Business photo shows hand written text OSHA

The National Association of Chemical Distributors (NACD) submitted comments May 19 in response to the proposed rule published by the U.S. Occupational Safety and Health Administration (OSHA) regarding Docket No. OSHA-2019-0001, Hazard Communication Standard (HCS).

While supportive of the overall objective, NACD has substantial concerns regarding some of OSHA’s proposals to harmonize the HCS with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

“Revisions to the HCS have a huge impact on NACD members,” said NACD president and CEO Eric R. Byer. “Chemical distributors serve a critical role in the middle of the supply chain, and most of these companies have large numbers of suppliers, products, and customers. Changing safety data sheets (SDSs) and labels for hundreds or even thousands of chemical products is a major undertaking for these companies.”

One NACD member estimates they have 10,000 SDSs to review to meet the new standard and 4,000 to update. Even at OSHA’s .7 hours per SDS estimate, that is 16 months of dedicated work. NACD members are predominantly small regional businesses, many of which are multi-generational and family owned. Some of the proposed changes are not necessary for harmonization and would create excessive burdens for chemical manufacturers and distributors while adding needless complexity and liability to the system, according to the NACD.

NACD is encouraging OSHA to seriously consider the issues and concerns raised in the association’s comments, including proposed changes, implementation and timelines, to ensure effective harmonization of important hazard communications standards while protecting businesses large and small from undue burdens.