This memorandum provides information on issues raised since the publication of the Inspection Procedures for the Hazard Communication Standard (HCS 2012) compliance directive, CPL 02-02-079. This memo serves primarily to assist the field staff in clarifying the requirements of HCS 2012. OSHA clarifies the following questions:
- Question 1: Has OSHA changed the meaning of the phrase “exposed under normal conditions of use or in a foreseeable emergency?”
- Question 2: When do all containers of hazardous chemicals shipped by a manufacturer or importer have to be HCS 2012-compliant labeled?
- Question 3: Are end-user employers required to re-label existing stock of containers?
- Question 4: Will OSHA allow an HCS pictogram for Hazards Not Otherwise Classified (HNOC) on a label or safety data sheet?
- Question 5: What ingredients must be listed in sections 3 and 8 of the safety data sheet?
- Question 6: Is “Trade Secret” the only compliant wording allowed on a safety data sheet to indicate that an ingredient is being withheld per the trade secret provisions of HCS?
- Question 7: What collaborative work is being done between OSHA and Health Canada to coordinate and align each country’s positions on GHS?