Significant changes are expected for U.S. federal hazard communications and for lead standards in California, and industrial painters need to be especially vigilant because the impacts could be dramatic, a regulatory expert said Wednesday during the 2024 AMPP Annual Conference + Expo.

The Occupational Safety and Health Administration’s Hazard Communication Final Rule is expected imminently, Alison B. Kaelin of ABKaelin, LLC, told attendees in the “Regulatory Update” forum.

The proposed OSHA hazard communications rule is expected to include changes to definitions, health classifications, and concentrations that could impact coatings, thinners, and abrasives, Kaelin said, adding that she expects the rule to become final in late 2024 or early 2025.

One of the most impactful provisions would be Section 2, where the standard would change to discuss health hazards of chemicals under normal conditions of use, not while in the container.

“The most significant part of the HazCom standard, in my opinion, is going to be the impact on combustible dust,” she said. This is because the ordinary use of some products would generate combustible dust.

The new definition of combustible dust means “finely divided solid particles of a substance or mixture that are liable to catch fire or explode on ignition when dispersed in air or other oxidizing media.”

In California, the pending lead rules of Cal/OSHA also have Kaelin’s attention. She expects them to become effective in January 2025, with extra time for compliance allowed with some provisions.

As Kaelin sees it, the most concerning aspect involves employees conducting dry abrasive blasting after testing for certain limits of blood lead levels. The amount of time an employee could conduct dry abrasive blasting would be limited to five hours per day until an exposure assessment has been completed. This would then decrease to just two hours per day after five years.

“Forewarning is the best thing I can give you,” Kaelin said.

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