Connection Spring 2015 - Page 8

the 33rd annual meeting of united agricultural cooperative, inc. for members and stockholders only Thursday, June 25, 2015 formal invitation coming soon I Be in the know about June 1 deadline for safety data sheets f you’ve been keeping up with the Hazard Communication Standard (HCS) changes, then you probably are aware that there is a June 1 deadline affecting Safety Data Sheets (SDS). But what is this deadline all about? “reasonable diligence and good faith” efforts before issuing citations for non-compliance. As long as a company can demonstrate to OSHA’s satisfaction that they tried to meet the deadline but the information needed was not available, OSHA will not issue a citation. OSHA set June 1, 2015, as the compliance date for all chemical manufacturers, distributors and importers to provide SDSs for their products in the new SDS format, as set out in the HCS-2012 final rule. This deadline does not directly affect chemical users. As indicated above, this deadline is for chemical manufacturers, distributors, and importers. If you are an end user of a chemical, your responsibility is to have the latest available SDS from the source you obtain the chemical from and make it available to your employees. You should use the latest version you have. You should receive updated versions with future deliveries. If you are concerned about the SDS you have, you are always able to contact your chemical manufacturer, distributor or importer to see if an updated SDS is available. Many chemical manufacturers, distributors and importers have expressed concern about meeting this deadline. They can breathe a little easier now, as long as they have tried to obtain the latest information needed for their SDSs. OSHA recently stated through an enforcement guidance that it will take into consideration documented 8