FOCUS ON OSHA & SAFETY

ARA urges members to ensure that the new standard’s requirements are in place at their facilities as the publication of this new OSHA Instruction is sure to bring workplaces under greater scrutiny.

and after the standard is fully implemented on June 1, 2016.

As reported here and in other ARA publications previously, under the standard, employers were required to train workers on the new label elements and safety data sheets by Dec. 1, 2013, including the use of pictograms, signal words, and revised warnings for physical and health hazards. In addition, employ- ers must update their written hazard communication program, any alternative workplace labeling, and provide additional employee training for newly-iden- tified physical or health hazards no later than June 1, 2016.

Chemical manufacturers, importers, and distribu- tors had to comply with revised safety data sheet requirements by June 1, 2015. Manufacturers and importers had to comply with new labeling provisions by June 1, 2015. Distributors have until Dec. 1, 2015,

to comply with labeling provisions as long as they are not relabeling materials or creating safety data sheets, in which case they must comply with the June 1 dead- line.

The OSHA Instruction describes a federal program change, but the state plans are required to establish enforcement policies and procedures, which are as least as effective as the federal instruction. According to industry press, OSHA is already issuing citations to some employers because their workers do not recognize a pictogram or refer to material safety data sheets (MSDSs) instead of the new terminology of SDSs. It is critical for professional automotive recyclers to understand that all hazardous chemicals present at the facility that employees may be exposed to are covered by this standard. It is also important for recyclers to know that inspectors will be looking for any example of noncompliance includ-

52 Automotive Recycling | September-October 2015