News & Analysis as of

Safety Data Sheets

The Cleaning Product Right to Know Act of 2017: California’s newest warning requirements

by Thompson Coburn LLP on

In the fall of last year, California Governor Jerry Brown signed the Cleaning Product Right to Know Act of 2017 (the "CPRTKA"), adding provisions to the California Health and Safety Code commencing at § 108950 related to...more

Upcoming EPCRA Tier II Reports Must Use New Hazard Classifications

by Williams Mullen on

Manufacturers and large scale users of hazardous chemicals know the significance of March 1st. The Emergency Planning and Community Right-To-Know Act (EPCRA) requires facilities where hazardous chemicals were present above...more

Medical Waste/OSHA Enforcement: Missouri Podiatry Clinic Cited for Alleged Violations

The Occupational Safety and Health Administration (“OSHA”) cited Anderson Foot and Ankle Clinic (“AFAC”) for alleged violations of the hazard communication standard. AFAC is stated to be a Rolla, Missouri podiatry clinic....more

Fundamental Hazard Communications to Control Risk

by Davis Wright Tremaine LLP on

To assure environmental health and safety, businesses must let their employees know the potential chemical hazards in the workplace. Businesses with such hazards were required to implement OSHA’s revised Hazard Communications...more

NAS Releases Its Compliance Safety Accountability System Report - Proposed Legislation May Further Impact the Use of the Program's...

by Holland & Knight LLP on

The Federal Motor Carrier Safety Administration (FMCSA) may overhaul how it evaluates the safety of the carriers it regulates following the release of a new study by the National Academies of Sciences, Engineering and...more

Synopsis Available for 2016 U.S.-EU: Bridging NanoEHS Research Efforts Joint Workshop

by Bergeson & Campbell, P.C. on

The synopsis is available for the June 6-7, 2016, U.S.-European Union (EU) Nano Environmental and Health Safety (NanoEHS) Research Efforts joint workshop. According to the synopsis, the first day of the workshop was devoted...more

TSCA: Proposed Revisions to Significant New Use Rules Reflect Current Occupational Safety and Health Standards

The U.S. Environmental Protection Agency (EPA) proposed on July 28, 2016, revisions to the regulations governing significant new uses of chemical substances under the Toxic Substances Control Act (TSCA) with revisions to the...more

What We Have Here is a Failure to Communicate (in the Workplace)

by Williams Mullen on

For the third consecutive year, OSHA’s second most cited violation was for failure to comply with the Hazard Communication Standard (HCS). The HCS was promulgated in 1983 and requires chemical manufacturers and importers to...more

Environmental Notes - May 2016

by Williams Mullen on

The news has been full of stories and articles concerning Coal Combustion Residuals (CCR), also referred to as coal ash. CCR became a hot topic in 2008 when a coal ash pond at a utility plant in Tennessee spilled more than 5...more

Australia Addresses Nanomaterials in Third NICNAS Reforms Consultation Paper

by Bergeson & Campbell, P.C. on

On April 29, 2016, Australia’s National Industrial Chemicals Notification and Assessment Scheme (NICNAS) published the third consultation paper on its reform initiative. Under the reforms, the requirements to establish that...more

OSHA Soliciting Comments for New Guidance for Determining Potential Health Hazards of Chemicals

by BakerHostetler on

On February 12, 2016, the U.S. Department of Labor’s Occupational Safety and Health Administration (“OSHA”) announced that it plans to issue new guidance as part of its effort to protect workers from the hazards of chemicals....more

REACH Enforcement: Notes from ANSI Chemical Network Presentation

On January 21, 2016, the American National Standards Institute (ANSI) hosted a presentation on enforcement under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation. The topics covered...more

HCS: OSHA Issues Letter of Interpretation on Import/Export Labels for Hazard Communication Standard (HCS 2012)

by Bergeson & Campbell, P.C. on

On November 23, 2015, the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) issued a Letter of Interpretation (LOI) on labeling packages for import and export. The LOI discusses labeling...more

OSHA Directive on Inspection Procedures for the Hazard Communication Standard

by Seyfarth Shaw LLP on

OSHA has just announced a compliance Directive on “Inspection Procedures for the Hazard Communication Standard,” CPL 02-02-079 (July 9, 2015)....more

New SDS Disclosures Require Changes to Overall Hazard Communication Policy

On June 1, new OSHA rules took effect for all employers, changing requirements for chemical manufacturers and importers who prepare and distribute Safety Data Sheets (SDS). Under these rules, the SDS (previously called...more

Protecting Your Chemical Trade Secrets vs. OSHA Compliance: What You Must Disclose and What You Can Keep Confidential

by Polsinelli on

Scenario: You are a chemical manufacturer and have created a chemical formulation that you intend to keep secret, to keep others from copying your product. The new formulation is hazardous and therefore must be handled with...more

U.S. OSHA HCS 2012 Deadline Less Than Two Weeks Away

by Bergeson & Campbell, P.C. on

On March 26, 2012, OSHA issued a final rule modifying its HCS to conform to the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. In the final rule, OSHA drastically...more

Revised Hazard Communication Standard: December 1st, 2013 Deadline for Training and the Basic Training Requirements that You Need...

by Miller & Martin PLLC on

OSHA revised its Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Two significant changes contained in the revised standard...more

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