OSHA Interpretations Provide Guidance for Complying with the Harmonized System of Classification Labeling Requirements

摘要

Efforts to comply with provisions of the Occupational Health and Safety Administration's (OSHA's) revised Hazard Communication Standard ("HCS 2012"; 29 CFR 1910.1200) have given rise to a number of questions concerning labeling of containers. The labeling requirements, based on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), were adopted in a final rule on March 26, 2012 and, with certain exceptions, are mandatory after June 1, 2015. During the transition period, chemical manufacturers, importers and distributors may continue to comply with the requirements of the 1994 HCS ("HazCom 1994") or begin using the revised HCS 2012 labeling provisions. An additional six months, to December 1, 2015, is provided for distributors to continue to ship containers which were labeled by manufacturers or importers in compliance with HazCom 1994, without having to modify the labels to meet HSC 2012 requirements.