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OSHA HAZCOM Compliance Deadline Looms

May 26, 2015 | Staffing Blog

Three years ago the Occupational Safety and Health Administration (OSHA) substantially revised its 1994 Hazard Communication Standard, giving business until June 1, 2015 to comply with the new requirements. Some businesses have expressed concerns about meeting the stricter OSHA compliance standards, particularly those companies whose work involves chemical mixtures. OSHA’s recently published Enforcement Guidance Memorandum indicates that business will not be cited if they have demonstrated an attempt to comply but were not able to obtain essential hazard information from suppliers by the deadline date. These companies must also have labeling compliant with the 1994 standard.

The revisions involve adopting a uniform classification system for chemicals, utilizing the United Nations’ system for chemical container labels and  standardizing a format for Safety Data Sheets (SDS). Chemical manufacturers and importers have the June 1 deadline, while chemical distributors do not have to comply until December 1.

Chemical Manufacturers and Importers

Businesses not compliant by the June 1 deadline due to circumstances out of their control will need to provide the following documentation of oral and written communications:

  • Efforts to obtain classification and SDSs from upstream suppliers
  • Look to alternative sources to get hazard information
  • Classify data on their own

The memorandum indicates that companies have  six months from the date of receiving the required information to create compliant SDSs and container labels.

Chemical Distributors

Chemical distributors have until December 1, 2015 to comply with new SDS and labeling requirements. The Enforcement Guidance Memorandum extends similar relief to distributors who show good faith in attempting to comply with the deadline. These companies can continue to ship chemicals with labels and information compliant to the 1994 standards until December 1, 2017.

Business owners and management should not assume that the deadline for compliance with HCS 2012 has been extended. Instead, OSHA is providing extensions in limited circumstances to companies that have not received the required hazard information from upstream sources in time. Employers should also make efforts to use the remaining time before the deadline to document all communications efforts that would allow for the temporary exemption.

Contact us for additional information on how your company can remain OSHA compliant in today’s workplace.