Seems like I get to be the messenger once again this month in how a change at one agency MAY impact yet again our compliance with another agency. Last week I reminded the SAFTENG family about how a 2010 change in OR-OSHA impacted some facilities RMPs. This week I have discovered that a change in OSHA’s HAZCOM standard (1910.1200) MAY impact our efforts to comply with EPA rules, specifically Sections 311 and 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Basically, EPA is reminding us that we NOT ONLY have to update our plant’s MSDS files, but that we will ALSO HAVE to update our files of MSDS or a list containing all hazardous chemicals to our State Emergency Response Commission (SERC), local emergency planning committee (LEPC) and our local fire department(s) if the reporting thresholds specified in 40 CFR part 370 are met. Here is more from EPA’s Fact Sheet released this month…