WASHINGTON - According to a standard interpretation letter posted by the Occupational Safety and Health Administration (OSHA) and reported by the NPCA, the consumer products exemption in the OSHA's hazard communication rule is applicable when products are used "as a normal consumer would use them."

OSHA responded to an inquiry from an attorney in Albany, N.Y., who asked whether requirements for maintaining material safety data sheets (MSDSs) would apply for workers using art supplies and office-cleaning products.

In the case of the paint thinners and paints, OSHA replied that if workers are "routinely exposed to these hazardous chemicals, then they would be required to be afforded the chemical hazard information available through MSDS and hazard communication training."

The determination is to be made by the employer, according to OSHA. "It is the responsibility of the employer to determine employee exposure and ascertain if the frequency of use/exposure is indeed not more than that which would be experienced by a normal consumer," the agency said.