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IN THIS ISSUE ...

Regulatory Alerts
  • OSHA Provides NACD with New Information on Hazard Communication Standard (HCS) / Global Harmonization System (GHS)
  • NACD Issues Regulatory Alert on OSHA's Hazard Communication Standard
  • OSHA Releases Guidance on GHS Enforcement
  • Regulatory Update — OSHA Says Mixture Ingredients with Health Hazards at or above Concentration Limits Must Be Listed on SDSs


  • OSHA Compliance Resources
  • Various OSHA Communications and Briefs
  • Everything You Need to Know about OSHA's Hazard Communication Standard (HCS)
  • OSHA quick card compares HazCom 2012, NFPA Diamond labels


  • OSHA Letters of Interpretation
  • 5 Letters of Interpretation in Response to NACD Member Questions Now on Website
  • 2 Important OSHA Interpretation Letters on HazCom/GHS Now Available
  • OSHA GHS Labeling Q&A Docs Now Available
  • OSHA Says Mixture Ingredients with Health Hazards at or above Concentration Limits Must Be Listed on SDSs


  • Important NACD Compliance Resources
  • OSHA Response to NACD Questions, May 2015
  • OSHA Clarifies GHS Implementation for Distributors
  • The Special Challenges of GHS Labeling in Chemical Distribution Webinar and Q&A Available (September 2014)
  • OSHA GHS Implementation - What Chemical Distributors Need to Know Webinar and Q&A Available (March 2013)


  • NACD Preferred Regulatory Compliance Providers Resources
  • U.S. OSHA HCS 2012 Deadline Less Than Two Weeks Away
  • Avoiding HCS Citations: OSHA Issues Useful 'How-To' Guidance; Resources Available
  • Regulatory Preferred Compliance Provider Resource: OSHA Labeling of Shipped Containers
  • OSHA Exercising Enforcement Discretion for HCS Compliance






  • OSHA Hazard Communication Edition
    NACD
    To help you comply with the Occupational Safety and Health Administration's (OSHA) upcoming Hazard Communication Standard (HCS) taking effect June 1, NACD has posted a number of resources to help you understand the regulation's requirements in NewsBrief. These resources can also be found at: http://www.nacd.com/regulatory/resources/
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    SPONSORED CONTENT


    REGULATORY ALERTS


    OSHA Provides NACD with New Information on Hazard Communication Standard (HCS) / Global Harmonization System (GHS)
    NACD
    The Occupational Health and Safety Administration (OSHA) provided NACD with written responses to members’ questions on the revised Hazard Communication Standard (HCS) during the Washington Fly-In meeting with OSHA Enforcement Director, Thomas Galassi.
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    NACD Issues Regulatory Alert on OSHA's Hazard Communication Standard
    NACD
    From May 12: With the Hazard Communication Standard 2012 (HCS)/Global Harmonization Standard June 1, 2015, deadline for chemical manufacturers, importers, and distributors to have updated safety data sheets (SDSs) and labels quickly approaching, NACD is seeking an enforcement delay from OSHA for all chemical distributors who are unable to meet this deadline because of circumstances beyond their control.
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    PRODUCT SHOWCASE
      GHS Compliant Labeling Solutions

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    OSHA Releases Guidance on GHS Enforcement
    NACD
    From Feb. 24: The U.S. Occupational Safety and Health Administration (OSHA) has released important and new enforcement guidance for the Global Harmonization System (GHS)/Hazard Communication Standard’s (HCS) June 1, 2015, effective date.
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    Regulatory Update — OSHA Says Mixture Ingredients with Health Hazards at or above Concentration Limits Must Be Listed on SDSs
    NACD
    From July 22: The U.S. Occupational Safety and Health Administration (OSHA) has issued a letter of interpretation clarifying that ingredients of chemical mixtures must be listed for products containing a sensitizer above the cut-off value/concentration limit.
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    OSHA COMPLIANCE RESOURCES


    Various OSHA Communications and Briefs
    OSHA
  • Small Entity Compliance Guide for Employers That Use Hazardous Chemicals
  • Steps to an Effective Hazard Communication Program for Employers that Use Hazardous Chemicals
  • OSHA Brief on Safety Data Sheets
  • OSHA Brief on Labels and Pictograms

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    Everything You Need to Know about OSHA's Hazard Communication Standard (HCS)
    NACD
    To view the updated HCS standard, letters of interpretation, guidance documents, enforcement memorandums, fact sheets, and more go to: https://www.osha.gov/dsg/hazcom/
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    Missed an issue of NACD's News Brief? Click here to visit the News Brief archive site.




    OSHA Quick Card Compares HazCom 2012, NFPA Diamond Labels
    NACD
    From Aug. 20: The U.S. Occupational Safety and Health Administration, in cooperation with the National Fire Protection Association, has published a "Quick Card" that compares the NFPA 704 Diamond label and HazCom 2012 label to address questions concerning the purpose of the labels, numbering systems used and the other information provided on these labels.
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      PRODUCT SHOWCASES
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    OSHA LETTERS OF INTEPRETATION


    5 Letters of Interpretation in Response to NACD Member Questions Now on Website
    OSHA
  • Letter of Interpretation, Valasek
  • Letter of Interpretation, Kelleher
  • Letter of Interpretation, Watters
  • Letter of Interpretation, Gregier
  • Letter of Interpretation, Olsby

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    2 Important OSHA Interpretation Letters on HazCom/GHS Now Available
    NACD
    From May 5: The deadline for GHS compliance is less than one month away, and OSHA has issued two interpretation letters on GHS requirements for chemicals in commerce, importers and pictograms. Both letters can be found on NACD's website under Regulatory Resources in the Chemical Product Safety section here: http://www.nacd.com/regulatory/resources/.
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    Looking for similar articles? Search here, keyword HAZCOM.


    OSHA GHS Labeling Q&A Docs Now Available
    NACD
    From Jan. 27: The first compliance deadline has past, and NACD is getting a lot of questions from members about how to comply with the new GHS standards. Labels are one of the major changes about which there are questions. Now, NACD has created a Q&A document answering your questions.
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    OSHA Says Mixture Ingredients with Health Hazards at or above Concentration Limits Must Be Listed on SDSs
    NACD
    From July 22: The U.S. Occupational Safety and Health Administration (OSHA) has issued a letter of interpretation clarifying that ingredients of chemical mixtures must be listed for products containing a sensitizer above the cut-off value/concentration limit.
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    IMPORTANT NACD COMPLIANCE RESOURCES


    OSHA Response to NACD Questions, May 2015
    NACD
    These responses are for informational purposes only and does not constitute an official interpretation from the Occupational Safety and Health Administration.
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    OSHA Clarifies GHS Implementation for Distributors
    NACD
    From April 7: During last week's webinar, Preparing for June 1, 2015: OSHA's Hazard Communication Enforcement for Distributors, OSHA provided clarification of the GHS requirements for companies that both manufacture and distribute hazardous chemicals. For these companies, OSHA said the implementation deadline depends on your company's operations.”
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    The Special Challenges of GHS Labeling in Chemical Distribution Webinar and Q&A Available (September 2014)
    NACD
  • Link to full webinar
  • Link to slides
  • Webinar Q&As

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    OSHA GHS Implementation — What Chemical Distributors Need to Know Webinar and Q&A Available (March 2013)
    NACD
  • Link to full webinar
  • Link to webinar slides
  • Link to webinar Q&A

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    NACD PREFERRED REGULATORY PROVIDERS RESOURCES


    U.S. OSHA HCS 2012 Deadline Less Than Two Weeks Away
    Bergeson & Campbell PC
    The U.S. Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) deadline of June 1, 2015, is fast approaching. Below is a brief summary of what is at stake, and what needs to be in place by the deadline.
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    Avoiding HCS Citations: OSHA Issues Useful 'How-To' Guidance; Resources Available
    Bergeson & Campbell PC
    From April 21: Materials are now available from the recent seminar, "Avoiding HCS Citations: OSHA Issues Useful 'How-To' Guidance," presented by The Acta Group, 3E Company, and Bergeson & Campbell, P.C., on April 2.
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    Regulatory Preferred Compliance Provider Resource: OSHA Labeling of Shipped Containers
    ComplianceCenter
    Sometimes, regulations don't give us all the answers we need. For example, many people are confused about the labelling requirements found in the Hazard Communication Standard (HCS) of Part 1910.1200 of the Occupational Safety and Health Act.
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    OSHA Exercising Enforcement Discretion for HCS Compliance
    JD Supra
    From March 3: The Occupational Safety and Health Administration (OSHA) on Feb. 9 issued enforcement guidance on the June 1, 2015, effective date for the Hazard Communication Standard (HCS). The guidance states that OSHA will not pursue enforcement actions against chemical manufacturers or importers who were unable to update their Safety Data Sheets (SDS) and labels by June 1, 2015, because they were not able to obtain updated information from their upstream suppliers, provided the manufacturers and importers exercised due diligence and good faith efforts to obtain the information.
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