September 20, 2005

American Chemistry Council

Attn: Susan Blanco

Via: e-mail

RE: American National Standard Institute (ANSI): Hazardous Industrial Chemicals – Precautionary Labeling (ANSI Z 129.1).

The American Association of Occupational Health Nurses (AAOHN) is pleased to submit comments on the American Chemistry Council’s (ACC) draft revision of the ANSI Z129.1document.

AAOHN commends the ACC for this mammoth undertaking and agrees that precautionary labeling for chemical products/materials is necessary for adequate identification of hazardous warnings to avoid harmful exposures, thereby preventing injury and illness. Examples of such precautionary labeling are: Environmental Protection Agency (EPA) - pesticides; Food & Drug Administration (FDA) - drugs; National Electrical Manufacturers Association (NEMA) - welding, etc.

The Association supports the use of universal and culturally suitable color codes and symbols, as well as the use of labeling schemes with precautionary statements, which provides information similar to that required for Material Safety Data Sheets (MSDs). The Association recommends that the ACC strive for standardization with other standards/guidelines to increase compliance with workers, globally (e.g. populations whose primary language is something other than English).

The definition of terms is very helpful but there is inconsistency with definitions and labeling of chemicals. Because the document is so long, it is difficult to even follow the numbering system. The tables found in the Annexes are clear and provide adequate precautionary alerts.

The following are AAOHN’s recommendations:

• Page 9, section 3.2.2, Physical Hazard Criteria: The varying definition differences between regulatory agencies (Department of Labor, Occupational Safety and Health Administration, etc.) may confuse the label writer/reader and result in injury/illness because of failure to read the label with each use. Again, the issue is standardization (e.g. one definition).

• Page 30, section 5.8.1, First Aid Statements: References to "physicians" should read "health care professionals (HCPs)", which would include physician, physician assistant, nurse practitioner, registered nurse, etc. First aid is within the scope of practice for all these health care providers, not just the purview of physicians.

• Page 31, section 5.8.1.3, 2^nd paragraph: Change wording to "For more detailed…consult a HCP.

• Page 31 to 32, section 5.9, Antidotes/Notes to Physician: AAOHN recommends an additional statement addressing new information updates in a timely manner within the notes to physician category. If information is out of date, who is responsible for removing, revising, etc.? Again, change physician to HCP.

• Page 33, section 5.11: For consistency, the spill or leak statements would be clearer to state "do not flush…." And "prevent runoff….".

• Page 35, section 5.13: From the Occupational and Environmental Health Nurse (OHN) experience, when outer and inner container labels are not the same or differ, the possibility of a misinterpretation exists. Therefore, the labels should be consistent.

• Page 39, Table B, Instructions in Case of Contact or Exposure: In many companies the OHN is the only HCP onsite, therefore we recommend changing the terminology to health care professionals.

• Page 81, Annex C, System of Classification: Physician should be changed to HCP.

• Page 84, Annex D, Glossary: American Industrial Hygiene Association (AIHA) and American Conference of Governmental Industrial Hygienist (ACGIH) are listed in the Glossary. A glossary is not the place to list organizations unless you are defining acronyms. We recommend including the occupational safety and health associations or none of them.

The Association appreciates the opportunity to respond to the American Chemistry Council’s draft revision of the ANSI Z129.1, Precautionary Labeling. As always, we will continue to lend our input and assistance to American Chemistry Council, ANSI, and other governmental and professional organizations to facilitate safe and healthful workplaces and communities.

Sincerely,

Susan A. Randolph, MSN, RN, COHN-S, FAAOHN

President

CC: AAOHN Board of Directors