# Briefing Report to Congressional IZlequester’s

iii& 1992 ---- ? 

# OCCUPATIONAL

SAFETY& HEALTH Employers’ Experiences in Complying With the Hazard Communication Standard 

# IIIll

I

146524



## GAWIIRD-9%63BR,,,I

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1

# GA!0 United States General Accounting Office Washington, D.C. 20548
Human Resources Division 

### B-243568 May 8,1992 The Honorable Dale L. Bumpers Chairman, Committee on Small Business United States Senate The Honorable Norman Sisisky Chairman, Subcommittee on Exports, Tax Policy, and Special Problems Committee on Small Business House of Representatives As you know, the Hazard Communication Standard (HCS) 

### requires employers to identify workplace chemical hazards and communicate this information to employees. First promulgated for the manufacturing sector in 1983, HCS



### was extended to nonmanufacturing employers in 1987. HCS 

### is administered by OSHA,

### an agency of the U.S. Department of Labor. In response to your request and after discussions with your offices, we examined (1) the difficulties small employers report they are experiencing in complying with HCS,

### in particular with the material safety data sheet (MSDS)

### requirements,’ and (2) the methodology underlying OS-IA’S 

### estimates of costs for small employers in nonmanufacturing industries to comply with the MSDS



### requirements. Consistent with your request, we focused on small employers, although we collected information on employers of all sizes. (In our 1991 report, we responded to other questions you asked about HCS2)

### We presented our preliminary results in a briefing with your offices on October 24, 199 1. Our final results appear in this report, which includes the charts used in that briefing (see app. I).

‘Typically, the MSDS is a 1-5 page document detailing, among other information, the chemical’s properties and hazardsand precautions for its safe useand handling. For examples of MSDSs,see Occupational Safety & Health: OSHAAction NeededTo Improve Compliance With Hazard Communication Standard (GAO/HRD-92-8, Nov. 1991).

“GAO/HRD-92-8.

Page 1 GAO/HRD-9243BR OSHA Hazard Communication StandardB-24350g



# Resultsin Brief “’ Of the small employers (those with fewer than 20 employees) we surveyed who appeared to be complying with the Hazard Communication Standard,3 almost 70 percent reported little difficulty with either of the two MSDS 

### requirements. However, almost 80 percent of such small employers reported problems complying with HCS’s 

### training requirements. Over half of small employers reported some cost increasesto comply with HCS’s 

### paperwork/clerical requirements, but fewer than a fifth reported “great” or
“very great” cost increases.4 Although OSHA'S



### general approach to estimating the cost to nonmanufacturing employers of complying with the MSDS 

### requirements is sound, the estimates derived from the cost model depend on the assumptions OSHA



### made about the values of the variables, Becauseof data limitations, we did not assess the accuracy of most of the numerical values OSHA 

### assumedin its cost calculations. In one case,OSHA 

### appears to have understated the compliance costs by excluding nonwage benefit costs such as pensions and health benefits from its wage rate variables. About 45 percent of all employers appearing to comply believed that, on balance, HCS



### had been beneficial for workers, compared with about 9 percent who reported that HCS 

### had a net negative effect and 36 percent who said it had equally positive and negative effects or none at all. Nevertheless, over 56 percent of all such employers reported a “great” or very “great” improvement in the availability of hazard information in the workplace and in management’s awarenessof workplace hazards.Also, about 30 percent of the employers said they replaced hazardous chemicals used in their workplaces with less hazardous ones becauseof information they received on an MSDS.

%e define asappearing to comply with HCSthose employers who received MSDSsand provided information to us indicating compliance with the MSDS,labeling, and training requirements. Employers who appearedto be in noncompliance with HCStended to report lessserious difficulty or lower cost increaseswith HCS.To avoid misstating the actual extent of compliance difficulties and related cost increases,we focused on employers appearing to comply with HCS. Becausewe did not determine whether employers maintained awritten hazardcommunication program, we did not ascertain actual compliance.

‘To obtain employers’ perceptions concerning HCS’seffect on their businessoperation costs,we asked for what they considered to bethe most appropriate responsesto several questions regarding the cost Impact of various aspectsof HCS.Theseresponsesranged from “not at all,” ‘little,” “somewhat,”
“moderately,” “greatly,” to a high of “very greatly.” (Seeapp. 11 and IV.) We did not obtain actual employer cost data.
Page 2 GAO/HRD-92.83BR OSHA Hazard Communication StandardB-243568



### Scope 

# iind Methodology To answer your question about employers’ experience with HCS, we 

### (1) conducted a nationally representative survey of about 2,000 construction, manufacturing, and selected service industry employers, (2) interviewed representatives from five drug and chemical distributor employers, and (3) interviewed OSHA officials about HCS



### compliance issues. We surveyed a random sampleof employers in three industry groups (manufacturing, construction, and selectedservice industries) listed in the national data basemaintained by the U.S. Small BusinessAdministration as of July 1990. Our results are weighted so that our estimates describe the information we would have obtained had we surveyedthe universe of employers in that data base. Becausewe wanted to compare the experiences of employers of different sizes,we stratified our sample by each employer’s number of employees. (Seeapps. II and IV.) To answer your question about OSHA’s 

### methodology in estimating compliance costs for the standard’s MSDS 

### requirements, we obtained and analyzeddocumentation from OSHA 

### on its model and general methodology for estimating the compliance costs of the standard’s MSDS 

### requirements in nonmanufacturing industries. (Seeapp. III.) Our work was performed between July 1990 and July 199 1 at OSHA’S 

### headquarters and Philadelphia regional office in accordance with generally accepted government auditing standards. 

# Background Under HCS,

### chemical manufacturers and importers must evaluate each chemical they produce or import to determine if it is hazardouswhen used in the workplace. For chemicals determined to be hazardous, the iirm must prepare a material safety data sheet. Manufacturers and importers also must label the chemical’s container and include the MSDS 

### with the initial shipment of the chemical to employers. Employers who receive hazardous a chemicals without labels or MSDSS 

### must obtain them from the supplier or produce their own. They are also required to (1) maintain a current file of MSDSs 

### for the chemicalsthey useand make it accessibleto employees, (2) develop a written program describing how they will meet HCS's 

### requirements, and (3) train their employeesin the safe handling and useof hazardous chemicals. In our November 199 1 report, we focused on the extent of small employer compliance with HCS.

### From a nationally representative survey, we found

Page 3 GAO/HRD-92-63BR OSHA Hazard Communication StandardB-243568



### 58 percent of small employers and 52 percent of all employers to be out of compliance with key requirements of HCS.6 

### Moreover, we reported that many small employers may have been out of compliance, not becauseof HCS’s 

### administrative burden but becausethey were unaware of HCS. 

### Over 29 percent of all small employers said that they had little or no awareness of HCS, 

### and almost 40 percent of those with at least someawarenessdid not know that employers with 10 or fewer employeesare covered by HCS. 

# Principal Flndings
Most Small Employers Reported No Difficulty Complying With MSDS Requirements Almost 70 percent of the small employers who appeared to comply reported no difficulty either maintaining a current MSDS 

### file or ensuring employee accessto it. For the individual requirements, over 75 percent of these small employers reported no difficulty maintaining a current MSDS 

### file and over 80 percent described no difficulty ensuring employee access to it. (Seefig. 1.4.) Small employers reported lessdifficulty complying with the MSDS 

### requirements than did large employers. (Seefig. 1.5.) Small employers’ ability to comply with the MSDS 

### requirements may be due to the small number of MSDSS 

### they had. Half of the small employers appearing to comply reported that they had 8 or fewer MSDSS, 

### with almost 75 percent having 25 or fewer. By comparison, half of all large employers-those with 500 or more employees-reported that they had 250 or more MSDSS. 

# SomeProblems Reported With HCSTraining Requirement Almost 80 percent of small employers who appeared to be complying with HCS 

### reported some problems complying with the HCS 

### training a requirements. Insufficient training expertise and that the MSDSS 

### were too complex to use in training were the problems most small employers reported they experienced to at least “some” extent. (Seefig. 1.7.) Large employers were more likely to report difficulties to some extent with all aspectsof the HCS



### training requirement. (Seefig. 1.8.)

50ther findings included that the MSDSshad readability, format, and languageproblems.

Page 4 GAOMRD-92-63BR OSHA Hazard Communication StandardB-243568



# Hti of Small Employers Reported SomeCost IncreasesDueto HCS Requirements The implementation of HCS 

### could result in cost increasesfor small employers. For example, clerical and paperwork costs could increase as employers collect or develop MSDSS 

### for all hazardous chemicals used in their workplaces and then keep their MSDS 

### files current0 For each individual cost category, over half of the small employers who appeared to comply with HCS 

### reported some increased costs. However, fewer than 15 percent of small employers described these increasesas
“great” or “very great.” (Seefig. I. 10). A greater proportion of large than small employers said that they experienced cost increasesfrom compliance.7(Seefig. I. 11.) In the key areas of papenvorldclerical and MSDS 

### storage costs, about 40 percent of small employers reported little or no increase in either category and over 80 percent reported at most

“moderate” cost increases.


# Distributors’ MSDS Diffkulties Appear to Vary by Industry Compliance difficulties with the MSDS 

### requirement vary by industry, judging from interviews we conducted with distributors of chemicals, pharmaceuticals, and health and beauty aids. Chemical distributors adapted to HCS



### with few problems, implementing computerized systemsfor shipping and receiving MSDSS 

### to respond quickly to customer requests for MSDSS. 

### Their HCS



### compliance costswere relatively modest, the distributors said, and did not create an individual competitive disadvantage because they fell on all employers in the industry. Drug and health/beauty aid distributors also have adapted to HCS,

### although they reported greater difficulties than the chemical distributors. For distributors handling many chemicals covered by HCS, 

### the tracking systems for maintaining current MSDSS 

### for each substanceand transmitting the appropriate sheetsto customers were not aswell developed asthe systems h used by the chemical distributors. In addition, drug and health/beauty aids distributors reported uncertainty about products for which they were required to maintain MSDSS 

### and customers to whom they should ship MSDSs.

‘In 1087, OSHAestimatedthat the extension of HCSto nonmanufacturing industries would cost employers about $687 million during 

### the first year of implementation. 7Forexample, about 76 percent of the large employers had some increasein paperwork/clerical costs from HCScomparedwith 53 percent of small employers.

Page 5 GAO/HRD-92-63BR OSHA Hazard Communication StandardB-243568



# OSHACost Model Sound but OSHA’S 

### methodology for estimating the costs of compliance with the 

# Accuracy of AssumedValues standard’s MSDS 

### requirements, including the general approach and 

# Is Unconfirmed equations, is fundamentally sound. However, the estimates derived from the cost model depend on the assumptions OS-IA 

### madeabout the values of the variables. For example, OSHA 

### appears to have understated the costs of complying with the MSDS 

### requirements by not including nonwage benefit costs such as pensions and health benefits into the wage rate variables. Becauseof data limitations, we did not judge the reasonablenessof many of the other numerical values OSHA 

### used in its calculations. The more realistic the assumptions, the more accurate OS-U’S

### cost estimates. (See app. III.) 

# Employers Reported Benefits The effect of HCS 

### on employeeswas positive in the opinion of nearly half 

# F’romHCSto Workers and (some 45 percent) of employers of all sizeswho appeared to comply with 

# Management it; negative in the view of about 9 percent. Most of the rest-36 percent, believed that it had equally positive and negative effects or none at all.” (Seefig. I. 15.) Over 56 percent of employers reported “great” or “very great” improvement in the availability of hazard information in the workplace and in management’s awarenessof workplace hazards.D (Seefig. I. 16.) Large employers were more likely to report benefits from HCS 

### than small employers. The vast majority of all employers-between 74 and 84 percent-believed that HCS 

### had no impact on productivity, employee or management morale, or workplace-related injuries and illnesses. Between 5 and 10 percent of all employers said worker or management workplace morale declined, and 10 percent said productivity declined. However, about 17 percent of all employers believed that HCS 

### had reduced workplace-related employee injuries, while only about 1 percent saidthat HCS 

### increased workplace injuries. Despite MSDSS'



### weaknessesin format and language, over half of the employers believe that MSDSS 

### provide essential information about the risks, safe handling, and general useof hazardous substances.Almost 30 percent

sHCScould havea negative effect on employeesif, for example, the hazard information resulted in increasedpsychological stressamong employees. eAbout 40 percent of all employers also believedthat HCShad a positive effect on management-for example, creating a safer and more productive workplace-compared with lessthan 20 percent who believed it had a net negative effect.

Page 6 GAOIHRD-92-63BR OSHA Hazard Communication StandardB-243568



### of employers said that they replaced a hazardous chemical with a less hazardous one becauseof information they received on an MSDS. 

# Agency Comments OS-I.4 

### believesthat our findings demonstrate that the Hazard Communication Standard has contributed significantly to better safety and health for workers while at the sametime posing minimal compliance problems for employers. The agency interprets our findings as supporting OSHA’s 

### contention that the standard is feasible for small businesses.The agency agreed to consider our concerns regarding their calculation of nonwage benefit costs in future cost estimation efforts and to include this report in its entirety in the record of future rulemaking on this issue. (See app. VI.)

As arranged with your office, we will send copies of this report to the Secretary of Labor and other interested parties and make it available to others upon request. If you have any questions concerning the report, please call me at (202) 512-7014. We list other major contributors in appendix VII.

Linda G. Morra Director, Education and Employment Issues

Page 7 GAO/HRD-92-63BR OSHA Hazard Communication Standard

# Contents

Letter 111 

# Appendix I Occupational Safety& Health: Employers’ Experiences in Complying With the Hazard Communication Standard Appendix II GAO’S Employer Surveyon OSHA’S Hazard Communication Standard: Methodology, Sampling, andAnalysis Questionnaire Design Initial andAausted Universeand SampleSizes Likely Employer ComplianceWith Individual HCS Requirements GAO Interviews With Chemical and Drug Distributors 35 Assessmentof OSHA’SCost Estimate Methodology 36 

# Appendix III
-- 

# GAOAssessmentof OSHA’S Model for Summary of OSHA’SCost Model Basic Equations in OSHA’SCost Model 

# Estimating Compliance CostsWith the MSDS Requirements of HCS Appendix IV Information on Responses

to Selected GAO Survey Questions 42 a

Page 8 GAO/H&D-92-63BR OSHA Hazard Communication StandardContentr



# Appendix V Data Supporting Figures in Appendix I Appendix VI 61 

# Comments From the Department of Labor Appendix VII Major Contributors to This Report 63



# RelatedGAO Products 64 

# Tables Table II. 1: Standard Industrial Classification (SIC) Codesfor SelectedIndustry Groups, GAO Employer Survey(July 1991) 31

Table 11.2:

Number of Employers Identified in Selected Industry and Employer Groups, by Size,GAO Employer Survey(July 1991) 32

Table 11.3:

Number of Employers Sampledby Industry Group and Employer SizeStrata, GAO Employer Survey(July 1991) 32

Table 11.4:

Adjusted Sampleand ResponseRatefor Industry Group and Employer SizeStrata, GAO Employer Survey (July 1991) 33

Table 11.5:

Determination of Adjusted Universe,GAO 1, 

### 34 Employer Sample(July 1991) Table III. 1: Estimated Costsof ComplianceWith HCSto 39 Nonmanufacturing Industry, OSHACost Model TableV. 1: Datafor Figure I.4 Table V.2: Datafor F’igureI.5 Table V.3: Datafor F’igureI.7 TableV.4: Datafor Figure I.8 TableV.5: Datafor F’igureI. 10 TableV.6: Datafor F’igureI. 11 Table V.7: Datafor F’igureI.16 58 58 58 59 59 59 60

Page 9 GAO/HRD-92-03BR OSHA Hazard Communication StandardContents



# F&p-es Table V.8: Data for Figure I. 17 60 A Figure I. 1:AssignmentObjectives 12 Figure 1.2:Methodology 13 Figure 1.3:Employer ExperiencesWith HCS:MSDSDuties 14 Figure 1.4:Most SmallEmployeesReport No Difficulty With 15 MSDSDuties Figure 1.5:More Large EmployersThan SmallReport MSDS Difficulties 16 Figure 1.6:Employer ExperiencesWith HCS:Training Requirement 17 Figure 1.7:SmallEmployers HaveVaried ExperiencesWith HCSTraining 18 Figure 1.8:More barge EmployersThan SmallReport Training Problems 19 Figure 1.9:Employer ExperiencesWith HCS:Compliance costs 20 Figure I. 10: Over 50 Percentof SmallEmployers Had Some Cost Increases 21 Figure I. 11: More Large EmployersThan SmallReport Cost Increases 22 Figure I. 12: Distributors’ ExperiencesWith MSDSDuties F’igureI. 13: OSHA’SCostMethodology F’igureI. 14: Benefits Employers Report Prom HCS Figure I. 15: Other HCSEffects Reported by Employers Figure I. 16: Over 40 Percentof EmployersSayHCSHas Positive Effects 23 24 25 26 27 Figure I. 17: Employers Report Improvements Dueto HCS 28 4

Abbreviations HCS 

### HazardCommunicationStandard IMIS 

### Integrated ManagementInformation System OSHA 

### Occupational Safetyand HealthAdministration MSDS 

### Material SafetyData Sheet SBA 

### SmallBusiness Administration SIC 

### Standard Industrial Classification USEEM 

### United StatesEmployment and Enterprise Microdata TPV 

### Total PresentValue

Page 10 GAO/HRD-9243BR OSHA Hazard Communication Standard

.‘

.’ ,I ,

, , ,Page 11 GAO/HRD-92-63BR OSHA HazardCommunication Standard

### Appendix I 

# ,) Occupational Safety& Health: Employers’ Experiences in Complying With the Hazard

~ Communication Standard

Flgure 1.1: 

# Ek) Assignment Objectives

l 

# Identify employers’ (especially small employers’) difficulties, costs, and benefits in meeting HCS requirements

l 

# Assess OSHA’s methodology in estimating compliance costs with the MSDS requirement

Page 12 GAOIHRD-92-63BR OSHA Hazard Communication StandardAppendix I Occupational Safety 4%

Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Flaure 1.2: 

# G+AD

Methodology

l 

# Conduct national employer survey in three industry groups 

# lfocus analysis on employers in likely compliance *compare data by employer size and industry

l 

# Conduct interviews with chemical/drug distributors

l 

# Obtain and review OSHA’s compliance cost model

Note: We describe the methodology used to develop our survey in appendix 11, which also includes a discussion of the interviews with chemical and pharmaceutical distributors. Appendix Ill contains our assessment of OSHA’s compliance cost estimates regarding the Hazard Communication Standard’s MSDS requirements, and appendix IV, responses to selected survey questions and the associated sampling errors

Page 13 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix I Occupational Safety & Health: Employers’ Experiences In Complying With the Hazard Communication Standard

Flgure 1.3: 

# w E mployer Experiences With

HCS: MSDS Duties

l 

# About 70 percent of small employers had no difficulty with the MSDS duties @ maintaining

current MSDS file *assuring employee access

l 

# Most small employers had 8 or fewer MSDSs

l 

# Most large employers had 250 or more MSDSs and difficulty complying with MSDS duties

Note: About 70 percent of small employers-those with fewer than 20 employees-appearing to comply with HCS reported no difficulty complying with both MSDS requirements.

Page 14 GAO/BRD-92-63BR OSBA Hazard Communication StandardAppendix I Occupational Safety & Health: Employers’ Experiences in Complying With the Hazard Communlcatlon Standard

Flgure 1.4: 

# Gm Most S mall E mployers Report

No Difficulty With MSDS Duties

Note: For each individual MSDS requirement, about 80 percent of all small employers appearing to comply reported no difficulty complying. About 7 percent of employers found complying with each MSDS requirement “very difficult.” Over 26 percent found maintaining current MSDS files “very easy,” and over a third found assuring employees access to the files “very easy.”

Page 15 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix I Occupational Safety & Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Figure 1.5: 

# GAO More Large Employers Than

Small Report MSDS Difficulties

PWCM ol Employm Who Fwnd Rqulnmw~l B-uvwy Dimoull

Note: Almost 50 percent of large employers-those with 500 or more employees-appearing to comply found it at least “somewhat difficult” maintaining and keeping MSDSs up to date, and about 13 percent found it “very difficult” to do so. Thirty percent of such employers found it “somewhat” difficult ensuring employee access to MSDS files at each worksite, with about 5 percent finding it “very difficult.” a

Page 16 GAO/BRD-92-63BR OSBA Hazard Communication StandardAppendix I Occupational Safety & Health: Employem Experiences LuComplying With the Hazard Communication Standard

Flaure 1.6: 

# G&I Employer Experiences With

HCS: Training Requirement

.-.._- .-_. . ,- ..

l 79 

# percent of small 

# employers had some problems complying with training requirement

l 

# Greatest problems for small employers are with inadequate training expertise and the use of MSDSs in training

l 

# Larger employers more likely to have problems with training requirement

Page 17 GAOiHRD-9243BR OSHA Hazard Communication StandardAppendix I Occupational Safety & Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Figure 1.7: 

# GAO S mall E mployers Have Varied

Experiences With HCS Training

Pmbt.m. Erpwt.nc.d In Prcwldlnp WCSR.,,“tnd ,,.tn,nS

El NwLlMo Enent Sme Exiont Moderate Enent

I Chat Enent

‘day Gnat Extent

Note: While 79 percent of small employers appearing to comply reported difficulty at least to “some

extent” with the HCS training requirement, at most about 54 percent of such employers had difficulty with any aspect of the requirement. About 22 percent of such small employers had “great” or “very great” difficulty providing training to employees at multiple worksites. About 20 percent of employers had similar degrees of difficulty with employee turnover. a

Page 18 GAO/BRD-92-63BR OSHA Hazard Communication StandardAppendix I Occupational Safety % Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Figure 1.8: 

# G-AZ)More Large E mployers Than

S mall Report Training Problems

SO P.,c.nl of Employ.” With ProUwm
79



# 0 Fewer Than 20 Employee8 (Small)

29 m 408 Employees (Medum) 111 500 w More Employeea (Large)

Note: A greater proportion of large than small employers appearing to comply reported difficulties “to at least some extent” on all potential training problems that we asked about (see app.lV). Over 70 percent of these large employers expenenced some difficulty integrating MSDSs into their training program compared with about 50 percent of the small employers.

Page 19 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix I Occupational Safety 81Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Figure 1.9:


# w Employer Experiences With

HCS: Compliance Costs

l 

# Over half of small employers reported some cost increases for each HCS requirement

l 

# Large employers were more likely to report some cost increases than small employers

Page 20 a

GAO/BRD-9243BR OSBA Hazard Communication StandardAppendix I - Occupational Safety & Bealth: Employers’ Experiences in Complying With the Hazard Communication Standard

Flgure 1.10:

# GAD Over 50% of S mall E mployers

Had Some Cost Increases

Note: For each individual area, over 50 percent of small employers appearing to comply found that their costs had increased “somewhat.” However, 15 percent of employers appearing to comply experienced

“great” or “very great” cost increases from HCS’s paperwork/clerical requirements, the largest proportion of any of the five categories and about 8 percent of such employers experienced “great” or
“very great” increases in employee training costs.

Page 21 GAOMRD-9243BR OSHA Hazard Communication StandardAppendix I Occupational Safety & Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Flgure 1.11: 

# w More Large E mployers Than S mall Report Cost Increases

00
70
00 00

.o 20
20 IO
0

Note: Almost 25 percent of large employers appearing to comply reported “great” or “very great” cost

increases from HCS’s paperwork/clerical requirements

Page 22 GAO/HRD-92-63BR OSHA Hazard Communication Standard

,;‘

. ‘/ I, I.,,,’ ‘,”Appendix I Occupational Safety % Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Flgure 1.12:

# MO Distributors’ Experiences

With MSDS Duties Interviews showed that

l 

# Chemical distributors adapted to MSDS duties with little difficulty

l 

# Drug distributors had more difficulty @ Uncertain

about the products covered and recipients of MSDSs

a

Page 23 GAO/HRD-9243BR OSBA Hazard Communication StandardAppendiz I Occupational Safety & Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Figure I.13: 

# QW 

# OSHA’s Cost Methodology

*Structure and approach of OSHA’s cost model regarding MSDS requirements are sound

l 

# However, in one case, OSHA’s model may underestimate compliance costs because nonwage compensation is excluded in wage variable

Note. See appendix III for a discussion of OSHA’s cost methodology.

Page 24 GAOIHRD-92-63BR OSBA Hazard Communication StandardAppendlx I Occupational Safety & Health: Employers’ Experlencee in Complying With the Haze,rd Communication Standard

Figure 1.14: 

# G’GAQ

Benefits Employers Report From 

# HCS

l 

# Over 40 percent of employers report positive HCS effects for employers and employees

l 

# Employers report safety and health improvements due to HCS

l 

# 29 percent of employers say they use a less hazardous chemical in the workplace because of HCS

a

Y

Page 25 GAO/BRD-92-63BR OSBA Hazard Communication StandardAppendix I Occupational Safety & Health: Employers’ Experiences in Complying With the Hazard Communication Standard

Flgure 1.15:

# m Other HCS Effects Reported

By E mployers

l 

# HCS had little effect on productivity, even for those employers reporting great cost increases 017 

# percent of employers report fewer work related injuries

l 

# 16 percent of employers report fewer work related illnesses

Note: Large employers appearing to comply were generally more positive about HCS’s effect on both employers and employees than small employers. Over 67 percent of such large employers believed that HCS had a positive effect on employees-compared with about 45 percent of small employers appearing to comply. Almost 60 percent of such large employers believed that HCS had a positive effect on employers compared with about 42 percent of the small employers. a

Page 26 GAO/HRD-92-63BR OSBA Hazard Communication StandardAppendix I Occupational Safety % Health: Employers’ Experiences in Complying With the Hazard Communication Standard



# GAO Over 40% 

# Of E mployers Say HCS Has Positive Effects

On Employ*n Ellc( al HCS On Emnployba

Page 27 GAOiHRD-92-63BR OSHA Hazard Communication StandardAppendix I Occupatlonal Safety & Health: Employers’ Experience@ in Complying With the Hazard Communication Standard

Figure 1.17: 

# GM E mployers Report Improvements Due to HCS

SO

00

WI

10

a0

10

0 Pnanl 01Employem

Page 28 GAO/HRD-9%63BR OSHA Hazard Communication Standard

### Annendix II 

# GAO’sEmployer Surveyon OSHA’sHazard Communication Standard: Methodology, Sampling, andAnalysis

We gathered data on employers’ experience with OSHA’S 

### Hazard Communication Standard through a questionnaire survey conducted from October 1990 through July 1991. The survey was designed to collect information on the extent of employer awarenessand knowledge of and compliance with HCS;

### employers’ perceived costs, benefits, and difficulties in complying with HCS;

### and sources of employers’ information on HCS. 

# Questionnaire Design Our survey questionnaire was designed to ensure that the data collected were consistent.* We pretested it with representatives of sevenemployers in the Washington, D.C., area, including a small and a medium-sized construction employer; a small manufacturing employer; and a small, two medium-sized, and a large personal services business.We gave OSHA 

### officials copies of the draft questionnaire for review. Guided by the results of the pretest and OSHA



### officials’ comments, we revised the questionnaire to ensure that all questions were fair, relevant, and easyto understand and answer. We also tested it to ensure that the task of completing it would not place too great a burden on the respondent. 

# Initial andAdjusted Universe and Sample Sizes We mailed questionnaires to a random sample of employers, stratified by industry and employer size and selected from aJuly 1990 United States Employment and Enterprise Microdata (USEEM) 

### file data baseobtained from the U.S. Small BusinessAdministration (sBA).~ 

### The USEEM



### file includes information on different types of business organizations. We included in our population only records of employers representing (1) employer headquarters with a single establishment, (2) employer headquarters with multiple establishments, or (3) subsidiary headquarters. For employers who maintained operations in several industries or sectors, our questionnaire included instructions to help 1, ensure that answerswere provided for what they considered their most typical or common operation.

‘For a copy of the questionnaire, seeOccupational Safety& Health: OSM Action NeededTo Improve Compliance With Hazard Communication Standard (GAO/HRD-92-8, Nov. 1991).

“SBA modified an employer data baseobtained from the Dun and Bradstreet corporation. We chose USEEM becauseSBA’s modifications improved the file’s reliability and SBAfrequently updatesthe information to improve its accuracy. The USEEM file also includes employer phone numbers and addresses,aswell as namesof employer representatives, to facilitate additional contact if necessary. Finally, we were able to obtain and accessthe fde with minimal difficulty.

Page 29 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix II GAO’s Employer Survey on OSHA’s Hazard Communication Standard: Methodology, Sampling, and Analysis



### We choseour samplefrom three different industry groups (seetable II. 1.):

l 

### The manufacturing sector, becauseit wasthe first major industrial group covered by HCS, 

### beginning in 1985.

l 

### The construction sector, becauseit was not covered by HCS 

### until 1987, and although it is an industry with considerable experience with OS-IA, 

### a number of its representatives have reported difficulties in complying with HCS.”

l 

### The personal services sector, a combination of various service industry operations, including personal services, automotive, and other repair service operations where employeesare very likely to come into contact with hazardous chemicals.An industry group not covered by HCS 

### until 1987, it appears to have lessexperience with OSHA 

### than someothers.4 Representatives of various segmentsof this sector also have reported difficulties in complying with HCS.

“In FY 1989-90, almost half of all inspections reported in our OSHAinspection data baseinvolved construction worksites. SeeGAO/HRD-92-8. 41n FY 1989-90, only about 3 percent of all inspections reported in our OSHAinspection data base involved worksites in SICcodes 72, 75, and 76. SeeGAO/HRD-92-S.

Page 30 GAO/HRD-92-63BR OSHA Hazard Communication Standard

.,a ,- ” ‘, ‘,Appendix IL GAO’s Employer Survey on OSwA’s Hazard Communication Standard; Methodology, Sampling, and Analysis

Table 11.1:

Standard lndurtrlal Classlficatlon (SIC)Codes for Selected Industry group SIC code Industry Groups, GAO Employer Survey Descrlptlon ._--_--- (July 1991) Manufacturing 2000-3999 All durable and nondurable manufacturing industries -. --- -- __- Construction industries Personal services 1500-1799
7211 7212
7213 7216 7217 7218 7219 7221 7231 7241 7251 All construction

___-- --- ___-.- __-- Power laundries, family and commercial Garment pressing and agents for laundries and dry cleaners, Linen supply Dry-cleaning plants, except rug cleaning Carpet and upholstery cleaning Industrial launderers Laundry and garment services Photographic studios, portrait Beauty shops Barber shops Shoe repair shops and shoeshine parlors 7261 Funeral services and crematories 7500-7599 Automotive repair services, garagesa 7600-7699 Miscellaneous repair services aTheseindustries include, among other activities,automotive rentaland leasing; general automotive repair;top, body, and upholstery repairand paint shops; tire retreadingand repair; and other automotive services. 

### To obtain information about the experiences of employers of various size, we stratified our sample accordingly, defining employers with fewer than 20 employeesas small, those with 20 to 499 employeesas medium-sized, and those with 500 or more employeesas large (seetables II.2 and II.3).5

%e classified employers by sizeand industry according to the initial SBA/Dunand Bradstreet sizeand industry classification rather than the employers’ survey response.

Page 31 GAO/HRD-92-63BR OSH.4 Hazard Communication StandardAppendix II GAO’s Employer Survey on OSM’s Hazard Conummicatlon Standard: Methodology, SampMn& and Analysis

Table 11.2:.

Number of Employers ldentlfled In Selected Industry and Employer Groups, by Size, GAO Employer Survey (July 1991) Industry groijp ___- Manufacturing --- --..___ Construction Personal services -..-.-__ 1-19 346,103 742,255 693,250 Number of employees

20-499 500 or more 99,329 6,756 51,374 634 14,390 207

___- All 452,190 794,263 707,647 Total 1.781.608 165.093 7.599 1.954.300

Table 11.3:

Number of Emolovers Sampled by Industry Grduphd Employer Size Strata, GAO Employer Survey (July 1991) Employer size (no. of employees) ---.---_____ Number of employees by Industry group Personal Construction Manufacturing services Total Fewer than 20 300 300 285 885 --_..- --.-..-._--..~---~ 20 to 499 215 215 203 633 --___ 500 + 160 215 94 469 Total 675 730 582 1.987 

# Ad(justedSampleSizeand ResponseRate We mailed 1,987 questionnaires to employers throughout the United States.After adjustments for employers not meeting our criteria, such as no longer being in operation, being self-employed with no employees, or classified in the incorrect industry, our count was 1,120 responsesfor a 77-percent response rate (seetable 11.4).In addition, we assumedthat any employer whose questionnaire was returned to us by the U.S. Postal Service as undeliverable and had no forwarding address and no current telephone listing was no longer in operation. Most employers classified as such were in the small employer (fewer than 20 employees) stratum.

Page 32 GAO/HRD-92.63BR OSBA Hazard Communication StandardAppendix II GAO’s Employer Survey on OSIiA’s Hazard Communication Standard: Methodology, Sampling, and Analysis

fable 11.4:

Adjusted Sample and Response Rate for Industry Group and Employer Size Strata, GAO Employer Survey (July 1991) Industry group/ employer size ----- Construction -.-______--. Fewerthan20emdovees - Number Percent Sa;yk Adjusted

size received received

-___ --__l -_I___ 300 137 97 70.8% 20to499employees 215 194 155 79.9 -----__I_-- --- 500+ employees 160 148 120 81.1 -_ - ____ _--.- Total 675 479 372 77.7 Manufacturing ~____- -.___ Fewerthan20employees 300 159 113 71.1 ------- _ -- 20to499employees 215 207 160 77.3 --___- 500+ employees 215 198 173 07.4 -.---- l_l_.__ ------ Total 730 564 446 79.1 Personal services ___- -~-_~ Fewerthan20employees 285 149 102 -- -.-.------.-.- ___-__ __-___-_ -6_8_~ 20to499em~lovees 203 177 128 72.3 500+ employees .-...- .._ --.--I_ Total Total employers with Fewer than 20 employees 20to499employees -_.-_..-.---.--~~ 500+ employees Total 94 81 72 88.9 582 407 302 74.2
885 445 312 70.1 ____- 633 S78 443 76.6 ____-__ __I-.---..-... 469 427 365 85.5 1967 1450 1120 77.2


### As HCS,

### like OSHA 

### regulations generally, applies only to employers with employees,we excluded employers who reported themselvesas self-employed with no employees. In addition, we excluded employers with operations exclusively outside of our designated industries asspecified in the SIC

### codes in table II. 1. Finally, we excluded employers who were financial holding companies and had no actual operations or employees in any of the industries we were surveying. l 

# Measuresto ReduceNumber To maximize our response rate, we conducted two mail and two telephone 

# of Nonrespondents follow-ups. The lowest response rates were for the small employer strata, with small personal services employers having the lowest at 69 percent. Scientifically selecting our sample enabled usto usethe results to represent employers in the universe. To reflect the employers in the entire universe, we weighted each of the employers in our sample (seetable 11.5). To obtain the estimated number in the adjusted universe, we multiplied the adjusted sample of respondents by the corresponding assigned industry

Page 33 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix II GAO’s Employer Survey on OSHA’6 Hazard Communication Standard; Methodology, Sampling, and Analynis



### weight. Our estimates represent employers in the universe who probably would have responded had they been sent a questionnaire.

Table 11.5:

Determination of AdJusted Universe, QAO Employer Sample (July 1991) Industry group/ employer size -.--.----- Construction Small Medium Large .- .-.. -.-.-...~.._ .- Manufacturing --- Small Medium Number of employers Adjusted Assigned Adjusted respondents universe

weight -~- -------__. 97 22474.18 239,996 ___-- 155 238.95 37,037 ---__ _-__--- -__. -.--~-- 120 3.96 476 -- --__-- ____---

113 1,153.68 130,365 160 462.00 73.919 Large Personal servlces -_. _ --.- -..-_- .-_----.----- --..... .-. Small ---__..-- ---____

-.- _... Medium 173 31A3 5,438
102 2,432.46 248,111 -..-.--~- 128 70.89 9.074 Lame 72 2.20 159 

# Sampling Errors Becausewe surveyed a sample rather than the universe of employers, each reported estimate has an associated sampling error. The sizeof the sampling error reflects the precision of the estimate; the smaller the error, the more precise the estimate. Sampling errors for estimatesfrom this survey were calculated at the 95-percent confidence level. This meansthat the chancesare about 19 out of 20 that the actual number or percentage being estimated falls within the range defined by our estimate, plus or minus the sampling error. For example, if we have estimated that 30 percent of a group has a characteristic and the sampling error is about 6 percentage points, there is a 95-percent chancethat the actual percentage is between 24 and 36. Generally, the sampling errors for employer characteristics did not exceed 9 percentage points at the 95-percent confidence level. However, for the number of employers in certain combined industry and sizestrata (for example, small construction employers) and certain other characteristics, the sampling errors were higher. Sampling errors are stated in given points for employer characteristics, becausethis is generally how the size estimates are presented in the report. (Sampling errors are given in app. IV and V.)

Page 34 GAO/HRD-9%63BR OSHA Hazard Communication StandardAppendix II GAO’s Employer Survey on OSHA’e Hazard Communication Standard: Methodology, Sampling, and Analysis



# Likely Employer ComplianceWith Individual HCS Requirements Using our employer survey data, we defined as in likely compliance employers who said they had received an MSDS~ 

### and did not report being out of compliance with one or more of the three HCS 

### requirements we askedabout7 Thesewere:

. Maintenance of a hard copy or computerized file of MSDSS 

### on most or all of the products that contain hazardous substances (one of the MSDS 

### requirements);

l 

### Provision of training to employeeson the safe handling and useof hazardous chemicals (training requirement);

l 

### Maintenance of container labels that clearly indicate the identity of the substanceand warning of its hazardsfor most or all of the products for which the employer has an MSDS 

### (labeling requirement). We measuredthe extent of any cost increasesexperienced by employers from various aspectsof HCS 

### through a series of questions based on a 6-point scale: not at all, a little, somewhat, moderately, greatly, and very greatly (seeapp. IV). We measuredthe severity of sevenproblems employers may encounter from HCS's 

### training requirement by asking them the extent to which the problems had been encountered at their business: little or no extent, someextent, moderate extent, great extent, very great extent, and don’t know/not applicable (seeapp. IV). 

# GAO Interviews With Chemicaland Drug Distributors In May and June 199 1,to obtain information on the experience of chemical and drug distributors in complying with HCS,GAO 

### conducted interviews with five firms active in either SIC

### 5122 (Drugs, Proprietaries, and Sundries) or 5169 (Chemicals and Allied Products Not Elsewhere Classified). The firms were located in either the Baltimore or Philadelphia area. The five firms differed in the amount of sales,the number of employees, number of distributing facilities, primary products distributed and principal markets of operation. Two of the firms distributed chemicals, and three distributed drugs. Of the latter, two also distributed health and beauty aid products and one manufactured drugs. Interview questions focused around four main issues: (1) the difficulties, if any, the firms have experienced in complying with the MSDS 

### requirements

“About 50 percent of all employers reported that they had receivedno MSDSs. 7Fora discussion of employer noncompliance with HCS,seeGAO/HRD-92-8.

Page 36 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix II GAO’s Employer Survey on OSHA’s Hazard Communication Standard: Methodology, Sampling, and Analysis



### of HCS;

### (2) the Ms~s 

### requirements’ effect on the firms’ costs; (3) the perceived benefits received, if any, from the MSDS 

### requirement; and (4) suggestions for modifying the HCS 

### requirement. 

# Assessmentof OSHA’s To assess the methodology underlying OSHA’S 

### compliance cost estimates 

# Cost Estimate for the MSDS 

### requirements in nonmanufacturing industries, we obtained and analyzeddocumentation from OSHA 

### on its model and general 

# Methodology methodology for estimating the compliance costs of the standard’s MSDS 

### requirements in nonmanufacturing industries. However, becauseof data limitations, we did not judge the accuracy of many of the assumptions (for example, the number of chemical hazards used in the workplace of a typical nonmanufacturing firm or voluntary compliance with HCS)

### made by OSHA 

### in developing its estimates.

Page 36 GAO/HRD-92-63BR OSHA Hazard Communication Standard

j, I’ j,’ I

,. ‘

.

### Appendix III 

# GAOAssessmentof OSHA’sModel for Estimating Compliance CostsWith the MSDS Requirementsof HCS

In November 1983, OSHA 

### published a final Hazard Communication Standard covering manufacturing industries. As part of that regulatory effort, OSHA



### had determined that it was economically feasible for all manufacturing industries to implement the HCS 

### requirements.’ In May 1985, a U.S. Circuit Court of Appeals ordered OSHA to apply HCS



### to nonmanufacturing industries unlessthe Secretary of Labor could state reasonswhy this application would not be feasible.” To provide direct evidence of the economic feasibility of expanding HCS's 

### coverage, OSHA



### commissioned a study with the JACA Corporation to estimate the economic impact of extending OSHA 

### to the 50 major nonmanufacturing industry groups within its jurisdiction. The study included estimates of the costs and the general economic impact of this regulatory revision. From this study and other evidence presented in the record, OSHA



### concluded that extension of HCS 

### to nonmanufacturing industries was economically feasible. Industry groups and government agencies criticized OSM’S 

### conclusion, contending that OSHA’S



### analysis was flawed and greatly underestimated the HCS

### compliance costs of nonmanufacturing employers, especially small employers. Some critics have focused on the material safety data sheet requirements of HCS,

### asserting that it has generated an excessive paperwork burden on employers. After analyzing OSHA’S



### cost estimate methodology concerning these MSDS 

### requirements, we concluded that OSHA’S 

### general approach and the equations comprising its model for estimating the HCS

### compliance costs are fundamentally sound. However, the estimates derived from OSHA’S 

### cost model depend on assumptions made about the values of the model’s variables (such asthe number of hazardous chemicals used in an employer’s workplace). Becauseof data limitations, we did not assessthe a accuracy of most of the numerical values OSHA 

### assumed in its cost calculations. The more realistic the assumptions, the more accurate OSHA’S 

### cost estimates will be. In one case,however, OSHA 

### appears to have understated the compliance costs by excluding nonwage benefit costs such as pensions and health benefits from its wage rate variables.

‘A factor in determining whether a specific standard is economically feasible is its affect on the financial viability of an industry.Industrial Union Department, AFL-CIO v. Hodgson, 499 F 2d 467, 477-78 (D.C. Cir. 1974).

‘United Steelworkers of America v. Auchter, 763 F.2d 728, 739 (3d Cir.1985).

Page 37 GAOEIRD-92-63BR OSHA Hazard Communication StandardAppendix III GAO Assessment of OSHA’e Model for Estimating Compliance Costs With the MSDS Requirement.9 of HCS



# Summaryof OSHXs Cost Model The costs to chemical manufacturers and importers of complying with HCS differ markedly from the costs nonmanufacturing employers would incur when the standard is applied to them. Under HCS, chemical manufacturers and importers must conduct a hazard evaluation-evaluate each chemical they produce or import-to determine if it is hazardous. For chemicals determined to be hazardous, they must prepare an MSDS providing details on the chemical’s properties, hazards, safe use,and handling. In addition, chemical manufacturers and importers must provide MSDSS to employers who use hazardous chemicals. Employers who use hazardous chemicals in the workplace must maintain a current file of MSDSS

and permit workers accessto that file. In nonmanufact,uring industries, most employers likely will use MSDSS received from chemical manufacturers and importers rather than develop their own MSDSS.

However, (1) employers must maintain MSDS files on hazardous chemicals used in the workplace and (2) employers who distribute hazardous chemicals must provide MSDSS to their customers. Thus, a nonmanufacturing employer’s cost of complying with the requirements will depend on the number of chemical hazards present in the employer’s own workplace(s), the number of employers who will require MSDSS, and the unit cost of preparing an MSDS. In its cost model, osm 

### estimatesthat keeping MSDS files current will cost the nation’s nonmanufacturing industries $44.9 million the first year and $84.8 million over 40 years (the latter figure is calculated in terms of total present value-TN--and assumesa lo-percent discount rate). To distribute MSDSS to employeeswill cost nonmanufacturing industries $19.3 the first year and $88.9 (TPV)over 40 years.
OS~ 

### also found that the costs of complying with the MSDS requirements alone were about 10 percent of the total compliance costs of HCS, both during the first year and over a 40-year horizon. (Seetable III. 1).

Page 38 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix III GAO Assessment of OSHA’s Model for Estimating Compliance Costs With the MSDS Requirements of HCS

Table 111.1:

Estlmated Costs of Compliance With HCS to Nonmanufacturlng Industry, OSHA Cost Dollar figures in millions ~---_---~- Model Flrst-year Percent of total HCS requirement cost first- year cost Total P;~;;;:

.--- --________ MSDS: -----__ ___~-- Maintain MSDS files $44.9 6.5% $84.8 --.- .__.... ----- ___-- --.. .- Provide MSDS to customers 19.3 2.8 88.9 ---..___.__. .- ~--- Total $64.2 9.3% $173.7 Labelingb 12.8 1.9 170.9 .____-. --~.. Written programC 137.4 20.0 170.9

--__--~-_ ___- -..--- TrainingC 472.9 68~s~-.-~EE4,!! Total cost of HCS compliance $667.3 100% 1,570.l aAssuming a lo-percent discount rate. bManufacturers and importers must label the container of any hazardous chemicals they ship, and employers who use hazardous chemicals must ensure that each such chemical in the workplace is labeled or otherwise identified.

“Employers using hazardous chemicals must develop a written hazard communication program that describes how they will meet HCS’s requirements and train their employees in the safe handling and use of the chemicals. 

# Basic Equations in OSHA’sCost Model The OSHA 

### cost model for each of the MSDS 

### requirements involves two equations: one to calculate the unit cost, the other to calculate total costs. The total costs for each requirement are calculated by multiplying the unit cost of preparing or maintaining an MSDS 

### by the number of MSDSS. 

### The equations are corrected for the creation of new businesses,the development of new chemicals and their introduction into the workplace, and prior employer compliance with state right-to-know laws. Nonmanufacturing employers are divided into classesbasedon their SIC 

### code and size (number of employees). Total costsare estimated for each SIC/size class.The total cost of compliance with HCS 

### is determined by summing the total costs for each class. The unit costs of both preparing and maintaining an MSDS 

### are calculated by the sameformula: AC=W*T+S Where AC is the unit cost,W is the wage rate of the employee, T is the time required by the employeeto prepare or maintain one MSDS, 

### and Sis the

Page 39 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix III GAO Assessment of OSHA’s Model for Estimating Compliance Costs With the MSDS Requirements of HCS



### cost of supplies usedto prepare or maintain one MSDS." 

### The total annual cost of maintaining MSDSS 

### for each nonmanufacturing size/SIC

### group is: TCm= (AC * N * H) * (1 + G”) * (1 + Gh) * (1 -P) Where TCm

= the total cost of maintaining MSDSS, 

### AC = the unit cost, N = the number of firms in the size/srcclass, H = the number of chemical hazards in a typical firm, G”and Gh= the growth rates of N and H respectively, and P = the proportion of firms voluntarily complying with HCS.4 OSM 

### assumedthat the requirement to ship MSDSS to 

### customers would affect wholesalers of durable and nondurable goods and selected retailerse5 The total annual cost of wholesalers providing MSDSS 

### is defined as: TCP= (AC * M * S) * (1 + G”) * (1 + Gh) * (1 -P) * (1 - Pr) Where TCP

= the total cost of providing MSDSS; 

### AC, G”, Gh,and P are defined above; M = the total number of MSDSS 

### needed by nonmanufacturing firms;” S = the share of total wholesale salesaccounted for by the particular size/SIC class;and Pr = the probability that a firm will buy a hazardous chemical product from a retailer rather than from a wholesaler.

“Data for the wage rate (W), the employer time required (T), andthe supply cost (S) variables were described in OSHA,Final Regulatory Impact and Regulatory Flexibility Analysis of the Hazard Communication Standard,Aug. 9, 1983. 4TheBureau of Labor Statistics furnished the data on the number of firms in eachclass/SICclass,while the number of hazardswasdetermined from the National Occupational Hazard Surveyand National Occupational Exposure Surveys.The other variables (G”, G”, and P) were estimated by the JACA Corporation. 5UnderHCS,wholesalersand distributors must transmit an MSDSwith the initial shipment of a hazardouschemical to all employers. MSDSsneed not betransmitted if, among other provisions, the hazardousproduct shipped is (1) prepackagedfor saleto consumersor (2) sold in solid form for direct ingestion by a patient. This secondexemption includes pills not made into liquid form and/or not crushed or otherwise combined before ingestion. Distributors need not sendan MSDSto retailers who haveinformed them that they do not sell the hazardouschemical to commercial customersor open the sealedcontainer to use it in their own workplace.

“The number of MSDSs(M) wasestimated by the JACACorporation.

Page 40 GAO/BRD-9%63BR OSHA Hazard Communication Standard

.‘! ,I : 1 :. ,, ,.’ ., ‘, .IAppendix III GAO Assessment of OSHA’s Model for Estimating Compliance Costs With the MSDS Requirements of HCS



### The total annual cost of providing MSDSS 

### by retailers is similarly defined by: TCP = (AC * M * S) * (1 + G”) * (1 + Gh) * (1 - P) * Pr The results from OSM’s 

### model depend on the agency’sassumptions concerning the values of the variables (such asthe level of unit costs, number of chemical hazards present in a nonmanufacturing workplace, number of MSDSS



### needed, number of firms, or employee compensation costs). Changesin thesevalueswill changethe calculated total costs7 The more realistic OSM’S 

### estimated numerical valuesfor thesevariables, the more accurate its estimates of compliance costswill be. Becauseof data limitations, GAO 

### cannotjudge the validity of many of OSM’s 

### assumptions underlying the numerical values it used. However, in one casewhere we did make an assessment,OSM 

### likely understated the costs to comply with the MSDS 

### requirements by not including nonwage compensation costs such as pensions and health benefits in the wage rates used in their calculations8

7Forexample, for the model’svoluntary compliance variable, P, OSHAassumedan annual rate of about Z-percent compliance with both MSDSrequirements for all industries and employer sizes,except for employers in wholesaletrade (SIC codegroups 50 and 5l), where OSHAassumeda 60-percent compliance rate for the provision of MSDSs. sCorrecting for nonwagecompliance costswould increasethe estunatedcosts of complying with the MSDSrequirement from $68.7 million to $87.9 million.

Page 41 GAO/HRD-92-63BR OSHA Hazard Communication Standard

### Appendix IV 

# Information on Responses to SelectedGAO SurveyQuestions

This appendix presents response information on selected questions from our survey questionnaire concerning the Hazard Communication Standard. The questions chosen are those relating to issuesdiscussed in this report-including employer compliance difficulties with WCS, 

### aswell asthe costs and benefits of compliance-and used in the figures throughout the text. Unless otherwise specified, information is for those employers appearing to comply with the HCS. 

### The associated sampling error is shown in parentheses after each response. For some of the smaller cells, the error may be quite large. Results with sampling errors greater than or equal to +/-20 percentage points are indicated by **. In some instances, response totals may not equal 100 percent due to rounding. We presented information related to survey questions on employer noncompliance with HCS,OSHA'S 

### outreach efforts, and employer problems with MSDSs



### in our report of November 199 1.l A complete copy of the questionnaire is included in this earlier report.

‘GAO/HHD-92-S.

Page 42 GAO/HRD-9%63BR OSHA Hazard Communication StandardAppendix IV Information on Responses to Selected GAO Survey Questions



### 12. Overall, do you believe that OSHA’S 

### regulation on right to know has had a positive or negative effect on employers?

Industry group/ employer size Constructlon Small
Mechum Large
Total Manufacturing Small
Medium Large
Tolal
Servlces Small
Medium Large
Total
Total Small
Medium Large
Tdtal Y Effect (percent of employers responding) Very Somewhat Equally positive Somewhat Very Don’t positive posltive & negative negative negative None know .-- --- --___..~~-. -~~ __- ___. .-~~

. ** 8%   **  8% 8% ** ~~(+‘

-‘5) ~~_ ..~.....~ ..*_1_ -... -._ ** ** (+/-15) (+/-15)

_____ --..__ -_~~--_._~-._~. 13% 26 28% 18% 8% 3 3 (t /-9) ( + I;1 1) ( + l-2 J)-_ (+/-lo) (+I-7) ( + /-5) (t '-5) .-. _ __.-.__.--~..- .-.- ~-.-... -.- 10 27 29 19 6 3 6 (t/-7) ~(+'-lq ~~~ (+/-IO) (+ '-9) (i-l-5) (-k/-4) (t /-5) ~~~.--_ ~~~ _--- 25 14 19 16 13 6 6 (+/-18) (+'-'~') (t/-J 4) (+/-14) (+I-14) (+/-IO) (t/-IO)

ii --.-~-.__...-~~-. 17 26 9 0 0 22 (+/-16) ( + '- ! 8) ---~A. +!:?LL!Yi!?~-~- ( + '-0) ( + LO) (i-'-17)

_ 14 28 32 14 1 9 2 ~~~(+'-!) (+'-2) (+'-6) (t/-3)

~. ~!+'-g) -~. -..- (+/-lo) --(+/-7) -- 17 45 28 9 0 2 0 (t/-6) ( + '-9) (t '-0) -L!L!L- ~-w:tj)

..._ ____ ...~.~~~-.--_.-~~+/ro) 15 28 30 12 1 5 10 (+'-7) (+-'-9) -_ (j-./-9,. (t/-6) (+'-1) (t/-3) (+'-7)
  **  6 6 0 0 **   (-t/-12) (t/-12) ( + /-0) (.-I'-_o, 23 17 29 17 10 0 4 (t/:12) (+/-lo) _--(-t/-12) (+/-lo) (+/-8) (+ '-0) (t '-5)

__ ._~. 25 25 13 18 0 13 6 a !+'-14) (+.'-14) .- ~~ --_.__A.+'-10) (t/-12) (t '-0) (t/-IO) ( t /-8) 19 **  ** 7 7 0 0 (+'-'8). .~ **. .~. .~ ---~- -2t:.-- (+'-'1)_-(+/-1!_L_-_~(+~~---_!+/-05 __-

-..~---- ___-__--. ..-.I_.. ~~ 22 20 30 10 8 3 8 (+'-12) (+'-I') .~ .----...w2?L-p. (t '-9) (+I-8) (+I-5) (t/-7) 14 27 31 15 3 7 3 (t/-5) (+'-7! ~~~ ~~~~~__ Lk!T~..______.__~~

(+I-6) 

### (t/-2) (+'-4) (t/-23) 16 43 27 10 0 3 1

~~(t-4 (+'-8) .~~-__. Lt!:7_)_--..~~~~ (t/-5) (t/-0.3) (+'-2) (t/0.3) 19 23 30 12 6 4 6 (+I-8) (t l-7) (t/-8) (+/-6) (t '-5) (-t/-3) (+I-4)

Page 43 GAOIHRD-92.63BR OSHA Hazard Communication Standard

I ;“

.‘: ; _. :. ., 5
,’ ,Appendix IV Infomatlon on Responses to Selected GAO Survey Questions



### Overall, do you believe that OSHA’S 

### regulation on right to know has had a positive or negative effect on employees?

Industry group/ employer size Effect (percent of employers responding) Somewhat Don’t positlve Equally positive Somewhat

81 negative negative Very negative None know -.-..-- ____.. .~- Constructlon Small
Medium Large
Total Manufacturing Small
Medium Large
Total
Services Small'
Medium Large
Total '
Total’ Small'
Medium Large'
Total 

# -_____. .-. _____---___-...-.~-~~   **  8% 8% ** 8%   **  (+/-15) (+/-15) ** (+/-15) --- 15% 30% 25% 8 3 13% 7 ( + /-9) (+/-12) (+/-II) ( + l-7) ( -_--- + ~-5LlY!l!$ _... --_!~t-/!?) 9 39 22 9 3 9 9 J+ i-6,. 

# !+/-“I ( + M) (+/-9) 

# .-----(+/-6)~-.-(+/:4~---~ (+/-6) 

# -_ -.- ~~~ 26 20 18 8 6 15 7 (+/-18) t+/-lp) (+/-11) (+/-lo) (+/-14) (+/-IO) .~ ~. (+ l-1 4]... __~~~ ~--._... ~~~~~ 17 30 17 9 0 0 26 !-km? _c+/-!P! (+/-'Q (+/-12) (+ /-0) ( + /-0) (+/-IQ

__ ~_~ 

# . .---.._~- ____ 16 27 30 5 0 17 5 (+/-8)~. ..~(+!-91 .~~~pm_mm(+/-'O) (+/-4) (+ /-0) (+/-8) (+/-4) 22 47 19 5 1 5 2 ( +/-!I ..( +t9L ..~. (+/-7) (+/-4) (+/-2) (+I-4) (+/-2) -~______-.~ -.--. 17 29 25 6 0 10 13 ~(~+/-7) J+/.-?) ~~~~~~~~ (+I-8) (+ /-5) (+/al) (+/-5) (+/-7)
  **  0 6 6 13 **   (+/-0) (+/-12) (i-/-12) .-.__ (+/-17) 26 18 29 10 4 8 6 (+/-121 

# ~~~~

~~~ ~.~ .. ~~~ ~~~~~ .. ---- (+/-II) (+/-13) _..~ (+!I!) ..____ (+/-5L LIE! __.--ems!) 19 41 9 13 0 13 6 (+/-1_2). .- (+./-I:) ~~ -~~.- -- ~~ -____--___ ~~_~~ ___ (+ /-9) (+/-lo) ( + LO)

_ (+/-lo) ( +/-8, 19 **  ** 1 6 6 12 (+-l-18)   (+/-1) (+/-11) (-b/-11) (+/-15)

23 ..-.. ._~._. .--____--.-___ 22 22 5 5 8 15 (+/-12) (+/-12) (+/-12) (+I-6) (+/-7) (+I-8) (+/-IO) 'I7 27 29 6 1 16 5 (+/-!3 (+/-7) (+/-7) (-k/-4) (t/-l) (+I-6) (+I-3) -~~-- _~~ ~~~~ _ ..___ ~~ __---_ .___-.- 21 47 19 5 1 5 2 I (?!:6) (+/-2) ~.~ ..!.+e?.. _~.-. ..~ ~~-._!+/Is)___--~-~..--~~~~.~_. (+/-3) (+/-l) (+/-3) 20 25 25 5 4 11 11 (+/-8) (+/-8) (+/-8) (+-14) (+/-4) (+/-6) (t l-6)

Page 44 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix IV Information on Responses to Selected GAO Suwey Questions



### 13. Listed below are things that might or might not be improved asa result of the regulation. In your opinion, to what degree, if at all, hasthe regulation improved each of the following?

Degree of improvement (percent of employers responding) Very great Great Moderate Somewhat Slight None -_--_-__--- ___--.. Aspect of workplace Quality of your employees’ formal/on-the-job training in avoiding (+E, 30% 28% 15% 11% 11% workplace hazards ( + /-9) ( + l-8) (+ l-6) ( + /-6) (+/-6) ~. --~-..___-__. -~--._ ___---____ Your employees’ awareness of workplace hazards (+/-:) (+;Z, (+Egs, (+;-:, (+:-:I ( .+/-85) ----__ Your employees’ care in handling and use of hazardous subslances (+,-ii (+Z, ,+,T:, (+E, (+I-:, (+;;, Availability of information on hazardous substances in your __.-- -__ ____. ~--- workplace (+::I r (+;I;, (+fE, (+;A, (+I-:) (+I-46) Your management’s awareness of workplace hazards -.-----..~ W-Z) (+I-:,

Page 45 GAOiHRD-92-63BR OSHA Hazard Communication StandardAppendix N Information on Responses to Selected GAO Survey Questions



### 14. Consider waysthe regulation on right to know has affected your business:To what extent, if any, 

### haveyour clerical costs due to the regulation’s paperwork requirements increased?

Industry group/ Extent of increase (percent of employers responding) employer size None Little Somewhat Moderate Great Very great Constru~tlon -.--~- .-___ _--.._-

-.~_...... -.-----.-^-.--.-_--------..-.._-~~~-. .--. Small 8% **  8% ** ** 8% (+/-I51 **
- . -...-..-- -_.. --. (t/-15)   ..___-- (+/:J:)

___.~.....___.. Medium IO 15% 22 27% 20% 7 (+/-8) ( + /-9) (+/-11) (+/-11) (-t/-6)

. -..--- .--..

-..---_---...-__~ .. .-~.-- ..--~~.- ---..- (@/-I 0) Large 3 15 15 40 21 7

~__ (+/-4) ( + /-8) ( + /-8) (+/-II) ( + /-9, (+/-6) ..- _-----.---.~. ._......__~-- ..--__- .-.---- .._~- _~_-.__-...-.-_-.-_-~.--..~.-. -~ - ~- Total 8 31 12 24 17 7 ( ++j 1) (+/-19) (+/-II) (+/-17) (+/-I41 ~~_ --._.___- ..__ .--.... (+/-11) Manufacturing ..-._~ --.. ~_~~~. --. __.--- Small 22 13 26 30 9 0 (+/-17) .-.( + Mp) _(+/-I81 (+I-191 (+/-12) ( + /-0) __-----...---..- _-.. _..~~~~ ..- ~~.. -~~~~ Medium 9 24 21 29 11 6 (+/-9) ( + /-9) -__I+ /-9, (t/-10) (+/-lo, ( + /-5) Large 5 19 21 30 19 6 (L-b P) .___ _...........

A?/-71 ..~_~ ...~~

~~~... (+/-7) ( + /-8) (+/-7) (-b/-4) ~~ . Total 14 19 23 30 10 4 (+I-71 (+/-7) (+ t-8) (+A9) (+I-6) (+I-3)
_.._._____ ~~~-

_..._....__ ~~.-.--~----~ Services Smail **  ** 13 ** 13 0   (t/-17) **  (+/-17) ( + l-0) Medium 13 23 27 23 13 2 (+ /-9).-m.. (+/-12) (+/-13) (+/-12) (+/-?! mp!+/.-?) .-~-. Large 9 41 19 13 19 0 a ( + /-9) Total' (+/-15) (+/-12) (+/-IO) ** 19 14 -- _ 19 -_-I? !Z) 13

. ._~~ _~-~--I!-

m 0 ** (+/-18) (t/-15, (f/-18) (+/-15) (+/-0.3) _.-.. _~___..

.--.~~~ ~._....____~~~... ~~-- --~... _--~-~ ~~~~~~---.-.~~~~ .- Total Smail 23 24 15 23 12 3 (+/-12) (+/-13) (+I-61 (+/-I21 Medi'um (-t/-l!) ._(+/-5) 10 21 22 28 13 6 (.$-/-5) ( +/bz) __-.-- ..... (+/-7) .._ (+/-7) (+I-51 Large __--.- (.+I-41 5 19 20 31 19 6 I (+/-13) (+/-6) (+/-7) (+I-7) (+/-6) Total ..J + I-4) 18 23 17 25 13 4 ( + l-8) (+/-8) (+/-6) (+/-8) (+/-6) (+/-3)

Page 46 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix IV Information on Rerponses to Selected C3AO Survey Questions



### To what extent, if any, haveyour overhead costs due to storing and maintaining information on hazardous substancesincreased? -

Industry group/ employer size Cdnstructlon Small
Medium Large
Total Manufacturlng~ Small
Medium Large
Total Extent of Increase (percent of employers responding) None Llttle Somewhat Moderate Great Very great

0% ** 8% ** 8% 8% ( -y-O). .~~~~~

.._... ** (+A15) ** (+/-15) (+/-15) -.---__ 8 26% 31 16% 15 3 (t/-7) (+/-4) (+/-12) (t /-9) (+/-5) ~~~~- -. _~--.. ....~._~~

- --- ( + /-q 10 15 14 35 12 4 (t/:7) ~~~__~_~~~~~~_~_~~,~~__ __ ---_--_ (+/-8) ( + l-9) (+/-ll) (+/-7) ( + /-5) 3 ** 15 26 10 6 ( +4 ** (+/-11) (+/-18) (+/-lo)

-.___...._ ~~. ..___.... ~_ (t/-11) _-..--. .-.- ~22---~~- --_ ~~-- ~~~9 -~.- -----.tt-.- _--.--~.. ..-.. 17 9 0 (+/-'7!. (+!I!?!

.--.-p--_"*--- (+/-16) (t/-12) (t LO)

.- - ~_~ _______---_-. 14 27 22 28 2 6 (-+!:7)~-_._ -.-~~ ( + /-9) (+ /-9)

.- t+/-1g (+/-3) (+/-5) 9 22 21 30 14 4 i+/-:). (+/-7) (t/-7) (t /-8) (t/-6) (+/-3)

_~~ ~. ~~~ ---- ~~

-_-__- ..------- .-.-.-- . -__ 17 20 30 24 5 4
Set&es Small
Medium Large
Total
Total Small
Medium .!+I4 ~~ _~ .~.~P/:7) _~~ ~~--k!Y%~-. (t/-8) (t/-5) (t/-3) --

- .-... ..~~ ._~~~~~~..

_.__ -- ..~_~-_._~~~-___-- .___ ** 13 0 ** 13 0 ** (t/-17) ** (+/-17) ( + LO) 17. J-t /-0) -.... ~-- - 30 19 23 9 2 (+/.-jl) ~~ ~_~. -. _~~~_ -_~~~ (+/-13) (+/-Ii) (+/-12) (t /-8) (+/-4)

.~~__ ___.__ ________ --..--..-__.- 13 28 31 19 9 0 (+/-lo) (+/-14) (H+j>l (+ /-Ia --.+!zL-.

_____ -w?) 6

l * 14 2 ** 12 1 ** (t-/-151_

... _--- (t/-l) ** (+/-15) (+/-0.3) ____-....- ._____-____-.__..-- -.. .- 18 23 14 32 10 3 (+/-lo) (+/-12) (t/-8) (i-/-14) (t /-9) -.__. (t /q 13 27 24 25 6 5 ( + 4 ~.

~- . ~-~~-kk!:!2 __~-

....._~-r+/-.!)___.~~-~-_-~3~.~-._(_+_/-4) 9 22 21 31 13 4
+. ( + /-5) (t/-7) (+/-7) (+/-7) (+/-6) (t /-3)

16 24 18 30 9 4 (+/-7) ( + /-8) (t /-5) (+/-9) (+I-6) (t /-3)

Page 47 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix IV Information on Reeponueeto Selected GAO Survey Questions



### To what extent, if any, haveyour overhead costs due to developing a written training document increased?

. .. Industry group/ Extent of increase (percent of employers responding) employer size None Little Somewhat Moderate Great Consttvctlon Very Great -________ __---. ____---- Small   9% **  ** 0%   (+/-18) **  ** -~.--._.. ~-.----_._- ._..._

-._._.__ -._.______ ___ ( + /-0) Medium 5% 10% 25 37% 17% 5 j '- /-cj, ._ -.-_

_- (t/-8) (+/-lo) (+/-12) (+/-IO) (+I-5) ---l_-_l--- Large 4 13 28 34 16 4 .(+/-y (+I-8) (+/-lo) (+/-1O) __-.__ct/-8) (+/-2) -~-.-_ Total 14 15 15 ** 18 2 bkjnufacturjgg- ($1-15)

_ (+/-16) ** (t/-12) (+/-lo) (+ /-2)

-_____.___ _ Small 13 22 17 ** 9 4
Medium ..J+np, __._. (+/-17) (+/-16) ** (+/-12) ( + /-9) -___----.------ 7 14 33 27 13 5 Large (+/-6) (+/;8) (+/-lo) (+/-lo) (+/-7) (+/-5) 3 17 33 33 10 4
Totil __ -_(+/-3) (+I-7) (+/-8) ( + i-8) ___-. (+ d-5) (+I-3)

__________ __-_I____ 9 17 27 31 11 5
Seivlces ._(+I+)_ (+/-8) (+I-8) ( + /-9) (+/-6) (+/-4) ___._~____._ smalls .'. ___-----   6 **  13 0 **   Medium- -. (+/-12) (+/-17) ( + /-0) I_______ ---I__.--- 10 25 23 17 23 2

_..._j-//:) (+/-12) (+/-12) (+/-I 1) (+/-12) t+/-4) -__I_ Large 13 28 16 38 6 0
iota1 ....,... (+ 1-J 0) (+/-14)

___ (+/-11) **  ** 8 ** iI* (+/-11)

-- Total Wall 20 25 10
Medi"m. (+/-12)

~-- .._ .~..~~.._ .

..__ __._.,_____...__... (+/-13) ( + /-9) 7 14 31

-.. Large .--.- --_m_.-( + /-4) (+I-6) (+I-8) 4 17 32 1 -Gal ___- -(+/-3) (+I-6) (+I-8) -- .._

-. ___..__ ____ 14 21 18 (+/-8) (+I-8) (+/-6) (+/-15) -~---.__(+/-6) (+/-0) l -.--. -. ** 13 0 ** (+/-15) (+/-0.3) ..-___ .--___-

----- -_- _... -.-. 31 13 1 (+/-14) (+/-lo) ( + /-2) 29 15 5 (+I-7) ( + /-6) (+/-3)

-- --_ _I_--.- 33 10 4 (+I-8) (+/-5) (+/-3)

-- 31 14 3 ( + l-9) (+/-7) (+/-2)

Page 48 GAOiHRD-92-63BR OSHA Hazard Communication Standard

..I 7, ‘

. /Appendix N Information on Responses to Selected GAO Survey Questions



### To what extent, if any, haveyour overhead costs due to following the regulation’s labeling reauirements increased?

Industry group/ Extent of increase (percent of employers responding) employer size None Little Somewhat Moderate Great Very great ~~@&~tlon .-- - Small

.’ ~. ~~~~~ .. . ~~.. .~.- --.... --~~-..--------.~.--.--_-__-. --   8% **  8% 8% ** ** (+/-15) ** (+/-15) (+/-15) -___--_---~-.. Medium 10% 19% 27 29% 12 3 -.(t /-q _--.-__-__ _- -.-

(+/-IO (+/-11) (+/-12)

_ (+W (+I-5)
___._ Large 15 16 22 22 24 2 ( + /-9) iotai !!I!?L 14 .- .._ --._-.wrll)_..

27 14 ( + /-9) ( + /-9) (+I-3) ___-.-__--__---- 30 9 --..-..- 6 - (+/-14) (+/-18) (+/-II) (+/-I@ (+/-11) (+/-IO) @akufacturlng ~.- .__- Small 13 17 ** 22 13 0 (+/-14) (+/-16) ** (+I-17) (+/-14) ( + l-0) Me&urn __-----____.--- _____- 9 18 31 26 12 5 (+/-6) (+I-8) (+/-IO) ( + /-9) (+/-7) (+I-5) Large .__-__ _______ ~.. 5 19 20 39 14 3 (+/-8) (t/-6) (t/-3) (t /-!J. _.!? !:Ll-_ (t-/-7) .._--. ._. ..__ _. __. .- Total 11 18 32 25 12 3
SerVices (.+E! ._.. .I~+@- _... .._ ( +/-9). (+/-8) (t/-7) (+I-3) __- -.._

---._..--__ ___.--- SAall ** 7 ** 13 13 0 ** (t/-13) ** (t/-18) ..-(t/-18) (+ /-0) __---_ .-- Medium 19 21 29 !+!-.I!) -~+l:X-._ (t/-13) (Ai, 17 2 (i-/-II) (i-l-4) ._- ~.-.__--. ---______ Large 10 42 26 19 3 0 6 (t l-9) (i-L-16) (t/-14) (+/-13) (t/-16) ( + /-0) Total ** 8 21 13 14 0 ** (+A12) (+/-19) (t/-16) (t/-16) (t bO.4) Total --___ --I-.--.---- -- Small 27 18 20 22 11 3 (+/-13) (-k/-II) (-f/-11).- (+/-12) ( + l-9) (+I-5) ---_--__ _----__- Medium IO 18 30 26 12 4 (+I-5) (_t@) _____._.._ (+A7) (t/-7) (-t/-5) (i-l-3) ia;ge _...._ ---__ 6 19 20 38 14 3 Y
Toit .~ . (~j- /d) (t/-6) (+/-8) (t/-3)

(+/-6)
___.. .- 20 _~_...._.~. . ..._ _ 18 24 (+/-6) 24 12 3 (t /-8) (+/-7) (+I-7) (+I-8) (t /-6) (t/-3)

Page 49 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix N Information on Responses to Selected GAG Survey Queetlons



### To what extent, if any, haveyour equipment costs due to the purchase of additional safety equipment increased?

Industry group/ Extent of increase (percent of employers responding) employer size None Little Somewhat konst&tioA -- .._ ..- ..._.........__ --_ -.- _ Moderate Great Very great -__ small .- -.____ -----.._ ** 8% 8% ** 8% 0% ** (+/-16) (+/-16) ** (+/-lo) ( + LO) __- Medium 18% 26 16 30% 7 3

...-J+/-IO) (+/-11) ( + /-9) (+/-12) (+/-6) (+I-5) Large. ____-. ____ - ___-.-- ..-- 19 24 29 21 6 2 ( + l-9) ( + /-9) (+/-IO) iolal ~. -_..----. ---.--.-__--.---~~.--

_. .^_. 28 14 11 ( +/-9) (+I-5) J++?) ** 8 1

.._-_ ( + l-1 9) (+/-II) (+/-II) ** (+/-II) (+-/-I) Manufacturing

_______ - ._..._ --.-.--.-.

~ - ______ _.._ -.--.-.-.-. -.-- Small 17 17 26 22 17 0 _(+/-16) (_+/;.16)- (t/-18) (+/-16) (+/-14) ( + /-0) --- --___. Medium 19 23 21 24 8 5 (+I-8) ( + i-9) ( + /-9) ( + /-9) (+/-6) ( + l-5) Large. -. .._ -...------...-._.--_.--.---.-. -.._I_---------__ -.~-.I_ 10 18 29 30 14 1

(+I-7) (+/-a) (+/-8) (+/-6) (+I-2) Toial ( + (-5) .-_______- --.. 18 20 24 23 12 3 (+/-8) Se/vices _(+/-a) ( + l-9) (+/-8) (+/-7) (+/-3) ~..- ____--__. S&all ___-.-__--- -.   **  13 ** 13   **  (+/-17) ** (+/-17) Medium __-__ 17 15 17 27 19 6 i.a;ge .-- _(+/-I 1) (+/-IO) (+/-11) (+/-13) (+/-11) (+I-7) 13 28 19 34 6 0 a

----. J.+/-10) (+/-11) (+/-12) (+/-15) (+/-la) ( + l-0) Toial __- __--. --____- 19 ** 1 14 ** 12 (+/-18) ** (+/-I) Tatal. ___- (+/-15) ~_.**~----~~-i+/-E)
SrtAall .~ ..- .._-_ . ..__ _.___. -_____-_c.-- --.- 23 20 10 24 18 5 (+/-13) (+/-11) (+A12) (+/-12) (+/-ll) (+I-7) Medium ..~ _.. --.-. _--_- ___

-_..-_..--I_..-.._-_-.-~..----_--.-_ ___- __--- 19 23 20 26 9 5 (+A7) (+/-7) (+I-4) (+I-3) Large ---~ __ ( +/-6)

_ _--_ (+I-7) 10 18 29 _~---___ 29 13 1 " (+/-5) (+I-6) (+/-7) (+/-7) ( Tdtal _____- + k!! __..___ m.-+!L., 21 21 14 25 14 4 (+/-a) (+/-8) (+I-5) (+/-8) (+/-7) (+/-4)

Page 50 GAOMRD-92-63BR OSHA Hazard Communication StandardAppendix lV Information on Responses to Selected GAO Survey Questions



### To what extent, if any, haveyour employeetraining costs due to the regulation’s training requirements increased?

industry group/ Extent of Increase (percent of employers responding) employer size None Little Somewhat Moderate Great
._ Very great

_ _ .-_ Constructlon &nail 0%   **  0% 0% (+/-0) **   (+ LO) (+/-0) Medium __-____ 12 18%. 26% 28% 10 3 (+I-8) (+/-IO) (+/-II) (+/-II) (+/-8) .- . . . -- --...-.-..-__- ~- .- ( -t /-5) Large 3 12 19 33 18 15 (+I-4) (+/-7) ( + /-9) (+/-IO) (+ /-9) (+I-8) iotili -- ..-._.. ...-.. -. -- _-._ - -- 4 22 30 **  3 1

(t/-17) (t/-18) ** (t /-2) (+/-1) ijaAufacti;ing -.,-- (+ /-3)

---.- Small 17 22 22 17 22 0 (+/-16) (-t/-17) (+/-17) (+/-16) (t/-17) ( + /-0) Medium- -. --.- _- -- 10 23 23 27 13 5

___ (+/-6) (t /-9) (+ /-9) (i-/-IO) (+/-I) (+/-5) -- Large 0 14 28 34 19 5

__ _&j-O, (t/-8) ( + /-8) (t/-8) (+/-7) (t /-4) Total __- 12 22 23 24 17 3

~_ (t/-7) (t/-8) (+/-8) (+/-8) (+I-8) (i-l-3) SeAicis ~ ---- Small   0 **  6 0 ** ** ( + LO) ** (t/-12) (t LO)

-- ___--_____ Medium 17 17 23 35 8 0 (+/-11) (t/-II) (t/-12) (t/-14) (+/-8) i&ge-. (+/I_) 6 31 19 31 13 0 (t/-8) (t/-15) (i-/-12) (t/-15) (+/-IO) (+/-0) * Total .. _.-...- ___-___- ** ** 2 **-- 6 0   (t/-l) **  (i-/-12) ( + LO) Total

~ .--- __- __..----

--. -- -.___ __.--____ .--.-___- ..- Small 17 29 16 30 8 0 (-b/-10) (+/-14) (+/-lo) (+/-13)

_ (+/-7) ( + l-0) Mkdium -. 11 21 I__- 24 28 12 --.--. 4

--- (+/-5) (+/-7) (t/-7) (+/-7) (+/-5) (+/-3) LIarbe -.-__ -_ 0 15 27 34 19 5 (+/-0.3) (+/-6) (-b/-7) (t/-8) (t/-6) (+/-3) Total .' ~-. --_-.- 26- -- 19 ___.- 14 29 -.----__- 10 2 (+/-7) ( + /-9) (+/-7) (+ /-9) (+I-5) (i-/-l)

Page 51 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix Iv Information on Response6 to Selected GAO Survey Questions



### 15.As a result of the regulation, to what extent, if any, has each of the following increased or decreasedin your business?

Aspect of workplace Morale (management)
Morale (employee) Productivity (employee). Workplace-related injuries (employee) Extent of change (percent of employers) Greatly Somewhat About Somewhat Greatly increased Increased the same decreased decreased __I____-.. 6% 11% 74% 9% 1% (+/-5) ( + /-6) ( + l-9) ( + /-5) (+/-1) -- 7 11 76 5 0

( + /-5) (+ /-8) ( + /-5) _-_ J+kg)

_ ( +/:J, 4 4 83 8 2 (+/-4) ( + /-4) ( + l-7) (t /-5) ( + /-3) ---- __I.__ 0 1 82 11 6 Workplace-related illnesses-(employee) __ .pJ-g -. (t-/-l) (t /-7) ( + i-5) (t /-5)

__--_ _-..__--

~_ __.--.____ ___-._-._---.~ 0 1 84 9 6 (+ l-0) (+/-I) (t l-7) (t l-5) (t l-5)


### 2 1.When your businessreceives products containing hazardous substances,or substancesyou believe to be hazardous, how often is the MSDS 

### with the initial shipment, with every subsequent shipment, received whenever a manufacturer updates the MSDS, 

### and/or received after you request the MSDS 

### from the manufacturer or distributor?

$&tlons of recent
With the initial shipment
With every subsequent shipment Received whenever a manufacturer updates the MSDS Received after the MSDS .is All or almost all of the time 40% ( + /-9) (+?,
(2, Frequency (percent of employers responding) None or

Most of Half of the the time tlme Some o:iz almost none Don’t of the time know 28% 10% 4% l

~~ (+!;8)- i+E G!!, .____ -T.-.w!l-.~- .___ -!.A!3

~~~ .J$;, __- (t/-i, (+;:I (+;i, (t/-i, -__ _____~.

-_-_--.---_ -._~-~ .-... (+ZZ, ,+;;, (+:-ii, (+;;I

_ -- pH/:, requested lrom the manufacturer or distributor

Page 52 GAO/HRD-9%63BR OSHA Hazard Communication StandardAppendix IV InformaCionon Responses to Selected GAO Survey Questions



### 23. For all the MSDSS



### you have received, how easyor difficult are they for you to maintain and keep up to date and to ensure employee accessto them at eachworksite?

Requirement Maintain MS&s and keep up to date

_ ~~~~~

_...._.._ Ensure empl&ee-access to them at each worksite Frequency (percent of employers responding) Very Somewhat Neither easY Somewhat easy easy nor difficu t difficult dlff::u t 7 -___--- 24% 24% 28% 16% (+I-8) ( + /-8) ( + l-8) ( + /-6) ( +E, ~~ __ (+Ei, (+2,


### 25. At your business, haveyou ever replaced a more hazardous substance with a less hazardous substance becauseof information received from a MSDS?

Industry group/ employer size ------ Construction Small

___..__ Medium Large
Total Manufacturing Small

_~~ ~--___- Medium Large
Total Percent of employers responding Yes No -- -----__ --

** l *

** **

--___ 20% 80% (+/-IO) (+/-lo) - -____

40 60 (+/-11) (+/-11) --- 26 ____--- 74 ( + /-8) (+/-8) 6 ________._____-----..~..-~

29 71 (+/-19) (+/-19) - ---_____-. __ 38 62 (+/-lo) (+/-lo) 70 30 (+/-8) ( + I-8)
___.. ___--

37 64 (+/-17) (+I-17) --- (continued)

Page 53 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix IV Information on Responses to Selected 

### GAO Survey Queetions

Industry group/ employer size -_- Services Small ---_-__--- Percent of employers respondlng Yes No

-- ~.._   **  ** Medium 38 62 (+A13) -.--____ --.-- --__~- __II_- ( + /-fg Large 58 42 (+/-16) (+/-16) -____- ..._

-.--.--- ___-- Total 21 80 ( + l-9) ( + I-9)
Small 25 75 (+/-12) (+/-12) _._-_..__---._ __-___ ~---~_l_~-_. Medium 34 66 (+/-7) (+/-7) ---------- .~-.-~-- .---____ ___-__. --___-- -- Large 68 32 (+/-7) (+/-7) -._ -- - --- __I--. Total 29 71

‘(+/-8) (+/-a)


### 26. Listed below are reasonswhy a businessmight not replace a more hazardous substancefor a lesshazardous substance.Which is the primary reason why your firm does not replace its hazardous substances?

Reason for not replacing hazardous substance (percent of Industry group/ employers responding) employer size (1) (2) (3) (4) _.I__-_~_--__-~---__-~- ._.. ~__ (5) Construction

__________ -.--..-~- Small 7%   7% **  ’ (+/-14) ** ** (+/-14) ** -__ Medium 7 51% 26% 3 13% ( + /-6) (+/-13) (+/-11) ( + /-5) ( + /-9) __.---_-__-._- ._.._

~...~_ _-..~-.-.___ __ ------ -.-- ___ ..~ Large 5 39 33 6 17 ( +m l_--l_-_

(+/-11) (+A11) ( + /-6) (+I-7) --. Total 7 40 28 6 19 (+/-lo) (+/-19) (+/-‘fa ______~ ( -t l-9) (+/-16) (continued)

Page 84 GAO/HRD-92-03BR OSHA Hazard Communication StandardAppendix Iv Information on Responses to Selected GAO Survey Questions

Reason for not replacing hazardous substance (percent of Industry group/ employers responding) employer size -_-----.-.--.-- (1) (2) (3) (4) (5)

_____ ---- Manufacturing --- ---- --__.-----. --- Small 0 30 ** 13 17 (+ /-0) (+/-19) ** (+/-14) (+/-16) __--- Medium 2 35 48 4 12 (+/-3) (+/-lo) (+/-II) ( + l-4) (+/-7) .~ Large 3 34 50 6 7 ( + l-3) (+I-8) ( + l-9) ( + l-4) ( + l-4) .___--_-- _-.. Total 2 33 45 7 14 ( + l-2) (+ /-9) (+/-IO) ( + /-6) (+/-7)

~-________--- Services ~--- __-~ Small 0   7 13 (+/-0) **  ** (+/-13) (+/-18) -___.. Medium 6 43 33 6 12 (+I-7) (+/-14) (+/-13) ( + /-7) ( + /-9) .___-.- -. Large 3 42 36 3 16 ( + l-6) (+/-16) (+/-15) (+ /-6) (+/-12)

____ Total 1   7 13 (+/-1) **  ** (+/-12) (t/-17) Total -.___-_____ -~ Small 3 31 41 9 17 (+ -/5) (+/-I41 (+/-14) ( + /-8) (+A11) Medium 4 39 41 4 12 ( + l-3) (+ /-8) (+/-8) ( + /-3) ( + /-5) Large 3 35 49- 6 8 ( + /-3) ( + /-8) ( + l-8) ( + /-4) ( + /-4) --_ -..____-____-__ -. Total 3 34 41 7 15 (+ /-3) ( + /-9) ( + l-9) (+I-5) (+I-71 Legend a (1) Can’t determine from the MSDS how hazardous the substance is (2) Don’t know whether or not a replacement exists (3) No replacement exists (4) Replacement costs are too high (5) Other (Please specify)

Page 55 GAO/HRD-92-63BR OSHA Hazard Communication StandardAppendix Iv Information on Responses to Selected GAO Survey Questions



### 29. Listed below are problems that might be encountered by a business in providing training to employeeson the safe useand handling of hazardous substances.To what extent, if any, do you believethese problems have been encountered at your business?

Extent of problem (percent of employers responding) Little Problem or/none Some Moderate Great Very

..~. IAuilicienl expertise in -..---.- .. -.--_.--___-.---- 24% great 38% 22% training

_... (+ /-w ( + /-8)

_ ..~ (+ /-7) (+Z, (+;I$ .-- .____I___ High employee turnover or transfer (+;:I (+;;I (+i-E, (+;;I --_-.-_--.__-- p/-i, MSDSs too difficult to use in the training program (+E, (+;E, &ploye& located at more (+EY) (+I-!) (+/-Z) - .-__ ------ than one work site (+/E, (+;i, (+/-Z) (+/-:I (+/-El E&ployees having variable --. work schedules (+Z, (+/-:I

-...-- ~-~.-~-.--._- _____.._____ ___I_______ High cost of training (+i-zi, (+I:) (+I-:) (+Z, Don’t know/ not applicable

( +E) -- ( + ;:I (+/:;I (+PY, -.. (+:-:I

Page 66 GAOEIRD-92-63BR OSHA Hazard Communication StandardAppendlx IV Inf’ormetlon on Responses to Selected GAO Survey Questions



### 30. How useful, if at all, would the following be in training your employees on the safe useand handling of hazardous substances?

Degree of usefulness (percent of employers respondlng) Type of tralnlng assistance More detailed lab&on hazardous product MSDSs or similar information on hazardous substances that are easy to understand

..” .._ .-- -- ..__ - ~ More specific pamphlets or written materials targeted to the hazardous substances used in your workplace Training videos targeted to the hazardous substances used in your industry Extrlrey$ Very useful Moder;w;,i
23% 23% 23% (+I-8) (+/-8) ( + I-8)

(,13& (CE, (+;i, __~ -~__-- (+E, (1-E) ,+;-;,
(+I-:, Not wee; Not applicable

.- 11% (+/6) (+:;,

(+/-.Oi) (+/-:I --.-.-.

d ( + /-:,

,+;-;, (+I-&

Page 57 GAO/HRD-92-63BR OSHA Hazard Communication Standard

### Appendix V 

# Data Supporting F’iguresin Appendix I

Table V.l: Data For Figure 1.4 Percent of emymyerr ;;it fewer than 20 P Y 1 2 3 4 5 Maintaining current MSDS file 26% --- 24% 30% 13% 7% ___- Assuring employees file access 37 21 24 11 7 Note: Sampling errors range from +/-I4 percentage points for small employers finding it very easy to assure employees access to MSDSs to +/-7 percentage points for those small employers who find it very difficult to maintain a current MSDS file

Table V.2: Data for Figure 1.5 . _ Percent of employers who found requirement somewhat/very dlfflcult

1 2 3 Maintaining current MSDS file Assuring employees file access 20% 27% 50% _- -I-- 18 20 30 Note: Sampling errors range from +/-12 percentage points for employers with fewer than 20 employees who find it somewhat/very difficult to maintain a current MSDS file to +/-6 percentage points for employers with 20 to 499 employees who found it somewhat/very difficult to assure employees access to MSDSs.

Table V.3: Data For Figure 1.7 Percent of small employers who had problems providing HCS-required tralnlng 1 2 3 4 5 ___l_-- --- Insufficient training expertise 46% 23% 21% 8% 3% -- _.-.- -.- ...-

_-- _I_- I__--- -- -__- Employee turnover 55 18 7 17 3 -...--.-.~.----.--_-_~--.---.- __- --I___ MSDSs too difficult to use 47 25 17 9 3

-_.- -__.-..--__--.-__ Employees at multiple worksites 65 11 2 11 G -..~ .---.--...~~_.- - --__ _I- -. Employees with variable work schedules 73 3 12 8 4 High training expenses 64 12 13 10 1 1, Note: Sampling errors range from +/-15 percentage points for employers with fewer than 20 employees who had problems with insufficient training expertise, employee turnover, and using MSDSs in training to little or no extent; to -t-/-3 percentage points for those who found employees at multiple worksites a problem to a moderate extent or high training expenses to a great extent. In this table and others, response totals may not equal 100 percent due to rounding.

Page 58 GAOMRD-9%03BR OSHA Hazard Communication StandardAppendix V Data Supporting Figures in Appendtx I

Table V.4: Data for Figure 1.8

___- Insufficient training expertise Employee turnover _--.- _.--..

-.---.--- -...--.-.- MSDSs too difficult to use Percent of employers who had problems prov;N# HCS-required

g 1 2 3 --- 54% 67% 56% ---- 45 66 60 54 76 73 Employees at multiple worksites 35 42 54 __--.- Employees with variable work schedules 27 45 63

-__ ___--- - High training expenses 37 53 53 Note: Sampling errors rangefrom t/-15 percentage points for employerswith fewer than 20 employees who had problems with insufficient training expertise, employee turnover, and using MSDSs in training to little or no extent; to t /-7 percentage points for those medium-size or large employers who had difficulty using MSDSs in their training programs.

Table V.5: Data for Figure 1.10 Percent of small employers who had cost Increases Paperwork/clerical MSDS storage _~~.._~. .~~ Written program development Labeling Employee training 1 2 3 47% 30% 15% 41 47 12

___ -... 44 41 14

__~~---~ 45 42 14

..- 46. 46 8 Note: Sampling errors range from t/-15 percentage points for small employers who experienced little or no increase in labeling requirement costs to +/-7 percentage points for small employers who experienced a great or very great increase from increased employee training costs

Table V.6: Data for Figure 1.11

.____-...__ Paperwork/clerical MSDS storage --~- ..- -- Written development program Labeling Emolovee trainina Percent of employers who had cost Increases 4 1 2 3

_____--__--- 53% 69% 76%

_____-.- ~- 59 60 69 __-- __-.-----~. 56 79 80 ___.-__-__---.---_~.. _ 56 72 -~ I_-- ..--11_5 54 68 85 Note: Sampling errors range from +/-15 percentage points for small employers who experienced great or very great increases in labeling requirement costs to +/-6 percentage points for large employers who experienced a great or very great increase from increased employee training costs,

Page 59 GAO/HRD-9%63BR OSHA Hazard Communication StandardAppendix V Data Supporting Figures in Appendix I

Table V.7: Data for Flgure I.16 Percent of emdovers

On emnlnvers 1 2 3 4 5 42% 30% --la% 4% 3% On emblovees 45 25 9 11 11 Note: Sampling errors range from +/-9 percentage points for employers finding a very/somewhat positive effect from HCS on employees to +/-3 percentage points for employers finding no effect from HCS on employers.

Table V.6: Data for Figure 1.17

_ ,.. Percent of employers 1 2 3 Quality of workplace hazard training Employee hazard awareness 36% 43% 22% .-___ -___-- 41 39 20 ~__- Employees’ care in handling/use of chemicals 41 38 21 ______c_-~-.-_. Availability of hazard information 56 37 7 --________I_ __.--.._- Management awareness of workplace hazards 56 31 13 Note: Sampling errors range from +/-9 percentage points for employers finding a great or verygreat improvement from HCS on the quality of workplace hazard training to +/-4 percentage points for employers finding slight or no improvement from HCS on the availability of workplace information.

Page 60 GAO/HRD-9%63BR OSHA Hazard Communication Standard

### Appendix VI - 

# Comments From the Department of Labor

r U.S. Department of Labor AssIslanl Secretary lor Occupmonal Safety and Heanh Washlnqton DC 20210

Ms. Linda G. Morra Director Education and Employment Issues U.S. General Accounting Office Washington, D.C. 20548 Dear Ms. Morra: Thank you for your letter of February 7 to Secretary of Labor Lynn Martin, in which you requested comments on the General Accounting Office (GAO) draft report entitled, Occupational Safety and Health: Employers' Experiences in Comolylng With the Hazard Communication Standard. The Occupational Safety and Health Administration (OSHA) appreciates the opportunity to present comments on such an important study of hazard communication. OSHA is encouraged by GAO's overall findings. These findings demonstrate that the Hazard Communication Standard (HCSI has contributed significantly to better safety and health for workers while, at the same time, posing minimal compliance problems for employers. The objective of the GAO study was to examine the possible difficulties small employers may be experiencing in complying with the HCS, and the methodology underlying OSHA's estimates that was used to assess costs for small employers. OSHA applauds the report for its factual recounting of GAO's findings in the investigation of these two issues. The GAO findings support the Agency's contention that the standard is feasible for small businesses, and that compliance results in benefits. GAO found that almost 70 percent of small employers that had made an attempt to comply with the standard were able to do so without experiencing significant burdens. This finding is consistent with OSHA's experience in implementing the rule. Additionally, OSHA considers the benefits of complying with the HCS to be significant. GAO notes that more than half of the small employers who attempted to comply with the standard reported a vast improvement in the availability of hazard information and in management's awareness of workplace hazards. Reported reductions in injuries and illnesses were also significant. Further, GAO found that 30% of all employers (and nearly 70% of large employers) have replaced a more hazardous

Page 6 1 GAOMRD-9243BR OSHA Hazard Communication Standard 

### aAppendlx VI Comments From the Department of Labor

substance with a less hazardous substance because of information received from a Material Safety Data Sheet. In our view, that represents a very significant finding, and vividly demonstrates the tremendous impact which the HCS is having on the promotion of safe and healthful workplaces. We were also encouraged by the finding that OSHA's methodology for estimating compliance costs is fundamentally sound. We have endeavored in all such analyses to use accepted and objective economic analysis methodologies. We will continue to try to utilize the most accurate data available in these models, and will carefully review the study's comments with respect to the calculation of non-wage benefit costs. Finally, let me assure you that OSHA will continue its efforts in assisting employers, especially small employers, in understanding and complying with the HCS. You can be assured that the Agency intends to include the GAO report in its entirety in the record of future rulemaking on this issue. Sincerely,

Dorothy L'. Strunk Acting Assistant Secretary

Page 62 GAO/HRD-92-63BR OSHA Hazard Communication Standard

### Appendix VII 

# Major Contributors to This Report

Human Resources Division, Washington D.C. Carlotta C. Joyner, Assistant Director, (202) 512-7010 Charles A. Jeszeck, Evaluator-in-Charge Susan L. Sullivan, Senior Social ScienceAnalyst Wayne M. Dow, Senior Operations ResearchAnalyst Tom S. Hungerford, Economist 

# Philadelphia Regional David J. Toner, Regional Management Representative 

# Office Michelle Walker, Senior Evaluator William F. Schmanke, Evaluator, Computer Science Marilyn R. Fisher, Computer Programmer Specialist

Page 03 GAO/HRD-92-63BR OSHA Hazard Communication Standard

# RelatedGAO Products

(206176) 

### Occupational Safety & Health: Worksite Safety and Health Programs Show Promise (GAO/r-HRD-92-15,Feb. 26, 1992). Occupational Safety & Health: OSHA 

### Action NeededTo Improve Compliance With Hazard Communication Standard (GAO/HRD-92-8, Nov. 26, 1991). Occupational Safety & Health: Worksite Programs and Committees (GAO/T-HRD-92-9,

Nov. 5, 1991). Managing Workplace Safety and Health In the Petrochemical Industry (GAOm-HRD-92-1,

Oct. 2, 1991). OSHA’S Oversight of Federal Agency Safety and Health Programs (GAOm-HRD-91-31,

May 16, 1991). Occupational Safety & Health: OSHA 

### Policy Changes Neededto Confirm That Employers Abate Serious Hazards (GAO/HRD-9 1-35BR,May 8, 199 1). Occupational Safety & Health: Inspector Opinions on Improving OSHA 

### Effectiveness (GAO/HRD-9 1-9FS,Nov. 14, 1990). Occupational Safety & Health: Options For Improving Safety and Health in the Workplace (GAO/HRD-90-66BR, Aug. 24, 1990). How Well Does OSHA



### Protect Workers From Reprisal: Inspector Opinions (GAO/-THRD-90-8,NOV. 

### 16, 1989).

a

Page 04 GAO/HRD-9%03BR OSHA Hazard Communication Standard

### Orders may also be pi;tcvd by calling (202) 275-6241.