Should the irritant properties of dusts be reflected in the HMIS® health rating?
In “Hazard Communication Standard Interpretive Quips,” OSHA gives the following interpretation regarding “nuisance dusts.” “The particles not otherwise regulated are exempt [from the HCS] unless evidence exists that they present a health or physical hazard other than physical irritant effects.” Although this factor may be included at the employer s discretion, there is no requirement under the HCS to consider irritation due to mechanical abrasion from the physical presence of an otherwise inert particle (i.e. “grit”). However, if the dust causes any health effect other than a “physical irritant effect,” the effect must be considered when assigning the HMIS® health rating.
