Recommendation No. 7 from the Chemical Emergencies Work Group calls for a law that requires EPA and other agencies to follow GHS, saying a uniform safety data sheet format is needed to ensure emergency responders and community members have complete and consistent access to information on chemical exposures and hazards.

Report Backs GHS Adoption, Safer Technologies Law

CDC has posted the National Conversation on Public Health and Chemical Exposures draft work group reports at, making them available for public comments until Sept. 20, including the chemical emergencies work group's report. Its 12 recommendations address training, partnerships, green technologies, funding, and three areas of major importance to safety and industrial hygiene professionals: exposure limits, safety data sheets and the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), and enacting a national law strongly encouraging facilities to utilize inherently safer technologies (IST). This report offers support for H.R. 2868, a bill sponsored by U.S. Rep. Bennie Thompson, D-Miss., who chairs the Homeland Security Committee; the U.S. chemical industry opposes the bill.

Recommendation #6 from the Chemical Emergencies group expresses support for H.R. 2868, which would reauthorize the Chemical Facility Anti-Terrorism Standards (CFATS) now set to expire in October 2010. The bill also would require EPA to set parallel security programs for drinking water and wastewater facilities. The U.S. House of Representatives passed H.R. 2868 in November 2009; the report says the work group believes the Senate should pass a similar bill and it should be signed into law.

The chemical industry contends IST should not be mandatory and prefers a Senate bill, S. 2996, which likewise would reauthorize CFATS through 2015.

"The only certain way to protect our communities is to remove the possibility of a toxic gas release by converting facilities to safer, more secure alternative technologies. There are many existing off-the-shelf remedies that can be used," recommendation #6 states. "Bleach plants can reduce danger to employees and surrounding populations by generating chlorine on-site without rail shipment and bulk storage. . . . The primary criterion for substitution should be to reduce the number of people potentially exposed to acutely toxic gases. Additional criteria should be to reduce the probability of release and/or to reduce the toxicity of the material that would potentially be released."

Recommendation #7 calls for a law that requires EPA, OSHA, the Consumer Product Safety Commission, and the U.S. Coast Guard to follow GHS, saying a uniform safety data sheet format is needed to ensure emergency responders and community members have "complete and consistent access to information on chemical exposures and hazards." EPA should harmonize the FIFRA hazard communication standards with GHS as far as possible within three years, the recommendation states.

Recommendation #10 involves consistency of exposure limits. Saying the gaps between OSHA's and those of NIOSH and ACGIH are of "great concern" to first responders and first receivers, this recommendation calls on Congress to "streamline or remove the impediments that make it harder for OSHA" to update its PELs and should appropriate sufficient funding for the agencies to develop consistent limits. Within OMB, the Office of Information and Regulatory Affairs (OIRA) "should do everything in its power to facilitate the swift fulfillment of this recommendation," it states.

Submit comments by e-mail to; by mail to National Conversation c/o RESOLVE, Inc. 1255 23rd Street, NW, Suite 875, Washington, DC 20037; or by fax to the attention of Jason Gershowitz at 202-338-1264.