PLEASE NOTE the LOI in which OSHA adopted EPA’s 1% rule was thrown out by the courts so I am NOT 100% sure OSHA can use the 1% rule from EPA in their evaluations of what is a covered process/HHC.
The smoke is still rising from OSHA’s recent change on Concentrations of greater than 1% for HHC solutions. But already I am getting first-hand accounts from friends that are being impacted in a significant way. Take for example a VERY common corrosion resistance material used in nearly all vehicle/ mobile equipment manufacturing that contains 5% Hydrogen Fluoride.