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Executive Summary

OSHA MATERIAL SAFETY DATA SHEETS WOULD COST DRUG WHOLESALERS more than $ 10 mil. per distribution center, the National Wholesale Druggists Association (NWDA) projected in Sept. 28 testimony before the House Small Business Subcommittee on Exports, Tourism and Special Problems, chaired by Rep. Sisisky (D-Va.). "NWDA estimates each distribution center having to make 4,8 mil. copies of 12.000 MSDSs (material safety data sheets), which, conservatively assuming an average page length per MSDS of four, would mean each distribution center distributing 19.2 mil. pages to pharmacies," NWDA said. "The average wholesaler is expected to incur costs in excess of $ 10 mil. per distribution center to comply with this requirement." The congressional testimony reiterates earlier comments to the Occupational Safety & Health Administration (OSHA) following an Aug. 19 Third Circuit Court ruling that overturned the Office of Management& Budget's decision to disapprove portions of the proposed reg ("The Pink Sheet" Sept. 5, T&G-8). The association has maintained that employees of distributors, pharmacies and hospitals already have access to FDA- approved labeling, particularly through the Physician's Desk Reference, and that access to the labeling by workers in the drug distribution system meets OSHA's proposed regulation requiring distribution of MSDSs. "Our customers . . . often are served by more than one drug wholesaler, [and] that means that the flood of paperwork coming to them from us will also come to them from two or three others," NWDA continued. "All of this cost and effort would be to provide generic, misleading and incomplete information is the form of MSDSs to professionals who already have published volumes of FDA-required, exact and detailed information on their shelves."

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