November Letter to the Editor

The “In the News” item titled OSHA instructs inspectors on enforcing hazcom standard links to a compliance directive that has some interesting points that shouldn’t be missed by EHS professionals.

That July 2015 OSHA directive, CPL 02-02-079, specifically states that complying with more recent versions of the Globally Harmonized System of Classification and Labeling (GHS) promulgated by the United Nations (UN) may result in non-compliance with the Hazard Communication Standard (HCS) 2012.

For example, changes in the classification of flammable aerosols under GHS Revision 4 would mean an employer complying with these international standards would be committing a “serious violation” for not meeting OSHA’s HCS 2012 standards, which are based on GHS Revision 3.

Employers and importers should be aware that keeping up with the most current UN GHS standards could cost them when it comes to compliance with OSHA regulations. Despite many similarities, OSHA’s HCS is not a direct reflection of current UN GHS regulations.

Carlo Emami
San Diego, CA