OSHA's Lead Standard sets requirements for the provision of environmental (workplace) monitoring, recordkeeping, employee education and training, medical surveillance, medical removal protection, hygiene facilities and other requirements that must be met by employers if their employee's exposure to lead exceeds the specified limits. OSHA's current standard for occupational exposure to lead during soldering operations is set at 50 micrograms lead per cubic meter of air (50mg/m3), measured as an 8-hour time weighted average exposure (e.g., employee exposure to lead in air, measured and averaged over an 8-hour work day). During soldering operations, personnel risk being exposed to lead fume. Solder contains, as you indicated in attachments to your letter, a large percentage of lead. With regard to your specific question on whether or not "standards exist for solder" and "if solder is in fact harmful" to one's health, OSHA has enforced, since 1981, its standard for occupational exposure to inorganic lead. have contained the warning labels you mentioned in your letter. Since November of 1985, therefore, manufacturers of hazardous substances in the United States have had to comply with the Agency's HCS as described above, and this is why shipments of solder you have been receiving from the U.S. It also provides necessary hazard information to employees, so they can participate in and support the protective measures in place at their workplaces. OSHA's Hazard Communication Standard was promulgated to ensure that all employers receive the information they need to inform and train their employees properly on the hazardous substances they work with and to help design and put in place employee protection programs. The HCS incorporates a "downstream flow of information" which means that producers of chemicals have the primary responsibility for generating and disseminating information, while users of chemicals must obtain the information and transmit it to their own employees. In addition, the standard requires that employers develop and implement a written hazard communication program and communicate hazard information to their employees through formal training programs. Chemical distributors must also adhere to the labeling requirements of the standard, and must ensure that MSDSs are provided to employees. The labels must include the identity of the chemical hazardous substance, appropriate hazard warnings and the name and address of the manufacturer, importer or responsible party. Under the HCS, manufacturers of chemicals or materials that may create a hazardous exposure during their use are to provide hazard information through warning labels affixed to all containers of their products and through the provision of material safety data sheets (MSDSs) to all downstream recipients or users of their products. The HCS has recently been expanded to include all workers exposed to hazardous substances in all industrial sectors, not just those in the manufacturing sector covered under the original standard. The standard requires that chemical manufacturers and importers assess the hazards of the chemicals and products they sell. In your letter, you mention that for a number of years you have been purchasing solder products from the United States but that recently, shipments of the solder materials have contained warning labels that indicated that the inhalation of solder fumes "could be harmful and could lead to birth defects, etc." On November 25, 1985, OSHA's Hazard Communication Standard (HCS) became effective. Please accept our apology for the long delay in this response to you. The National Institute of Standards and Technology (formerly the National Bureau of Standards) forwarded your letter to the Occupational Safety and Health Administration (OSHA). This is in response to your letter of January 12, addressed to the National Bureau of Standards, regarding the hazard warning labels attached to a shipment of solder your company received.
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