requirement that was scheduled to take effect January 1, 2025. The legislation also creates new sales prohibitions for products with intentionally added PFAS with varying effective dates, exempts certain product categories from the prohibitions, and establishes a new reporting program for those product categories that receive a currently unavoidable use (CUU) determination from MDEP. More information is available in our May 24, 2024, blog item.OSHA HCS Amendments Primarily Align With GHS Rev 7: The U.S. Occupational Safety and Health Administration (OSHA) issued a final rule on May 20, 2024, that amends the Hazard Communication Standard (HCS) to conform to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), primarily Revision 7 (Rev 7), address issues that arose during the implementation of the 2012 update to the HCS, and provide better alignment with other U.S. agencies and international trading partners while enhancing the effectiveness of the standard. 89 Fed. Reg. 44144. OSHA states that, consistent with Executive Order 13563 and the Regulatory Flexibility Act, which call for assessment and, where appropriate, modification and improvement of existing rules, OSHA has reviewed the existing HCS. OSHA states that it determined that the revisions in the final rule “will enhance the effectiveness of the HCS by ensuring employees are appropriately apprised of the chemical hazards to which they may be exposed, thus reducing the incidence of chemical-related occupational illnesses and injuries.” The modifications to the HCS include revised criteria for classification of certain health and physical hazards, revised provisions for updating labels, new labeling provisions for small containers, new provisions related to trade secrets, technical amendments related to the contents of safety data sheets (SDS), and related revisions to definitions of terms used in the standard. The final rule will be effective July 19, 2024. The incorporation by reference of certain

The U.S. Occupational Safety and Health Administration (OSHA) issued a final rule on May 20, 2024, that amends the Hazard Communication Standard (HCS) to conform to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), primarily Revision 7 (Rev 7), address issues that arose during the implementation of the 2012 update to the HCS, and provide better alignment with other U.S. agencies and international trading partners while enhancing the effectiveness of the standard. 89 Fed. Reg. 44144. OSHA states that, consistent with Executive Order 13563 and the Regulatory Flexibility Act, which call for assessment and, where appropriate, modification and improvement of existing rules, OSHA has reviewed the existing HCS. OSHA states that it determined that the revisions in the final rule “will enhance the effectiveness of the HCS by ensuring employees are appropriately apprised of the chemical hazards to which they may be exposed, thus reducing the incidence of chemical-related occupational illnesses and injuries.” The modifications to the HCS include revised criteria for classification of certain health and physical hazards, revised provisions for updating labels, new labeling provisions for small containers, new provisions related to trade secrets, technical amendments related to the contents of safety data sheets (SDS), and related revisions to definitions of terms used in the standard. The final rule will be effective July 19, 2024. The incorporation by reference of certain

Download PDFThe Occupational Safety and Health Administration (“OSHA”) published a final rule in the May 20th Federal Register updating and revising its Hazard Communication Standard (“HCS”). See 89 Fed. Reg. 44144.OSHA states that the purpose of the final rule is to modify the HCS to:Maintain conformity with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (“GHS”)Align certain provisions with Canada and other United States agenciesAddress issues that have arisen since implementation of the 2012 HCSThe HCS is found at 29 C.F.R. 1910.1200. It was originally promulgated in 1983.The HCS requires that employers communicate with employees about hazardous chemicals to which they may be exposed at work.The information provided by the HCS is typically divided into five main areas:List of hazardous chemicals used within the facilityCreation of a written Hazardous Communication ProgramProper labelling of dangerous chemicalsProviding Material Safety Data SheetsProviding comprehensive staff trainingThe HCS provides certain information about the identities and hazards of the chemicals by requiring:Chemical manufacturers and importers must evaluate the hazards of the