Enforcement Guidance for OSHA's Hazard Communication Standard's June 1, 2015 Effective Date

摘要

The June 1, 2015 deadline of the Occupational Safety and Health Administration's (OSHA's) revised Hazard Communication Standard (HCS 2012) has become challenging for many manufacturers of formulated products because manufacturers of individual raw materials are not required to provide HCS 2012 safety data sheets (SDSs), classifications, and labels until the June 1, 2015 deadline. In August 2014, nine trade associations petitioned OSHA to grant formulators an extension of the June 1, 2015, deadline for HCS 2012-compliant labels and SDSs. OSHA decided to address the issue through its enforcement policy and enforcement discretion. In response to the petition, OSHA has developed Enforcement Guidance for the Hazard Communication Standard's June 1, 2015 Effective Date. This field enforcement guidance applies only to HCS 2012 compliance inspections of chemical manufacturers, importers, and distributors in their classification of hazardous chemicals and development of SDSs and labels for chemical mixtures. The guidance was issued February 9, 2015 and provides limited relief from enforcement to those formulators and distributors who are not able to comply with the HCS 2012 effective dates for SDSs and labels (due to circumstances beyond their control) because they have not received the necessary classifications, SDSs, and labels from their upstream supplier.