On February 16, 2021, the Occupational Safety and Health Administration (OSHA) published a notice of proposed rulemaking (NPRM) to amend the Hazard Communication Standard (HCS). On April, 12, 2021, OSHA published a Federal Register notice to extend the comment period of the NPRM to amend the HCS by one month. The HCS is the federal-level legislation that sets forth the classification, labeling, Safety Data Sheet (SDS), and training requirements for hazardous chemicals intended to be used, handled, or stored in workplaces. The notice is open for comment until May 19, 2021, and OSHA intends to schedule an informal public hearing. OSHA notes in the NPRM that several of the proposed revisions to the regulatory text are meant to incorporate previous Letters of Interpretation (LOI) and provide clarification of obligations. The pressing question we seek to answer below is whether the changes to regulatory text clarify the issue or create additional burdens. For more information, please read the full memorandum.
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