Since its adoption in 1983, the OSHA Hazard Communication Standard (HCS) has required manufacturers and importers of substances (typically chemicals and mixtures) to:
- review the available scientific literature to determine the potential health or physical hazards that may result from the use of the substances and
- communicate to their customers, in the form of labels and safety data sheets (SDS), the hazard information as well as recommendations for protection against the hazards.
The customers (who OSHA calls employers) are to:
- have written hazard communications programs,
- make available to employees the labels and safety data sheets provided by the manufacturer or importer and place appropriate warning labels on intermediate processing and storage containers and
- formally train employees on hazards of, and appropriate protective measures for, substances found in the workplace.
Because of the health or physical hazards potentially associated with their use, many of the raw materials used by composite manufacturers have long been provided with hazard warning labels and SDSs. For example, under the HCS, suppliers of unsaturated polyester resin provide their composites manufacturing customers with labels and SDS warning of the potential for fire and mild temporary nervous system effects that may result from use of the materials and recommending safeguards such as elimination of open flames or sparks and use of protective eyewear and gloves.
Molded composite products have typically been considered articles, which are exempt from the HCS. OSHA’s March 26, 2012, revision to the HCS, however, made several changes that are believed to affect the applicability of the standard to molded composite parts. As a result, many composites manufacturers may be required to provide their customers with labels and SDS warning of a hazard that may result from normal use of molded composite products.
A number of industrial explosions and fires have been attributed to combustible dust explosions, including several that resulted in worker fatalities and serious injuries. While some industries such as grain processing and wood milling have long been known to involve combustible dust hazards, many of the recent combustible dust incidents have been in industries such as metals and polymer processing where such hazards were not expected to be present.
In response to a growing awareness of the potential for combustible dust to contribute to a fire or explosion hazard, in 2007 OSHA instituted its Combustible Dust National Emphasis Program (NEP). Under the NEP, composites manufacturers and other industries known to generate or process combustible dusts are targeted for inspections.