Revisions needed in the Hazard Communication standard to improve worker and community access to critical information on toxicity of chemical products used in the workplace and home

Material safety data sheets (MSDS) are currently the principal source for workers and consumers on composition and toxicity of chemical products. The Hazard Communication Standard (HazCom) is deeply flawed and requires changes to provide procedures and documents useful for protection of public health. Areas in which revisions are needed include trade secrecy, retention of MSDS in a central repository, requirements for literature searches, establishment of criteria for accuracy of MSDS and development and implementation of programs to improve MSDS accuracy. Other changes needed include requirements for regular and timely updating of sheets, ensuring that workers and the public receive documentation of literature searches and preparation of MSDS, and relaxation of Federal preemption of state occupational health programs in the area of toxicity/risk communication (worker right-to-know). OSHA must convert a largely voluntary performance-based and largely unenforceable standard to one that is both mandatory (while being flexible) and enforceable.