Proposed changes will have negative time and cost impact on Safety Data Sheet generation

Last week 12 major chemical organizations sent a joint letter to U.S. Secretary of Labor Martin J. Walsh and Assistant Secretary of Labor Douglas L. Parker reiterating their concerns over proposed changes to OSHA’s Hazard Communication Standard (HCS) regarding Safety Data Sheets (SDS).
HazCom Update

These organizations represent the entire U.S. chemical value chain. They include:

  • American Chemistry Council
  • American Cleaning Institute
  • American Coatings Association
  • The Chlorine Institute
  • Color Pigments Manufacturers Association
  • Council of Producers and Distributors of Agrotechnology
  • The Fertilizer Institute
  • Household & Commercial Products Association
  • National Association of Chemical Distributors
  • Plastics Industry Association
  • RISE (Responsible Industry for a Sound Environment)
  • Society of Chemical Manufacturers and Affiliates

The proposed changes include a provision to classify a product based not on the product as shipped, but to include any possible downstream reactions. If adopted in the final rule, this requirement would create an impossible situation for chemical manufacturers and distributors. It is impractical for an upstream manufacturer or distributor, with no direct line of sight, to know all possible uses and hazards or potential reactions associated with downstream customers’ processes without knowing the details of those processes. This will also make irrelevant the existing chemical hazard data that has been curated since the beginning of GHS. In addition to the burden on manufacturers, this will also create an SDS that potentially has no correlation to the product as shipped and will undermine the HCS’s own goals of seeking to communicate chemical hazard data to assure worker protection.

Here is the letter to Secretary Walsh

Quantum agrees whole heartedly with the content of this letter and urges you to contact OSHA and your representatives with your concerns regarding the proposed OSHA HazCom regulations.


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