OSHA Issues Enforcement Guidance for the Hazard Communication Standard

A long anticipated memo was published February 9, 2015 by the Occupational Safety and Health Administration (OSHA) which outlines enforcement guidance regarding the Hazard Communication Standard’s June 1, 2015 deadline for all labels and SDSs to meet the new Globally Harmonized System of Classification and Labeling of Chemicals (GHS) criteria. The memo describes OSHA’s approach to compliance enforcement with respect to chemical manufacturers and importers who have attempted but were unable to receive the necessary classification information from their up-stream suppliers or other alternative sources, and as a result, cannot comply with the June 1, 2015 deadline. The memo also shows that OSHA has the ability to allow manufactures and importers of mixtures a reasonable amount of time to come into compliance beyond the deadline. The caveat is that this discretion applies on a case-by-case basis and only when the manufacture or importer is able to clearly demonstrate and document "due diligence" and "good faith efforts" toward compliance. SGIA will keep the industry updated on developments and is working toward additional information to assist members in understanding the requirements and for meeting the enforcement discretion guidelines. For more specifics and what OSHA will require, you can review the full OSHA memo at: https://www.osha.gov/dep/enforcement/hazcom_enforcement-memo.html