![]() I have spoken to our insurance hygienist and he stated that he has never experienced high concentrations of air born particles in the air in "the normal drilling operation". Further down the page there are three products that would meet the requirements to be considered an article. The Key to the definition of "article", and thus the exemption, is the term "under normal conditions of use".". In each case the deciding factor was the possibility that a toxic gas may be given off in the course of drilling a hole.Īs stated in the OSHA Instruction CPL 2-2.38, page A-3 paragraph four, it states, "The "Article" exemption raises many questions. Simmons, and after giving him the same description of a drill bit, it was his decision that our product would not qualify as an article. ![]() The agent then transferred my call to a hygienist, for verification. I phoned the Washington office on Monday August 17, I spoke with an agent who, after hearing my description of a drill bit, agreed that this product would qualify as an article under the standard. I asked the agent that I was speaking to if the Occupational Safety and Health Administration offices in Washington DC could speak with more authority on this subject. When I called Chicago I was told that since a drill heats up during operation, it could give off a toxic gas, and therefore it is exempt from the article. When I called Chicago I was told that since a drill heats up during operations, it could give off toxic gas, and therefore it is exempt from the article. The agent that I spoke to gave me the phone number of the Chicago office of OSHA to verify his opinion. I have contacted the Occupational Safety and Health office located in North Aurora, Illinois with the question, "Is a drill bit an article, under the OSHA Standard 1910.1200"? The answer that I received was yes a drill bit would qualify. However in the form that we receive the steel it is considered nontoxic. These steels have components which, in their raw form are toxic. The body of these bits are fabricated of high speed or Cobalt steels. Here are Precision Twist Drill we manufacture drill bits. which does not release, or otherwise result in exposure to a hazard chemical under normal conditions of use. which has end use function(s) dependent in whole or in part upon its shape or design during end use.ģ. A manufactured item: which is formed to a specific shape or design during manufacture,Ģ. The standard lists three criteria that must be met to qualify as an article:ġ. I am referring to the classification of an article under the OSHA Standard, 1910.1200, (b) (5). However I have been trying to obtain a definitive answer from Occupational Safety and Health office, both in Illinois and Washington DC, thus far with no success. I would like to apologize for this intrusion into your busy schedule. If I can be of further assistance please feel free to contact me again. In these instances the article exemption would not apply. However, there may be, circumstances beyond our ability to anticipate that may result in exposure to employees. In most cases, based on our experience thus for, drill bits will be considered "articles" under the Hazard Communication Standard. Consequently, a blanket exemption for specific products cannot be given by OSHA. The Occupational Safety and Health Administration (OSHA) cannot make an across-the-board determination of a products' exclusion as an "article." The standard's definition by its very wording imposes the need to make case-by-case evaluations. If your hazard determination indicates that downstream employees will not be exposed to any hazardous chemicals contained in your drill bit, then your product would meet the definition of an article. The Hazard Communication Standard requires "chemical manufacturers" to evaluate the chemicals produced in their workplace to determine if they are hazardous. Your letter states that you have been informed that if the drill bit is used properly, with a coolant, no dusts will become airborne and that the steel will not heat up to the 1200-degree temperature necessary to release a toxic gas. " Many items appear to meet the definition in their manufactured form, but, manufacturers must consider their products' end use before the "article" exemption may apply. not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use. The key to the definition of an "article," and thus exemption, is the requirement that the manufactured item does ". ![]() The "article" exemption can pose difficulties for manufacturers in determining whether their products meet the definition. Specifically, you asked if a drill bit meets this definition. This is in response to your letters of August 19 and 26 regarding the "article" definition given under the Hazard Communication Standard.
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