OSHA has issued a 2022 LOI discussing the use of Transmitting bulk shipment labels by technological or other means. In the letter, OSHA addresses the use of QR Codes, which has become a very popular means of conveying information to employees. Here are the two (2) questions OSHA addresses in its letter:
Question 1: Does OSHA have guidance on acceptable methods to transmit labels by “technological or other means”? For example, would including a website link to the safety data sheet (SDS) that also includes a copy of the label information or a link to the label itself on the shipping papers meet this requirement?
Question 2: Could we provide the label electronically when we provide the SDS prior to the first bulk shipment? If so, would we need to re-send the label prior to each shipment, or only if there are changes to the label?
CLICK HERE for the full letter.