OSHA Issues Enforcement Guidance on New Hazard Communication Standard

Last week the U.S. Occupational Safety and Health Administration (OSHA) issued interim enforcement guidance for the new Hazard Communication Standard which became effective June 1, 2015. The new guidance is temporary in lieu of guidance that will be added to the OSHA Hazard Communication directive later this month. Specifically, the interim guidance notes that, "Where a manufacturer or importer (such as concrete producers) has not received classification information from its upstream supplier(s) on which it intends to rely for the classification of its product before June 1, 2015, the manufacturer or importer may continue use of the HCS 1994 label under certain limited circumstances. To do so, the manufacturer or importer must be able to initially demonstrate it has exercised reasonable diligence and made good faith efforts to obtain and integrate the information. "