In comments submitted to OSHA on Dec. 29, 2009, ORC Worldwide, a global safety and health consultancy based in Washington, D.C., affirms its overall support for this effort, noting that “most of the proposed modifications to the agency’s Hazard Communication Standard (HCS) will increase the quality and consistency of information provided to employers and employees.” ORC also agrees with OSHA’s approach of limiting changes to the HCS to those required for consistency with the GHS, according to a posting on ORC’s safety and health website.
In its letter to the agency, ORC identifies many of the benefits of the proposed changes, including:
- Standardized label elements will be more effective in communicating hazard information;
- Standardized headings and a consistent order of information will improve the utility of Safety Data Sheets (SDS);
- Employee training will support and enhance the effectiveness of the new label and SDS requirements.
ORC also responds to specific questions posed by OSHA in its Notice of Proposed of Rulemaking. For example, ORC agrees with OSHA’s proposal to require that OSHA permissible exposure limits (PELs) be included on the SDS, as well as any other non-mandatory exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet.
One important issue raised by the proposal is the amount of time the regulated community will have to come into compliance with the changes to the HCS. OSHA has proposed that chemical manufacturers, importers, distributors, and employers be required to comply with all provisions of the modified final rule within three years after its publication.
n comments previously delivered to OSHA on this issue, ORC argued that OSHA should consider a company’s place in the manufacturing supply chain in determining how the phase-in is implemented. ORC believes it would be sensible to start with producers of raw materials and basic chemicals. The technical information, classification and categorization they perform will be useful downstream for the intermediate chemical producers and specialty chemical manufacturers.
In its more recent comments, “ORC asks that OSHA reconsider this approach, although we understand OSHA’s view that ‘the supply chain is not always orderly and logical’ and that customer demands and other market forces may result in supply chain coordination that would eliminate the need for a specific phase-in schedule for different types of producers (74 FR 50404).”
An informal public hearing on the rulemaking will begin March 2 in Washington, DC. ORC has filed a notice of intention to provide testimony at the hearing.
