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On February 16, 2021, the Occupational Safety and Health Administration (OSHA) published a Notice of Proposed Rule Making (NPRM) to amend the Hazard Communication Standard (HCS). The current HCS was last updated in 2012 to align the standard with the third revision of the United Nations (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The proposed changes are to update the HCS to align it with the seventh revised edition of the GHS.

Highlights of the proposed changes include:

Definitions

• Updates to three existing definitions (exposure/exposed, hazardous chemical, physical hazard)
• Addition of eight new definitions (bulk shipment, combustible dust, gas, liquid, solid, immediate outer package, physician or other licensed health-care professional (PLHCP), and released for shipment)

Hazard Classification

• Clarification that the hazard classification has to consider both normal considerations of use and foreseeable emergencies
• Additional requirements that the hazard classification must include any hazards associated with a change in the chemical’s physical form or […]
  

Section 312 of the Emergency Planning and Community Right-to-Know Act (EPCRA) describes reporting requirements for facilities that possess chemicals above established reporting thresholds. For those facilities subject to reporting, submission of a Tier II Emergency and Hazardous Chemical Inventory Form to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local Fire Department is required by March 1^st of every year for the previous calendar year.

These reporting requirements allow state and local emergency response and planning committees to be aware of the hazardous materials present within their communities and to prepare for emergency responses.

Which facilities have to report?

Facilities storing a hazardous chemical that is an Extremely Hazardous Substances (EHS) in an amount equal to or greater than 500 pounds or above the Threshold Planning Quantity (TPQ), whichever is lower, are required to submit Tier II reports. EHS and TPQs can be found in 40 CFR part 355 Appendix B and the EPA’s […]

OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, is used to summarize the recordable injuries and illnesses for the previous year and includes the number of days work was lost or restricted, and the types of injuries and illnesses that occurred.

Information about the company, including the average number of employees and total hours worked by all employees, must also be recorded.

Form 300A must be posted from February 1 through April 30 each year.  If no recordable incidents or illnesses occurred during the previous year, the form must still be completed and posted reflecting zero recordable cases. The information in Form 300A is based on information recorded in OSHA Form 300, Log of Work-Related Injuries and Illnesses. However, certain employers are exempt from these reporting requirements.

Employers with 10 or fewer employees are not required to prepare Form 300 or Form 300A. In addition, only industries within certain North American Industrial Classification (NAICS) codes are […]