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OSHA Releases HCS Interim Enforcement Guidelines

On Friday, May 29th, Occupational Safety and Health Administration (OSHA) released a memo (attached) detailing its interim enforcement guidance for the Hazard Communication Standard (HCS) labeling requirements, effective today, Monday June 1st.

The memo clarifies that manufacturers and importers will not be cited if able to demonstrate reasonable diligence and good faith efforts to obtain classification information from upstream suppliers or alternative sources. Also, existing stock that has been packaged for shipment prior to June 1st may continue to be shipped downstream with no requirement to re-label such containers.

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Barnes & Thornburg alert - May 2015 - June 1: OSHA’s Revised Hazard Communication Standard Deadline for Compliance

On June 1, 2015, OSHA’s revised Hazard Communication Standard (HCS) goes into effect.

Any employer that uses hazardous chemicals in its workplace is subject to the communication and training requirements of the HCS.

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