Since releasing the original memo “Enforcement Guidance for Hazard Communication Standards” on February 9, 2015, OSHA has received an overwhelming amount of questions relating to the use of HCS 1994-compliant labels on containers packaged for shipment and requests for additional clarification on behalf of manufacturers, importers and distributors.
In response to these questions and requests, on May 29, 2015 OSHA released a memo entitled “Interim Enforcement Guidance for Hazard Communication 2012 (HCS 2012) June 1,2015 Effective Date” which focuses on manufacturers, importers and distributors that have not yet received classification and SDS information from upstream suppliers.
Due to OSHA’s efforts to ensure the additional clarification gets included in the revised Hazard Communication directive there has been a slight delay in completing review and clearance of the directive. The anticipated issuance date for the directive is now set for shortly after June 1, 2015 and this memo will be cancelled upon its issuance.
