The OSHA Hazard Communication Standard and how it applies in various industries. In your second letter you state that you concur with OSHA's interpretation, but ask how HCS would apply to other industries. As long as PCBs are encased so that they will not present a threat of exposure, workers do not need to be advised of the hazards of PCBs. If employees were exposed to PCB's during the construction of electric light ballasts at the manufacturer's facility, the HCS would apply. During the removal and disposal of old light ballasts, the HCS may apply if the employer determines there is a threat of hazard exposure.
Information regarding the hazards of PCBs and appropriate protective measures is readily available.
Employers whose employees are involved in operations where PCB exposure may occur under normal conditions of use or in foreseeable emergencies, should obtain such information and include it in their hazard communication program. We hope this information is helpful.