GHS

What You Need to Know About OSHA’s Updated Hazard Communication (Chemical Right-to-Know) Standard

Kate M. McMahon 2 Comments

By Valerie Butera and Kate McMahon

On May 20, 2024, OSHA published a significant revision to the Hazard Communication Standard (HCS) in an effort to better align the HCS with the United Nations’ Globally Harmonized System of Classification, primarily Revision 7 (GHS).  This final rule also seeks to clarify ambiguities left unresolved by the last set of revisions to the HCS and to improve alignment with other federal agencies and international trading partners.

In making these changes, OSHA has created a host of new regulatory hurdles for chemical manufacturers, importers, distributors, and downstream users.  The final rule becomes effective July 20, 2024, but offers a grace period during which the regulated community may comply with the final rule or the prior version of the HCS.

CMC sat down with Maureen Ruskin, the now-former OSHA official who led the effort to align the HCS with the GHS, to discuss the changes in this final rule.  Our conversation informed this Client Alert, which begins with an overview of the biggest impacts the final rule will have on the regulated community and the timeline for coming into compliance with the new and changed requirements, provides a detailed discussion of what the final rule says and means, explores significant changes between the language of the proposed rule and what was actually adopted in the final rule, and explores tips and strategies for compliance.

Implications for the Regulated Community

The final rule impacts nearly every aspect of hazard communication – from Continue reading →

New GHS Hazard Communication Standard: Roll-out Issues [Webinar Recording]

Kate M. McMahon Leave a comment

On Wednesday, May 11, 2016, Kathryn M. McMahon and Dan C. Deacon of Conn Macial Carey’s national OSHA Practice Group presented a webinar regarding the final roll-out of OSHA’s new GHS Hazard Communication Standard as part of the Firm’s 2016 OSHA Webinar Series.

Perhaps the most significant safety related regulatory reform during the Obama Administration has been the amended Hazard Communication Standard, bringing OSHA’s chemical Right-to-Know regulation more in line with the United Nation’s Globally Harmonized System of Classification and Labeling of Chemicals (“GHS”).  The new GHS HazCom standard fundamentally changes how employers must classify chemicals in the workplace, and requires all new chemical labels and Safety Data Sheets (formerly MSDSs).

The new GHS HazCom Standard had a seemingly long roll-out period, but time has flown by, and many of the key deadlines under the new rule have already past, and the final deadlines are now upon us.

This webinar explained the new Hazard Communication standard, identified some of the key issues with the new HazCom rule that have surfaced during the roll-out, and explained what employers need to do to come into compliance.  Participants learned about the following:

  •  Background about OSHA’s new GHS Hazard Communication Standard
  • Important elements of the new rule that employers need to know
  • Key implementation deadlines and enforcement deferrals
  • Developing issues uncovered during the roll-out of the new rule
  • Best practices for coming into compliance with the new GHS HazCom Standard

Click here to view a recording of the webinar.

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2015 OSHA Webinar Series – Archive of Recordings

Eric J. Conn 3 Comments
Webinar Series 1
Today’s OSHA has increased enforcement to levels never seen before, from increased inspections and citations to dramatically higher penalties, from more criminal referrals to a heavy dose of public shaming.  It is more important than ever to be prepared. This complimentary webinar series has been designed to give employers the tools they need to avoid becoming an OSHA-enforcement poster child.
We have recorded and will continued to record each of the webinars, and as we move through the year and conduct these webinars, we are pleased to provide links below to the recordings.  There are also links below to the registration pages for the remaining webinars in the series.  Check out the completed webinars and plan to join us for all or some of the rest of the series.

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