OSHA requirements for arsenic-treated wood

The OSHA interpretation letter from May 3, 2023, addresses concerns regarding arsenic-treated wood. The letter clarifies that the Inorganic Arsenic Standard (29 CFR § 1910.1018) does not cover arsenic-treated wood, which is a preservative used in certain types of lumber. However, OSHA acknowledges that this wood is still subject to the Hazard Communication Standard (HCS, 29 CFR § 1910.1200). Under the HCS, employers of workers exposed to wood dust, including arsenic-treated wood, must provide appropriate hazard communication, including training, labels, and Safety Data Sheets (SDS).

This interpretation also highlights that while residential use of arsenic-treated wood largely ended in 2004, there are still potential exposures in construction and renovation work involving existing structures. OSHA reinforces that employers must ensure that workers are informed of the hazards associated with arsenic-treated wood, and that measures for worker protection, such as personal protective equipment (PPE) and training, must be in place.

Additionally, the letter contrasts this approach with that for hexavalent chromium-treated wood, which is covered under OSHA's Hexavalent Chromium Standard. In contrast, no such coverage applies to arsenic-treated wood beyond the HCS. See more here.

OSHA HCS applicability to markers

The OSHA Standard Interpretation dated November 21, 2023 addresses the applicability of the Hazard Communication Standard (HCS) 29 CFR 1910.1200 to industrial markers containing liquid paint or ink. The key point is that these markers, when containing hazardous chemicals, fall under the scope of HCS.

• Labeling: Manufacturers and importers must label these products in compliance with the HCS, ensuring proper hazard communication. This includes providing appropriate hazard warnings and symbols on the product's label.

• Safety Data Sheets (SDS): An SDS must also be supplied for the industrial markers containing hazardous chemicals. These data sheets should cover all relevant safety and health information about the product's chemicals, per HCS standards.

• End-User Obligations: Employers using these products must also comply with HCS by maintaining an up-to-date SDS and ensuring that workers are trained on the hazards and proper handling of these products.

The interpretation reinforces that even for everyday products like markers, if hazardous chemicals are present, strict HCS rules apply​. See more here.

OSHA interpretation for formaldehyde

The OSHA interpretation from January 11, 2024, addresses the requirements for emergency eyewash facilities when handling formaldehyde solutions with concentrations at or above 0.1%. According to the Hazard Communication Standard (HCS), 29 CFR 1910.1200, and the Formaldehyde Standard, 29 CFR 1910.1048, employees exposed to formaldehyde in these concentrations must have access to emergency eyewash stations.

The key aspect of this requirement is ensuring that an eyewash facility is available within a 10-second reach from the location where formaldehyde exposure occurs. This aligns with the ANSI Z358.1-2014 standard for emergency eyewash equipment, ensuring proper first aid for workers exposed to harmful substances like formaldehyde.

OSHA emphasizes that this requirement is critical to minimizing the health risks associated with formaldehyde exposure, which can cause eye irritation, respiratory issues, and other serious health effects​. See more here.