Labor and Employment Law Alert - June 1: OSHA’s Revised Hazard Communication Standard Deadline for Compliance

The Occupational Safety and Health Administration’s (OSHA) revised Hazard Communication Standard (HCS) compliance deadline of Monday, June 1, 2015, is fast approaching. The revised standard was effective in 2012, but it has staggered compliance deadlines for various aspects of the regulations over the years.

OSHA’s revised Hazard Communication Standard (HCS) took effect May 25, 2012. It was revised to align with the internationally accepted Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Any employer that uses hazardous chemicals in its workplace is subject to the communication and training requirements of the HCS. OSHA estimates that this revised standard will affect more than five million workplaces across the country employing more than 43 million workers.

Employers were required to train their employees on the new labeling elements as well as the new standardized safety data sheets by Dec. 1, 2013. The deadline for chemical manufacturers, importers and distributors to comply with new hazard classifications and the classifications of chemical mixtures on their labels is June 1, 2015. However, distributors may still ship chemicals labeled by manufacturers under the old systems until Dec. 1, 2015.

Hazard Communication has been one of the most frequently cited standards by OSHA for years. In fact, in fiscal year 2014, it was the most frequently cited standard for general industry. Given this fact, employers should consider consulting legal counsel regarding compliance with the revised regulations.

For more information, please contact the Barnes & Thornburg Labor and Employment attorney with whom you work, or a leader of the firm’s Labor and Employment Law Department in the following offices:

Kenneth J. Yerkes
Department Chair
(317) 231-7513

John T.L. Koenig
Atlanta
(404) 264-4018

David B. Ritter
Chicago
(312) 214-4862

William A. Nolan
Columbus
(614) 628-1401

Mark S. Kittaka
Fort Wayne
(260) 425-4616

Robert W. Sikkel
Grand Rapids
616-742-3978

Peter A. Morse
Indianapolis
(317) 231-7794

Scott J. Witlin
Los Angeles
(310) 284-3777

Teresa L. Jakubowski
Washington, D.C.
(202) 371-6366

Janilyn Brouwer Daub
South Bend/Elkhart
(574) 237-1130

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