How to Prepare for OSHA’s Proposed Rulemaking to Amend the Hazard Communication Standard

By Johnny Andon, Global Regulatory Affairs Manager

osha-hazcom-standard

With the comment period for OSHA’s Proposed Rulemaking to Amend the Hazard Communication Standard having ended in April 2021, OSHA is now in the later phases of issuing the final rule. For a look at some of the most important changes expected to be implemented, you can reference these articles: OSHA’s Hazard Communication Standard Update and OSHA to Adopt GHS Revision 7. How exactly will this final rule affect you and your business, and how can you best set your company on a path to success when the changes are mandated?

OSHA has identified several industries that will be the most affected by the Proposed Amendment to the HCS. These determinations were based on the number of affected firms, affected establishments, and affected employees. These industries are as follows:

  • Oil and Gas Extraction
  • Petroleum and Coal Products Manufacturing
  • Chemical Manufacturing
  • Plastics and Rubber Products Manufacturing
  • Nonmetallic Mineral Product Manufacturing
  • Primary Metal Manufacturing
  • Miscellaneous Manufacturing (such as for Medical Instruments, Jewelry, Office Supplies, and Toys)
  • Merchant Wholesalers of Durable Goods 
  • Merchant Wholesalers of Nondurable Goods

Within these industries alone more than 115,000 firms comprised of over 152,000 establishments employing more than 4 million individuals will be affected. In addition, a little over 1 billion labels (>63% of the estimated total labels) and over 1 million SDSs (>94% of the estimated total number of SDSs) will need to be revised due to chemical reclassifications and label revisions. These numbers imply an immense amount of effort that will be needed to come into compliance with the Proposed Amendment. With the right software, the process does not have to be as daunting as the numbers suggest.

TotalSDS’ authoring software can take away a lot of the headache associated with hazard communication requirements. With its unique Product Wizard that encompasses product classification requirements, jurisdiction-specific template requirements, and a robust phrase library meticulously researched by our Regulatory Compliance Specialists, TotalSDS offers a comprehensive tool to quickly bring products into compliance with jurisdictions all around the world. When jurisdictional or ingredient level changes occur, TotalSDS updates in turn, and the Product Wizard allows you to quickly revise your SDSs.

OSHA’s Proposed Amendment is not the only one of its kind. Canada is also working to update their WHMIS 2015 regulation, and we can expect their update to be rolled out around the same time as OSHA’s. Regulatory changes are not new or unique to these jurisdictions. The Globally Harmonized System (GHS) is updated by the United Nations every two years, so we can expect that jurisdictions around the world will also be following their own amendments and adoptions in accordance. Therefore, it is essential to have software that stays up to date on global hazard communication requirements. Simplifying regulatory compliance is what TotalSDS does best. Take advantage of the time savings that TotalSDS can provide and the regulatory expertise of our team to navigate the changes.

Contact TotalSDS to find out more and book a demo today.