OSHA Internal Memo: Interim Guidance on Enforcement of the revised Hazard Communication Standard

OSHA HCS Interium memo

 

OSHA HCS Interium memoAlthough the revised Hazard Communication Standard (HCS 2012) does not become fully implemented until June 1, 2016, some provisions are already in effect or will soon be in effect (e.g., training). Per 29 CFR 1910.1200(j)(l), by December 1, 2013, all employers whose employees are potentially exposed to hazardous chemicals should have provided training on the revised HCS label elements and the new format and types of information on each section of safety data sheets (SDSs). The purpose of this training is to ensure that when employees begin to see HCS 2012-compliant labels and SDSs in their workplaces, they understand how to use them and access the information effectively. The Office of Health Enforcement is developing a revised Compliance Directive to outline procedures and policies for the new standard. This memo provides interim guidance to Compliance Safety and Health Officers (CSHOs) on the December 1, 2013, implementation date. Beginning December 2, 2013, if an employer has not provided the training required by the HCS, citations shall be issued for training deficiencies under 1910.1200(h) ofHCS 2012. The following is a brief outline of the expectations on or after December 1, 2013, for all employers covered by the standard: …

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