In your first letter you inquired if labelling, MSDS or training would be required under the Cadmium standard or the HCS, where the potential source of exposure is cadmium coated fasteners. You also asked if the standard would apply if cadmium dust was or was not visible in containers or on gloves or hands of employees. In the May 10 letter, you made an additional inquiry related to the requirements of the cadmium standard. As you may know, the Cadmium standard applies to all occupational exposures to cadmium and cadmium compounds. Under the HCS, employers are required to provide information to their employees about the hazardous chemicals which are known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.
Exposure is defined to include both possible and accidental exposure.
The HCS addresses chemical hazards which are inherent properties of the hazardous chemical and would exist no matter what quantity was present in the workplace. Risk is a function of the inherent hazard and level of exposure. The mechanical coating or plating of cadmium to the fasteners does not combine to form a mixture. The cadmium adheres to the outer surface layer of the fastener. Consequently, the weight of cadmium coating in relation to the total weight of the fasteners is unrelated to what is released and available for employee exposure.