Roll out the red flags and citation books.
This week, OSHA instructors received HazCom 2012 compliance instructions to ensure consistent enforcement. The full list of instructions explain how the revised standard is to be enforced during the transition period, and after the standard is fully implemented on June 1, 2016.
Most facilities, including chemical manufactures and importers, had until June 1, 2015 to comply with new chemical labeling provisions. Distributors have until Dec. 1, 2015 to comply, as long as they are not relabeling materials or creating safety data sheets. If so, distributions should have met the June 1, 2015 deadline.
The general Citation Guidelines are as follows:
- For all violations the CSHOshall document the chemical name (and hazardous ingredients) or Chemical Abstract Service (CAS) number, the frequency and duration of use, the number of employees who may be exposed,and the health and physical hazards.
- The CSHO should include photos or video of the chemicals in question and copies of inadequate SDSs.
- During the transition period, when a violation exists either under HCS 1994 or HCS 2012, citations to manufacturers or importers will be issued for both standards. After the appropriate effective date, citations shall be issued only under HCS 2012.
- Repeat violations and failure to abate violations may still be issued under HCS 2012.
- Existing labels that have been removed or defaced and not immediately marked with the required information would be a violation.