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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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New Storage Tank Rule Requirements clarifications

Please click here for a printable version of this bulletin.

Please click here for a frequently-asked-questions resource on this issue.

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Barnes & Thornburg alert - May 2015 - EPA and Army Corp of Engineers Pass Rule Clarifying “Waters of the U.S.” Authority

EPA has finalized a rule that purportedly clarifies the definition of “waters of the U.S” and therefore affects the applicability of all Clean Water Act programs.

EPA’s rulemaking has been the subject of national attention, with more than 1 million total comments received - some for and some against the rule.

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March 3 - Michigan Chemistry Council 2015 Policy Priorities

The Michigan Chemistry Council's 2015 Policy Priorities may be found by clicking here.

The Michigan Chemistry Council's 2015 Energy Policy Agenda may be found by clicking here.