Rubber Industry

ARPM Rubber Manufacturing Blog

The ARPM Rubber Manufacturing Blog allows members to rapidly communicate with each other. Post both questions and answers to questions that other ARPM members have about any industry topic from material and process issues to R&E Tax Credits and other business issues.

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Rubber Manufacturing Blog / Materials / CFR 29 and the GHS requirements
Posted:  01 Jun 2015 16:05
As I review this new set of requirements is appears to focus primarily on the documentation form of the reporting and there seems to be little change in the reporting requirements themselves.  As a producer of fully cured / cross linked product it appears to me that I continue to supply material that falls under the definition of an "article" as described in the standard.  Am I missing something?

Kendall House
Posted:  01 Jun 2015 16:41
It depends on the following from the codes:

1910.1200(c)

    Definitions. Article means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section), and does not pose a physical hazard or health risk to employees. What is key, is; "under normal conditions will the product release hazardous chemicals?".  [You had mentioned a "cured" product, most cured products I know of release gases during the production of the product as a waste but, under normal conditions do not release gases or chemicals when in normal use.]