OSHA’s updated hazard communication standard requires manufacturers to update Safety Data Sheets (SDSs) to include newly defined hazards. The updated hazard communication standard and required changes to SDSs align with the major 2016 regulatory update to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Manufacturers were required to provide updated SDSs to hazardous chemical users by June 2015, but many manufacturers are still working toward this compliance requirement. This makes it difficult for users of hazardous chemicals to comply with the modified hazard reporting categories included in the EPCRA Tier II inventory report.
To help facilities accurately complete the new hazard category information on EPCRA Tier II inventory forms, the EPA has developed a “crosswalk” in coordination with OSHA to assist facilities in comparing the hazards included on old MSDSs with the hazards required to be included on the new SDSs and reported in the EPCRA Tier II inventory report.
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Regulatory reporting can be challenging under normal circumstances, and can become even harder after a regulatory update or through reporting transitions. VBA is here to help. We are extremely experienced in assisting clients through challenging transitions, including EPA and OSHA updates.
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