On October 31, OSHA officials responded to a petition from the American Coatings Association (ACA) and other trade associations regarding the June 1, 2014 regulatory deadline.Manufacturers voiced their concern in an August 2014 petition, citing the fact that they may not receive updated SDS’s from their suppliers until June 1, 2015. Therefore, they will be unable to process that information and generate their own GHS compliant SDS’s and labels on time.
OSHA denied the ACA petition, however, the regulatory agency offered a reprieve for certain product manufacturers. In the October 31 letter, OSHA agreed to exercise enforcement discretion in cases where a company has performed due diligence, and made a good faith effort to obtain the necessary information.
What you need to know:
1. The deadline for GHS compliance is still June 1, 2015.
2. OSHA may extend the deadline only if it has determined that a company has made good faith efforts to comply, but was inhibited by obstacles outside of its control.
Note: y You must provide a detailed implementation plan for attaining compliance.
3. ACA encourages companies to document all efforts taken to obtain the required information from suppliers and/orto find other suppliers, orto reinvent the missing information.
More information can be found at the American Coatings Association. For clarification or concerns, please email us at sds@usequantum.com or call 734-930-0009 ext 307.