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Re: MSDS for radiological hazards?



 Several years ago, I talked directly with an OSHA official (but I can't
 remember who) who told me that radioactive materials were exempt from MSDS
 requirements. I am now trying to find a citation to support this statement.

 I have received some direct responses to my original posting on this topic
 which I would like to repeat here on RADSAFE to elicit some further responses.

 My first respondent stated:

   "As I remember, it is not a direct citation in the AEA or OSHA. The
    authority for OSHA extends to radiation hazards that are not source,
    special nuclear material, or byproduct material as those hazards are the
    exclusive domain of agencies regulating under the AEA. Consequently, OSHA
    regulates machine-produced radiation and naturally occurring and accelerator
    produced radioactive material.

    SHORT ANSWER: If the tritium were produced by an accelerator, it would
    fall under OSHA and MSDS requirements would apply."

 My second respondent pointed out:

   "In the State of Washington, the Department of Labor and Industries
    publishes the state's general occupational health standards in Washington
    Administrative Code Chapter 296-62 WAC; Part C of these regulations regard
    Hazard Communication, including MSDSs. WAC 296-62-05403(6)(k) specifically
    excludes ionizing and nonionizing radiation from HazCom requirements."


   Bruce Pickett
   The Boeing Company, Seattle, WA
   shea136@kgv2.bems.boeing.com

 "Welcome to my nightmare."
                          - Alice Cooper