Criteria for updating the crystalline silica pel
This Instruction outlines the changes in enforcement due to the release of the revised HCS published in the Federal Register on March 26, 2012.
The revised standard changes "hazard determination" to the specific requirements for hazard classification of chemicals, standardizes label elements for containers of hazardous chemicals, and specifies the format and required content for SDSs.
The official, public domain, OSHA version of this document is available at https://gov/Osh Doc/Directive_pdf/CPL_02-02-079
This guidance is not a standard or regulation, and it creates no new legal obligations.
It is only applicable to the labeling requirements of the HCS.
Establishing reasonable diligence and good faith requires that manufacturers or importers demonstrate attempt(s) to obtain the necessary classification or SDSs through both oral and written communications directly with the upstream supplier.
The chemical manufacturer or importer must not wait to create all of its SDSs all at once.So, take a stroll down memory lane to remember all of our past Word of the Year selections.OSHA Instruction, CPL 02-02-038, Inspection Procedures for the Hazard Communication Standard, March 20, 1998.For each hazardous chemical shipped by a manufacturer or importer after June 1, 2015 that does not comply with HCS 2012, the CSHO  must evaluate all of the above factors, any combination of these efforts may be considered to be reasonably diligent and made in good faith.CSHOs shall also consider whether the manufacturer or importer attempted to obtain the hazard information in a timely manner (i.e., in a way that would have enabled it to comply with the June 1, 2015 effective date) in determining whether reasonable diligence and good faith efforts to comply are present.