![\"\"](\"https:\/\/blog.thecompliancecenter.com\/wp-content\/uploads\/sites\/7\/2019\/12\/ICC_HazCom2012_Blog.png\")
<\/p>\r\n<\/p>\r\n
It just doesn\u2019t seem possible that the new OSHA standard, known as HazCom2012, has been in full swing for over 4 years now.\u00a0 Of course, the time taken to get everything in place regarding it is still fresh in many people\u2019s memories. I can still remember choosing to work on Memorial Day weekend to help some customers meet the June 1, 2015 deadline.\u00a0 Just as a reminder, that transition was to Revision 3 of the Globally Harmonized System of Classification and Labeling of Chemicals (UNSCEGHS) or Purple Book and the direct section of the Code of Federal Regulations (CFR) that was updated is Title 29 1910.1200.\u00a0 Given that the UN just released Revision 8, the US is a bit behind some other parts of the world.<\/p>\r\n
\r\n\r\n<\/p>\r\n
Don\u2019t worry though, OSHA is already in the process of preparing another update to the standard.\u00a0 However, this will take time given the process involved with updating the CFR.\u00a0 The process was supposed to start in the Fall of 2014 with a Notice of Proposed Rulemaking (NPRM) for an update to Revision 7 of the Purple Book.\u00a0 That didn\u2019t happen and the date moved to Spring of 2018.\u00a0 Again, the process stalled.\u00a0 OSHA is now looking to publish the NPRM this month \u2013 December 2019.\u00a0<\/p>\r\n
\r\n\r\n<\/p>\r\n
This notice of proposed rulemaking, whenever it is published, is supposed to update the OSHA standard to the most recent revision of the Purple Book. \u00a0\u00a0However, this will likely be to Revision 7 and not 8 that was just published.\u00a0 Also, keep in mind that with the allowances under the \u201cbuilding block approach\u201d, not all elements of the latest standard or even the previous ones have to be incorporated into the next update. So, what kind of changes are likely?\u00a0<\/p>\r\n
\r\n\r\n<\/p>\r\n
Expected Revisions to HazCom2012<\/strong><\/p>\r\n \r\n\r\n<\/p>\r\n \r\n\r\n<\/p>\r\n While the list is somewhat short, these changes can have quite an impact when implemented.\u00a0 Even though we are currently in a wait and see situation, I would advise current industry people to focus on the current standard.\u00a0 Since it\u2019s implementation, non-compliance with the standard are consistently listed as one of OSHA\u2019s top 10 violations.\u00a0<\/p>\r\n \r\n\r\n<\/p>\r\n\r\n
\r\n
\r\n
\r\n
\r\n
\r\n