Hazcom Deadline Looming for Manufacturers – Regulatory Compliance

On June 1, 2015, chemical manufacturers, importers, and distributors must be in compliance with all modified provisions of the updated Federal Hazard Communication Standard. As of that date, chemical manufacturers and importers will be required to provide updated chemical labels and safety data sheets – SDSs (replacing old material safety data sheets – MSDSs).

The safety data sheets must follow a new standardized format listing 16 specific sections, ensuring consistency in presentation of important protection information. The labels must include a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.

Dental offices that utilize chemicals must update the SDSs on a continuous basis when new ones become available. It is also a good idea to check the labeling of any new chemicals that arrive onsite to make sure they have updated labels.

Employers have until June 1, 2016 to update the office chemical labeling system (if any) and to make sure that the written hazard communication has been updated to include the new requirements for labeling, safety data sheets, and training.

For users of our SUV Disinfectant and SUV Disinfecting Wipes… Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), disinfectants are considered pesticides, which are regulated by the Environmental Protection Agency (EPA). All disinfectant manufacturers and distributors must follow EPA labeling requirements. For this reason, at this time, OSHA’s Hazard Communication Standard includes an exemption for any pesticide, i.e. disinfectant, as defined in FIFRA:

29 CFR 1910.1200 Hazard Communication

(b)(5) This section does not require labeling of the following chemicals:

(i) Any pesticide as such term is defined in the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136 et seq.), when subject to the labeling requirements of that Act and labeling regulations issued under that Act by the Environmental Protection Agency;