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OSHA releases guidance on its hazard communication standard effective dates [US]
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OSHA’s enforcement memorandum extension for chemical manufacturers & importers
OSHA’s February 9, 2015 enforcement memorandum will extend its enforcement of the June 1, 2015 deadline for chemical manufacturers and importers to provide updated safety data sheets (SDS) and labels.Who is concerned by the OSHA’s enforcement memorandum extension
Not all chemical manufacturers or importers will be covered under this extension. Only those manufacturers and importers that have made reasonable and good faith efforts to comply by the original deadline, but are unable to comply due to circumstances outside of their control will be granted an extension.- Distributors whose suppliers have not been able to comply with the June 1, 2015 deadline will be permitted to ship products with the outdated labels until provided with current SDSs and labels.
- A distributor shipping products with outdated labels must be able to document its communication with its suppliers regarding the suppliers’ non-compliance with the new label requirements.
OSHA Process
OSHA will determine whether manufacturers or importers have exercised reasonable diligence and good faith in obtaining updated SDSs and labels from their upstream raw material suppliers. Manufacturers and importers should document their efforts to obtain classification information and SDSs from upstream suppliers, find hazard information from alternative sources, and classify the data themselves.Red-on-line EHS Legal Expert
Sources :
OSHA Memorandum, Enforcement Guidance for the Hazard Communication Standard’s (HCS) June 1, 2015 Effective Date, February 9, 2015