By Brent I. Clark, Adam R. Young, and Craig B. Simonsen

iStock_000011623330_MediumThe Occupational Safety and Health Administration has recently released a draft Guidance on Data Evaluation for Weight of Evidence Determination: Application to the 2012 Hazard Communication Standard.

We had previously blogged about OSHA’s 2012 Hazard Communication Standard (HCS), including an Enforcement Guidance,  and a Directive
Continue Reading Hazard Communication Update: OSHA Releases Draft Guidance on “Data Evaluation for Weight of Evidence Determination”

By Brent I. Clark, Ilana R. Morady, and Craig B. Simonsen

iStock_000004667648MediumWe had previously blogged that June 1, 2015 is the deadline for compliance with the all new hazardous communication (HazCom) standard (29 CFR section 1910.1200) (HCS 2012) requirements, with exceptions for chemical distributors, and for employers to update workplace labeling and hazard communication programs. 77
Continue Reading Enforcement Guidance for the Hazard Communication Standard Compliance Date

By James L. Curtis and Craig B. Simonsen

In an illustration of how widely OSHA will be looking at industries that use highly hazardous chemicals, OSHA’s Omaha Area Director recently announced that a Local Emphasis Program will include health inspections at funeral homes, chemical and product manufacturing plants, printing facilities, and outpatient care centers. See, for instance, Appendix A.
Continue Reading OSHA Local Emphasis Program for Funeral Homes, Chemical and Product Manufacturing Plants, Printing Facilities, and Outpatient Care Centers

By Brent I. Clark and Craig B. Simonsen

OSHA has recently released a “Small Entity Compliance Guide for Employers That Use Hazardous Chemicals.” OSHA 3695-03 2014.

As we noted in an earlier blog, OSHA had in 2012 issued a more than 800-page Final Rule revising the Hazard Communication Standard (HCS), 29 C.F.R. 1910.1200.  The primary purpose
Continue Reading OSHA HazCom Small Entity Compliance Guide — Are You (And Your Company’s Policy Manuals and Training Requirements) Ready?

By James L. Curtis and Ilana R. Morady

As we noted in a blog earlier this year, on December 1, 2013, employers must begin complying with OSHA’s new Hazard Communication (HazCom) standard.

The Agency had revised its HazCom standard (77 Fed. Reg. 17574 (March 26, 2012)) to align with the Globally Harmonized System of Classification and Labeling of
Continue Reading OSHA HazCom Compliance — Are You (And Your Company’s Policy Manuals and Training Requirements) Ready?

By Ilana R. Morady

2013 is the year that employers must begin complying with OSHA’s new Hazard Communication (HazCom) standard.

What is the new HazCom standard?

Last year, the Agency revised the HazCom standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which is an international standardized approach to elements of hazard communication.

Continue Reading New OSHA HazCom Compliance Deadlines Are Around The Corner