the chemical.

Cotton uniforms should not be regarded as personal protective equipment (PPE) in this case. If chemical splashes are expected, then impermeable clothing should be worn. Uniforms in the vehicle maintenance setting are provided to employees to prevent their own clothes from becoming torn or dirty. If there is a potential for asbestos exposure, then the employer is responsible for providing and washing of the personal protective clothing or providing disposable coveralls.

Col. Barkley's memo essentially follows 29 CFR 1910.132 in its approach to determine if additional personal protective equipment is needed and if uniforms are being improperly regarded as PPE. Supervisors must assess the workplace for hazards, select and provide the proper protective equipment, communicate selection decisions to the employees, ensure employees follow correct procedures, and ensure employees wear the proper equipment.

We hope this answers your questions. If you need further assistance, please feel free to contact Craig Moulton of the Office of Health Compliance Assistance at (202) 219-7380.

Sincerely,

Stephen Mallinger, Acting Director
Office of Health Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]