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Policy Recommendations:

• Require manufacturers to ensure that the hazard evaluation information on MSDSs is complete, accurate, and comprehensible, especially regarding substances that pose chronic health hazards.

Require manufacturers and distributors of nail salon products to provide bilingual MSDSs (including English/Vietnamese) to all purchasers.

Legislatively mandate a standardized MSDS format for nail salon product manufacturers, using the format of the ANSI or GHS.

Develop and translate “how to” guides into appropriate languages to help nail salon owners and technicians interpret the information in MSDSs.

Continue developing an enforcement initiative within OSHA for compliance officers to review and evaluate the adequacy of MSDSs.37

Ensure basic fairness and due process for primary language non-English speakers.

Current law requires that state agencies, such as the BBC and Cal/OSHA, provide language assistance, including interpretive services in formal administrative hearings. Agencies may provide language assistance services in “informal fact-finding or informal investigatory hearings” but it is not mandatory that they do so.38

Additionally, every agency must notify each person of her or his right to interpreter services at the time s/he receives notice of a hearing date, but the law requires that an agency must cover the cost of interpreter services only if the hearing officer requires it. Consistently covering the cost of interpreter services could result in cost-saving in more efficient communication and hearing processes.

POLICY RECOMMENDATIONS:

  • Require that language assistance be provided at informal fact-finding and investigatory hearings as well as formal hearings, with costs covered by the state government or agencies.

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OVEREXPOSED & UNDERINFORMED

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